SUMMARY:

The Bureau of Land Management proposes a ten-year timber management plan for for the 488,258 acres of public land in the Jackson & Klamath Sustained Yield Units of the Medford District. Proposed annual timber harvest is 20.55 million cubic feet (120 MM bd.ft.) consisting of 115 MM bd. ft. as sustained yield allowable cut from high intensity forest management land and 5 MM bd. ft. as trial harvest from low intensity forest management land not included in the sustained yield computation base. Treatments specified by the proposal include road construction; harvest by two-stage shelterwood, clearcut, and single tree selection methods; slash disposal; site preparation; planing of trees; herbicide application precommercial thinning; fertilization; and commercial thinning. This proposed action would reduce annual timber harvest from the Jackson & Klamath SYUS by 1.38 million cubic feet (8 MM bd.ft.). Air quality would be adversely affected by particulates from slash burning. Adverse impacts to soil and water resources would be of a lesser magnitude than under the present program, but significant adverse site-specific impacts would still occur within the proposed action.

GO.TTACT

STATE ID NO:

ESTIMATED APPLICATION FILING DATE:

This office deals with air quality and is responsible for the development of air quality maintenance plans for transportation related air pollution, and works closely with the State Department of Environmental Quality in developing complete air quality plans. Comments provided, by this office, will be limited to those dealing directly with air quality.

Section 2.2, page 2-4, describes current air quality conditions within the 27-1 Medford-Ashland air quality maintenance area. Unfortunately, the information cited is no longer considered an accurate description of this air shed.

Levels of particulates in ambient air are reported, most commenly, as a geometric mean of the annual sampling data. Unusual daily levels are discounted, thus attainment of the ambient air quality standards are based on the annual goemetric mean of regularily taken samples, normally on an every sixth day frequency. As reported in the Oregon Air Quality Annual Report of 1977, and testimony of the director of the Department of Environmental Quality, submitted at a hearing of the Joint Legislative Committee on Trade and Economic Development, the Medford-Ashland air shed is experiencing a worsening of air quality, not an improvement.

Until such time as attainment with ambient air quality standards is shown, at the least, new sources of particulate emissions are subjected to a stringent off-set rule, which requires a greater than one-for-one reduction in total emissions prior to the start-up of a new source. This rule applies only to 19

new industrial sources, though debate now surrounds grass seen burning in the Willamette Valley.

The table below summarizes recent particulate air quality, noting a health standard of 75 micrograms per cubic meter (75m/grms/m3) and a state of Oregon standard, equal to the federal secondary standard of 60 m/grms/m3.

2) Increased emissions from slash disposal will be accounted for in
an overall total emission reduction plan, which could result in
additional industrial emission controls being necessary.

3) Due to severity of existing problems and the increased emissions this
Timber Management plan represents, the local timber industry may not be
able to accommodate the increased forest harvest, due in part to off-set
requirements.

Clearly the air shed is experiencing a worsening in air quality. The MedfordAshland air quality maintenance area is now being designated as a primary standard nonattainment area, with additional control strategies needed prior to March of 1980.

I recommend that the plan include provisions for some alternative means of slash disposal, such that emissions may be reduced substantially. Furthermore, the air quality information portions should be corrected to represent current information.

The Timber Management plan represents a new source of particulate emissions, some of which will impact the air shed. The impace associated with slash burning may result in a number of effects unaccounted for in Section 3.2. They are listed below:

27-1 The downward trend in particulate levels was for the number of violations occurring annually. The text of Section 2.2 of the FES was changed to reflect this, and to include the data on worsening ambient air quality with respect to particulate levels.

27-2

The text in Section 2.2 has been changed to include the information provided, and these changes are reflected in Section 3.2.

Appendices

App.