Response

Comment
DEQ has become increasingly concerned about residential woodstove impacts on urban air quality.
The discussion of firewood as an issue devotes little or no analysis to the impact of the Forest's firewood
policy on smoke in Klamath Falls. DEQ data show severe winter air quality problems in Klamath Falls
attributable to woodstove smoke, not only for short time periods as stated on page 111-9 of the DEIS.
Yet, the preferred alternative results in the highest level of total suspended particulates (TSP) from
prescribed burning of any alternative. Why does that occur? What is the impact of the preferred alternative
on wood stove emissions in Klamath Falls?
Response
The reason the preferred alternative results in the highest level of total suspended particulates (TSP) is
because this alternative has the greatest level of timber harvest. As the level of timber harvest increases
so does the number of acres that require fuel hazard reduction by prescribed burning. As the number
of acres treated by prescribed burning increase there is a corresponding increase in TSP. There are
50 pounds of TSP produced per ton of fuel treated(Reference DEIS, TABLE IV-1, IV-6).
There is no direct correlation between the alternatives and the amount of wood stove emissions in
Klamath Falls. The Forest only supplies a portion of the fuelwood used in Klamath Falls. The Forest
has no control on the type of stove in which the fuelwood is burned nor the air/fuel mixture, nor the
weather conditions that exist when the fuelwood is burned. All of the above listed factors in combination
determine the amount of wood stove emissions.
Comment
You need to develop and analyze particulate levels in Klamath Falls as an indicator of responsive to
the firewood issue. The discussion of air quality impacts in Chapter 4 should address the impact of
each alternative on Klamath Falls air quality. Potential mitigation measures to reduce woodstove smoke
impacts should be addressed. The development of this analysis should be based on the newest
information and monitoring data for Klamath Falls gathered by DEQ. You should not assume, as you
do on page 111-9, that the woodstove certification program will reduce the long-term problem--it will
help, but it will not solve the problem.
Response
There is no direct correlation between the alternatives and the amournt of wood stove emissions in
Klamath Falls. The Forest is just one source of supply for the fuelwood used in Klamath Falls. The
Forest has no control on the type of in which stove the fuelwood is burned nor the air/fuel mixture, nor
the weather conditions that exist when the fuelwood is burned. All of the above listed factors in combination
determine the amount of wood stove emissions.
There are two mitigation measures which could be implemented to help reduce the emission levels.
The Forest could refrain from selling fuelwood to the people living in Klamath Falls or the Forest could
limit the season of fuelwood gathering. These would be effective if all sources of fuelwood were managed
to implement the same mitigation measures. The Forest is willing to work with Klamath County to implement
mitigation measures if requested by the County Commissioners.
Comment
Regarding air quality, the Department's primary concerns are those of air quality impacts from forest
prescribed burning and the burning of the Forest's fuelwood by the public within urban areas. Because
of the serious nature of the air quality problem in Klamath Falls during the winter months, it is very
important that the Winema National Forest Smoke Management Plan treat the Klamath Basin as a
smoke sensitive area
Response
The Forest does treat Klamath Falls as a smoke sensitive area. prescribed bum activities are conducted
according to the voluntary smoke management advisory issued by the Oregon Department of Forestry,
Salem office. The advisory is developed with the objective of keeping smoke out of Klamath Falls. In
addition, the smoke from prescribed burns are monitored. If the advisory is wrong and the smoke
appears to be heading for Klamath Falls the burn would be halted. It should, however, be noted that
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