Response

Comment
Management alternatives should be evaluated with respect to the Clean Air Act and Oregon Clean Air
Implementation Plan requirements. The first issue that must be addressed is that of impacts on air
quality standard attainment and maintenance. Table 1 lists Federal and State of Oregon air quality
standards. Specifically, analysis of the alternatives should demonstrate that the proposed action will
not cause or significantly contribute to air quality standard violations. Air quality impacts within attainment
areas must not exceed Prevention of Significant Deterioration (PSD) increments (Table 2) or cause
violations of air quality standards.
Response
The Forest's analysis shows that emissions are expected to be less than that which occurred during
the baseline period. Therefore, no additional technical analysis is necessary.
Comment
Part C of the Clean Air Act, requires the Department to insure that pollutant increments in Class I areas
(Table 2) do not exceed specific limits adopted by Congress irrespective of the originating source. To
assure that these increments are not exceeded due to planned increases in prescribed burning emissions,
a technical analysis of the impact of planned burns on nearby Class I wilderness and Class II lands
would be required. As noted above, such an analysis would not be required if it can be shown that
the proposed burning activity would not exceed that which occurred during the 1976-1979 baseline
period. If the analysis indicates significant impacts, specific measures designed to mitigate the impacts
must be described in the Forest Plan.
Response
The Forest's analysis shows that emissions are expected to be less than that which occurred during
the baseline period. Therefore, no additional technical analysis is necessary.
All prescribed burning will be conducted in such a manner so as to meet the requires set forth in the
"OPERATIONAL GUIDANCE FOR THE OREGON SMOKE MANAGEMENT PROGRAM." This will assure
that the emission levels do not exceed acceptable levels.
Comment
The Oregon Visibility Protection Plan requires the protection of visibility within Class I areas during the
period of the July 4th weekend to. Labor Day, inclusive. During this period, the Winema Smoke
Management Program must be conducted such that smoke is not intentionally transported into Class I
wildernesses. The Final Forest Plan should evaluate the impact of proposed increases in prescribed
burning activities on the Visibility Protection Plan to assure the continued protection of visibility within
Class I areas.
Response
The Forest's prescribed burn program is conducted in the spring and the fall. Rarely would a prescribed
burn be conducted during the period of the July 4th weekend to Labor Day. Therefore, it is not anticipated
that there is going to be an increased in prescribed burning which would have an impact on visibility
within Class I areas.
Comment
The Department has become increasingly concerned about residential wood smoke impacts on urban
air quality, especially in Klamath Falls. Fuelwood cutting programs managed on the Winema National
Forest is a major and inexpensive source of fuelwood for Southwest Oregon residents. The DEIS does
not discuss the serious environmental consequences of the fuelwood program or it's consistency with
Federal and State environmental policies. Specifically, the DEIS should clearly demonstrate that
woodcutting fees are not subsidizing the public's use of fuelwood. In addition, we would urge the Forest
to distribute at the Supervisor's and District Offices, copies of the Department's public information
brochures on better wood burning practices and to actively promote public education programs intended
to minimize wood smoke problems.
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