Oregon

Area Designations For the 

24-Hour Fine Particle National Ambient Air Quality Standards

) standard.   A county (or part thereof) is designated as nonattainment
if it has an air quality monitor that is violating the standard or if
the county is determined to be contributing to the violation of the
standard. 

 

Area	Oregon Recommended Nonattainment Counties	EPA’s Designated
Nonattainment Counties

Klamath County, partial	Klamath County, partial, Klamath Falls Air
Quality Zone 	Klamath County, partial, Klamath Falls Air Quality Zone 

Lane County, partial	Lane County, partial, Oakridge Urban Growth
Boundary	Lane County, partial;

T37S R9E Sections 31-32

T38S R8E Sections 1-5, 8-16, 22-26, 35-36

T38S R9E Sections 5-8, 14-15, 17-36

T39S R8E Sections 1-2, 11-13, 24

T39S R9E Sections 1-27

T39S R10E Sections 3-10, 15-20, 29-30





Aside from the areas designated nonattainment, EPA has designated the
remaining portions of Klamath and Lane Counties and all other counties
in the state as “attainment/unclassifiable”, including all lands in
Oregon within Indian Country.   EPA designated a county or portion of a
county as unclassifiable only when it did not have any data, or had air
quality monitoring data for the 2005-2007 time period that was not
complete and could not be used for determining compliance with the
standard.

EPA Technical Analysis for Klamath County 24 hour PM2.5 Nonattainment
Area:

Introduction   

 standard and evaluates nearby counties for contributions to fine
particle concentrations in Klamath Falls.   EPA has evaluated these
counties based on the weight of evidence of the following nine factors
recommended in EPA guidance and any other relevant information:   

- pollutant emissions

- air quality data

- population density and degree of urbanization

- traffic and commuting patterns

- growth

- meteorology

- geography and topography

- jurisdictional boundaries

- level of control of emissions sources

We also used analytical tools and data such as pollution roses, fine
particle composition monitoring data, back trajectory analyses, and the
contributing emission score (CES) to evaluate these areas. (See
additional discussion of the CES under factor 1 below.)

 

Figure 5.25 is a map of the counties in the area and other relevant
information such as the locations and design values of air quality
monitors, the metropolitan area boundary, and counties or portions of
counties recommended as nonattainment by the State.

Figure 5.26 below is a map of the partial Klamath County nonattainment
area, including topography.   The nonattainment area is also the County
designated Air Quality Zone identified by the red boundary line.

Figure 5.26   Nonattainment area (Klamath Falls Air Quality Zone)
partial county designation

 NAAQS are from Federal Reference Method (FRM) monitors located in the
state.   

In August 2008, EPA notified Oregon by letter of its intended
designations.   EPA’s initial intended designation for Klamath Falls
was a partial county designation with an area significantly larger than
the Klamath Falls UGB that roughly followed mountain ridge topography to
the east, north and west of Klamath Falls and south to the California
border.   In this letter, EPA also requested that if Oregon wished to
provide comments on EPA’s intended designation, it should do so by
October 20, 2008.   EPA stated that it would consider any additional
information (e.g., on power plants or partial county areas) provided by
the state in making final decisions on the designations.   Oregon
provided two letters dated October 2, 2008 and October 20, 2008,
providing additional information on the Klamath Falls area.   See letter
from Governor Theodore R. Kulongoski dated December 17, 2007, letter
from Dick Pederson, Director, Oregon Department of Environmental Quality
dated October 2, 2008, and letter from Andy Ginsburg, Air Program
Administrator, dated October 20, 2008.   In addition, Oregon provided
EPA an e-mail “power point” and oral presentation on October 30,
2008, that also included additional information on the Klamath Falls
area.   All of these materials are included in the docket for this
action.

Based on EPA's technical analysis described below, EPA has designated a
portion of Klamath County as nonattainment for the 24-hour PM2.5
air-quality standard as part of the Klamath Falls nonattainment area,
based upon currently available information.   The portion of Klamath
County designated nonattainment is described below.   To clearly define
a legal boundary of the nonattainment area, EPA used
‘township-range’ nomenclature that closely mimicked the Klamath
County designated AQZ.   Thus, the current AQZ boundary description is
slightly different from the nonattainment boundary.

Klamath County	State-Recommended Nonattainment Counties	EPA-Final
Designated Nonattainment Counties

Oregon	Klamath County, partial, Air Quality Zone	Klamath County,
partial, 

T37S R9E Sections 31-32

T38S R8E Sections 1-5, 8-16, 22-26, 35-36

T38S R9E Sections 5-8, 14-15, 17-36

T39S R8E Sections 1-2, 11-13, 24

T39S R9E Sections 1-27

T39S R10E Sections 3-10, 15-20, 29-30





The following is a technical analysis for the Klamath Falls area of
Klamath County.   This analysis determined whether a multi-county or
partial county designation was appropriate

Factor 1:   Emissions data

For this factor, EPA evaluated county level emission data for the
following PM2.5 components and precursor pollutants:   “PM2.5
emissions total,” “PM2.5 emissions carbon,” “PM2.5 emissions
other,” “SO2,” “NOx,” “VOCs,” and “NH3.”   “PM2.5
emissions total” represents direct emissions of PM2.5 and includes:   
“PM2.5 emissions carbon,” “PM2.5 emissions other”, primary
sulfate (SO4), and primary nitrate.   (Although primary sulfate and
primary nitrate, which are emitted directly from stacks rather than
forming in atmospheric reactions with SO2 and NOx, are part of “PM2.5
emissions total,” they are not shown in Table 1 as separate items).  
“PM2.5 emissions carbon” represents the sum of organic carbon (OC)
and elemental carbon (EC) emissions, and “PM2.5 emissions other”
represents other inorganic particles (crustal).   Emissions of SO2 and
NOx, which are precursors of the secondary PM2.5 components sulfate and
nitrate, are also considered.   VOCs (volatile organic compounds) and
NH3 (ammonia) are also potential PM2.5 precursors and are included for
consideration. 

Annual emissions data were derived from the 2005 National Emissions
Inventory (NEI), version 1.   See
http://www.epa.gov/ttn/naaqs/pm/pm25_2006_techinfo.html.

EPA also considered the Contributing Emissions Score (CES) for each
nearby county.   In general EPA considers nearby counties as potentially
contributing to nonattainment in the nonattainment county.   The CES is
a metric that considers emissions, meteorological and air quality data
to provide a relative ranking of counties in and near an area.   The CES
is not the exclusive determining factor whether or not to include nearby
counties in the nonattainment area.   A summary of the CES is included
in attachment 2, and a more detailed description can be found at:

http://www.epa.gov/ttn/naaqs/pm/pm25_2006_techinfo.html#C. ]

Table 1 shows annual emissions of PM2.5 and precursor pollutant
components (given in tons per year) and the CES for violating and
potentially contributing counties for the partial Klamath County
designation.   Counties are listed in descending order by CES.

Table 1.   PM2.5 Related Emissions and Contributing Emissions Score

County	State Recom-mended Non-attain

ment?	CES	PM2.5

emissions 

total

(tpy)	PM2.5

emissions 

carbon

(tpy)	PM2.5

emissions 

other

(tpy)	SO2

(tpy)	NOx

(tpy)	VOCs

(tpy)	NH3

(tpy)

Klamath County 	Yes	100	3760	575 	7377	2205	1502	15688	2004

Jackson

County	No	18	5246	1368 	8109	3123	2049	21736	1446

Siskiyou County, Ca.

13	3264	347 	4467	2038	1183	10723	1055

[Footnotes or notes]



Jackson County, Oregon and Siskiyou County, California are identified as
two nearby counties that could contribute to violations at the Peterson
School site in Klamath Falls.   Jackson County is located west of
Klamath County.   The major urban area in Jackson County is the
Medford-Ashland area approximately 60 miles west of Klamath Falls over
the Cascade Mountain range.   

Siskiyou County, California is located to the south on the
Oregon-California border.   There is no major metropolitan area in
Siskiyou County and is characterized as mountainous forest and
wilderness areas with limited ranching and agriculture.   Small
population centers are located on the north-south Interstate-5 corridor
more than 100 miles to the south west of Klamath Falls.   The following
nine factor analysis will determine whether these counties need to be
included in the nonattainment area for Klamath Falls.

Thus, in considering emissions in Table 1 above, emissions of total
PM2.5 emissions are of primary concern.   PM2.5 emissions from each
county are of the same order of magnitude, ranging from 3264 t/yr in
Siskiyou County to 5246 t/yr in Jackson County.   

 Thus, despite similar emissions it is unlikely that any emissions from
these counties impact the violating monitor, and that neither of these
counties is appropriate for inclusion in the nonattainment area based on
this factor.

Table 1 above does not present daily emissions for the winter season
when exceedances

during the season when exceedances are recorded, are considered.

Daily worst case emissions were used in previous Oregon SIPs for the
purpose of demonstrating that the proposed control strategy would be
adequate to attain the 24 hour NAAQS under worst case situations.  
Oregon continues to use daily worst case emissions in its air quality
planning efforts to assess those sources that contribute to high daily
levels of air pollution..

 for the Klamath Falls UGB is found in the PM-10 maintenance plan for
Klamath Falls PM-10 nonattainment area.   PM-10 is particulate matter
with an aerodynamic diameter of 10 micrometers or less.   Thus, PM-10
contains the fine particle fraction (PM2.5).   Wood smoke is primarily
in the fine particle fraction and the PM-10 emission inventory can
provide some insight into sources that contribute to PM2.5   

If RWC is a significant contributor to the PM-10 emission inventory, it
would also be significant for PM2.5.   

The PM-10 inventory shows the 1996 emission 24-hour distribution as
follows:

Residential Wood Combustion: 75%

Industry: 22%

Winter Road Sanding: 1%

Transportation: 1%

for Klamath County and the Klamath Falls AQZ.   Data for Table 2 was
provided by the State in its Oct 2, 2008 letter.

:

	Area sources

(lbs/day)

	Point sources

(lbs/day)

	Nonroad mobile sources

(lbs/day)

	On road mobile sources

(lbs/day)

emissions

Klamath County 	20326	3319	423	205

	24273

AQZ	9301	2953	153	149	12556



   problem.

Figure 5.27.   A portion of Klamath County showing location of
industrial point sources:

Both the AQZ and nonattainment boundary encompass the industrial sources
of the County.

Figure 5.28 Worst case day emission distribution in the AQZ.   

Summary of analysis of emissions:   Emissions from nearby counties do
not contribute to exceedances in Klamath Falls due to topography and
distance. The AQZ incorporates all the industrial sources in Klamath
County and most of the county wide area source emission and in
particular residential wood combustion, suggesting that a partial county
designation covering the AQZ is appropriate under this factor.

Factor 2:   Air quality data 

Air quality data are considered in this analysis for three reasons: to
determine whether a monitor violates the NAAQS, to help determine the
extent of the areas contributing to the   violations, and to identify
the PM2.5   composition on days with exceeedances of the 24-hour PM2.5
NAAQS.      

NAAQS for designation purposes.   The Klamath Falls air quality data
meet these requirements.

This factor considers the 24-hour PM2.5 design values (in µg/m3) for
air quality monitors in Klamath County and counties nearby the Klamath
Falls area based on data for both the 2004-2006 and 2005-2007 period.  
A monitor’s design value indicates whether that monitor attains a
specified air quality standard. The 24-hour PM2.5 standards are met when
the 3-year average of a monitor’s 98th percentile values are 35 µg/m3
or less.   A design value is only valid if federal minimum data
completeness criteria are met. 

NAAQS.

Table 3.   Air Quality Data 

County	State 

Recommended

 Design 

Values, 2004-2006

Design 

Values, 2005-2007

(µg/m3)

Klamath County, Or.	Yes	48	47

Jackson County, Or.	No	34	33

Siskiyou County, Ca.	No	No data available	No data available



Further data for the Peterson School site are shown in Table 4, which
lists all of the days that the 24-hour PM2.5 NAAQS were exceeded.   All
exceedances occur during the winter heating season beginning in November
and ending by February.    

Exceedance Days & Values:   Peterson School, Klamath Falls, Oregon

	2005				2006				2007

Date	Value

(ug/m3)	Date	Value

(ug/m3)	Date	Value

(ug/m3)

1/13/05 	49.9	1/23/06	47.5	1/15/07	39.7

1/16/05 	46.4	12/4/06	51.2	1/18/07	55.6

1/19/05 	50.5	12/31/06	52.6	1/24/07	35.3

1/22/05 	49.2

	11/23/07	39.6

10/31/05	43.3





11/18/05	38.7





11/21/05	37.3





11/24/05	35.2





12/06/05 	44.2





12/12/05	46.8







 NAAQS.   There are no monitors in Siskiyou County.   However, the
absence of a violating monitor alone is not a sufficient reason to
eliminate nearby counties as candidates for nonattainment status.   Each
nearby county has been evaluated based on the weight of evidence of the
nine factors and other relevant information.   In addition, the
technical analysis will determine whether only a portion of Klamath
County be designated nonattainment.   

 NAAQS in this area.



Figure 5.29 – PM2.5 Speciation Data from November 8, 2007 (36 ug/m3)
measured at the Peterson School monitor:

Speciation Data from December 14, 2007 (51.5 ug/m3), measured at the
Peterson School monitor)

EPA independently analyzed the composition of mass on filters from the
Peterson School site.   Figure 5.31 below shows this information.

Figure 5.31:   EPA analysis of filters from Klamath Falls

Summary of Air Quality Factor:

NAAQS,

Exceedances in Klamath Falls occur in the winter,

Chemical composition of filters shows that total carbon dominates filter
mass indicating wood smoke.

Based on this factor, areas within Klamath Falls that account for
woodsmoke emissions are appropriate for inclusion in the nonattainment
area.   The AQZ and EPA’s nonattainment area encompasses the bulk of
woodstove emissions in Klamath Falls.

Factor 3: Population density and degree of urbanization (including
commercial development)

Table 5 below shows the 2005 population for each county in the area
being evaluated, as well as the population density for each county in
that area.   Population data gives an indication of whether it is likely
that population-based emissions might contribute to violations of the
24-hour PM2.5 standards. 

Table 5.   Population

County	State Recommended Nonattainment?	2005 Population	2005 Population
Density (pop/sq mi)

Klamath County, Or.	Yes, partial, Klamath Co. AQZ	65,803	10.6

Jackson County, Or.	No	195,151	70

Siskiyou County, Ca.	No	45,066	7



Klamath County is located in south central Oregon on the east slope of
the Cascade mountain range and encompasses 6,135 square miles. Average
population density is 10.6 people per square mile.   Outside the Klamath
Falls AQZ the population density is approximately 3 people per square
mile.    Klamath County is arid, high elevation, forested and desert
land with little population.   Over 70% of the county’s population
resides within the Klamath Falls Air Quality Zone.   

Jackson County is located to the west of Klamath Count and is the 6th
largest county in Oregon covering 2800 square miles.   Seventy one
percent of the population resides in 11 incorporated cities centered
along the Interstate-5 corridor and includes the cities of Medford and
Ashland.   Approximately half of the county population lives in Medford
and Ashland.   Approximately 58,330 live in unincorporated areas.   The
population centers are separated from Klamath Falls by the Cascade
Mountain Range.   This topographical barrier prevents Jackson County
emissions being transported into Klamath Falls.

Siskiyou County is located to the south of Klamath County and covers
6347 square miles.   The largest city in the County is Yreka with a
population of approximately 7300 (2000 census).   Yreka is approximately
100 miles south-west of Klamath Falls.   Due to the distance and low
population of Yreka and low population density of the County, emissions
from Siskiyou County do not contribute to exceedances recorded in
Klamath Falls. 

   

Klamath Falls population based on 2005 U.S. Census Bureau:

Klamath Falls Air Quality Zone:	53,965	

Klamath County:			65,055

Most of the population of Klamath County resides within the Klamath
Falls AQZ.

Based on this factor in conjunction with information on sources of
emissions and topography only the Klamath Falls AQZ should be included
in the nonattainment area.

Population Growth

The Klamath Falls area is growing but largely within the urban growth
boundary. Klamath County is predicted to have an overall grow rate of
0.5% per year for the next five years. In the city of Klamath Falls, the
anticipated growth is slightly less than 1.0%. However, as a result of
Oregon’s land-use laws much of that growth will occur in the major
metropolitan area of Klamath Falls.

Population density and topography maps:

Figure 5.32:   This map shows the topography for Klamath County.



Figure 5.33 Map showing the topography surrounding Klamath Falls:

Figure 5.34:   Population density in the Klamath Falls area of Klamath
County   

Klamath Falls has the highest population density in Klamath County, and
also contains a

major concentration of woodstove usage. Figure 5.35, shows U.S. Census
data (2000) for

households using wood as the primary source of heat equal or greater
than four heating

units per square mile.

Figure 5.35:   Shows the woodstove density in the Klamath Falls area:

Figure 5.36 Agricultural lands in the Klamath Falls area

There are roughly 16,000 acres of cereal grain, 100,000 acres of forage
and 4,000 acres

of vegetables grown in the Klamath irrigation project, a major project
south of Klamath

Falls. Agricultural harvest activity occurs between August and October
and field burning

is completed by mid-October at the completion of the harvest. Grain
fields are flood

irrigated beginning in November and remain flooded until March when
planting activity

 exceedances.



Figure 5.36 Federal, State, Agricultural, Forested, and Range Lands in
the Klamath Falls area

South of Klamath Falls there are over 30,000 acres of federally and
state managed lands (Figure 5.36). There are U.S. Fish and Wildlife
refuge properties that comprise a total of 11,126 acres. The Bureau of
Land Management (BLM) also manages 14,021 acres of land within the
boundaries of the EPA proposed NAA. The BLM also manages 41 acres of
land within the Air Quality Zone. In addition, the Oregon Department of
Forestry manages 2,435 acres.

The U.S. Fish and Wildlife service manage its lands which includes
farming and burning

of the lands. The BLM activities include managing range resources and a
small amount

of timberlands. Any burning of these lands does not occur during
stagnant periods and is

conducted outside of the winter exceedance season

Based on this factor in conjunction with information on sources of
emissions and topography only the Klamath Falls AQZ should be included
in the nonattainment area.

Factor 4: Traffic and commuting patterns 

This factor considers the number of commuters in each county who drive
to another county within the Klamath Falls area, the percent of total
commuters in each county who commute to other counties within the area,
as well as the total Vehicle Miles Traveled (VMT) for each county in
thousands of miles (see Table 6). A county with numerous commuters is
generally an integral part of an urban area and is likely contributing
to fine particle concentrations in the area.   

Table 6.   Traffic and Commuting Patterns

County	State Recommended Non-attainment?	2005 VMT

(million annually)	Number Commuting within and into any violating
counties 

	Percent

Commuting in and into any violating counties 

	Number Commuting in and into   statistical area 	Percent

Commuting in and into statistical area 

Klamath County	Yes	807	24,920	                     97	24860	97

Jackson County	No	1,948	360	                        0	200	0

Siskiyou County, Ca.	No	525	220	                        1	280	1



The listing of counties on Table 5 reflects a ranking based on the
number of people commuting within Klamath County and people in nearby
counties commuting into Klamath County. 

Table 6 indicates traffic and commuting pattern data for Klamath County
as well as surrounding counties. The annual VMT in Klamath County is
over 800 million miles. For comparison, the annual 2005 VMT for Jackson
County, was about 2000 million miles annually.   Medford, located in
Jackson County is the closest major city to Klamath Falls and is the 8th
most populous city in Oregon. Percent commuting into Klamath Counties
from surrounding counties is very low, less than 2%.   Klamath County is
not urbanized.   EPA believes that this low VMT commuting from nearby
counties into Klamath County, along with the low degree of urbanization
and rugged terrain features that separate Klamath Falls from surrounding
counties, indicate that commuters from surrounding counties do not
contribute to violations. A partial county boundary for Klamath County
of the Klamath Falls AQZ is sufficient to capture all potential mobile
sources contributing to the violations of the monitor in Klamath Falls.

The 2005 VMT data used for table 5 and 6 of the 9-factor analysis have
been derived using methodology such as that described in "Documentation
for the  2005 Mobile National Emissions Inventory, Version 2," December
2008, prepared for the Emission Inventory Group, U.S. EPA.  This
document may be found at:
ftp://ftp.epa.gov/EmisInventory/2005_nei/mobile_sector/documentation/200
5_mobile_nei_version_2_report.pdfNote:  The 2005 VMT data used for table
5 and 6 of the technical analysis were derived using methodology similar
to that described in “Documentation for the final 2002 Mobile National
Emissions Inventory, Version 3, September 2007, prepared for the
Emission Inventory Group, U.S. EPA.  This document may be found at:
atftp://ftp.epa.gov/EmisInventory/2002finalnei/documentation/mobile/2002
_mobile_nei_version_3_report_092807.pdf

The 2005 VMT data were taken from documentation which is still draft,
but which should be released in 2008.

Factor 5:   Growth rates and patterns   

This factor considers population growth for 2000-2005 and growth in
vehicle miles traveled for 1996-2005 for counties in Klamath Falls area,
as well as patterns of population and VMT growth.   A county with rapid
population or VMT growth is generally an integral part of an urban area
and likely to be contributing to fine particle concentrations in the
area.   

Table 7, below shows population, population growth for Klamath County
compared to statewide projected growth.   Klamath County anticipates
slower growth than the State as a whole. Due to the low population of
the counties in eastern Oregon, large geographic size, and rural nature
of eastern Oregon, growth rates in neighboring counties were not an
important consideration in our decision making process.   However, EPA
did consider growth within Klamath County.   According to the State’s
analysis, the Klamath Falls area is growing with a predicted growth rate
of 0.5% per year for the next 5 years. This rate is predicted to
increase to 0.71% per year to 2040.   Much of that growth will occur in
the major metropolitan area of the greater Klamath Falls area. 

Table 7;   Klamath county Growth Forecasts

Total Population	2000	2003	2005	2010	2015	2030

Oregon Statewide	3,436,750

3,618,200	3,843,900	4,095,708	4,891,225

Klamath County	63,900	64,600	65,330	66,968	68,851	74,924









Population change	’00-‘03	’00-‘05	’05-‘10	’05-‘15
’15-‘20	’30-‘35

Oregon statewide	104,750	181,450	225,700	251,808	263,550	263,568

Klamath County	          700	       1430	      1638	       1883	     
1744	       2441









Annual Growth Rate	’00-‘03	’00-‘05	’05-‘10	’05-‘15
’15-‘20	’30-‘35

Oregon	1.00%	1.03%	1.21%	1.27%	1.25%	1.05%

Klamath County	0.36%	0.44%	0.50%	0.55%	0.50%	0.64%

Based on this factor the Klamath Falls AQZ appears to be the appropriate
nonattainment area.

Factor 6:   Meteorology (weather/transport patterns)

EPA considered data from National Weather Service monitoring sites,
State operated instruments, and other meteorological monitoring sites in
the area.   Wind direction and wind speed data for 2005-2007 were
analyzed, with an emphasis on “high PM2.5 days” for each of two
seasons (an October-April “cold” season and a May-September
“warm” season).   These high days are defined as days where any FRM
or FEM air quality monitors had 24-hour PM2.5 concentrations above 95%
on a frequency distribution curve of PM2.5 24-hour values.

 values by color; days exceeding 35 ug/m3 are denoted with a red or
black icon.   A dot indicates the day occurred in the warm season; a
triangle indicates the day occurred in the cool season.   The center of
the figure indicates the location of the air quality monitoring site,
and the location of the icon in relation to the center indicates the
direction from which the wind was blowing on that day.   An icon that is
close to the center indicates a low average wind speed on that day.  
Higher wind speeds are indicated when the icon is further away from the
center.]

  

Figure 5.37.   Pollution rose for Klamath Falls

 

As shown in the pollution rose in Figure 5.37, the average prevailing
surface wind directions for high PM2.5 days in Klamath County (Peterson
School site located in the south-east portion of the City of Klamath
Falls) are from the northwest, west and south.   The pollution roses
show that 24-hour PM2.5 concentrations are influenced by low wind speed
and with winds from the northwest during the ‘cool season’ of
October through April.   

values (30-35 ug/m3; yellow dots) were recorded during the warm season
(May through September) with wind direction from the south and
southeast.   Values below 30 ug/m3 (blue dots) were recorded with the
predominant wind from the northwest.    



 levels increase.

levels in Klamath Falls.

Based on this factor in conjunction with information on sources of
emissions and topography only the Klamath Falls AQZ should be included
in the nonattainment area.

Factor 7:   Geography/topography (mountain ranges or other air basin
boundaries)

The geography/topography analysis evaluates the physical features of the
land that might have an effect on the air shed and, therefore, on the
distribution of PM2.5 over the Klamath Falls area.

Figure 5.41:   Elevation contours around Klamath Falls

Klamath Falls lies in a valley at the northern end of the Klamath basin,
a broad valley that extends south into northern California and
surrounded by mountains.   Klamath Falls is at an elevation of
approximately 4500 ft. above mean sea level (MSL).   Surrounding
mountains rise to 5000-6000 ft. MSL.   Figure 5.41 above shows the
contours of the area surrounding Klamath Falls.   The AQZ closely
follows the ridge lines west, north and east of Klamath Falls.   To the
south of Klamath Falls is the Klamath Basin extending into California.  
There are no sources of emissions south of Klamath Falls for several
hundred miles that could contribute to the wintertime exceedances,
especially since high PM levels are associated with calm to low wind
speed.   Thus the southern boundary of the AQZ encompasses all the local
emission sources that could contribute to high PM levels.

Based on this factor the Klamath Falls AQZ follows topographical
features and is an appropriate nonattainment area.

Factor 8:   Jurisdictional boundaries 

In evaluating the jurisdictional boundary factor, EPA gave consideration
to existing jurisdictional boundaries, where relevant.   

This factor was a consideration for Klamath Falls.   EPA considered both
the Klamath Falls UGB as initially recommended by Oregon, as well as the
AQZ a subsequent recommendation by Oregon.    The AQZ meets the
requirements of the Clean Air Act, whereas the UGB does not.   The
nonattainment area for Klamath Falls uses a legal description of
‘township-range’ nomenclature that closely follows AQZ boundary.   

Factor 9:   Level of control of emission sources 

) and for pollutants which react in the atmosphere to form fine
particles (e.g. SO2, NOx, VOC, and ammonia).   

This factor was not a consideration for the Klamath Falls area.

Conclusion

A multi-county designation for Klamath Falls nonattainment area is not
warranted or appropriate.   Emissions from surrounding counties do not
contribute to violations in Klamath Falls.   This fact is due to:

isolation of Klamath County from surrounding counties by topography and
distance,

the large counties in eastern Oregon,

negligible emissions from surrounding counties, 

negligible commute traffic from surrounding counties, and 

great distances to urban areas in surrounding counties.   

A partial county designation is appropriate because:

pollutant emissions are locally generated, primarily from residential
wood combustion,

speciation data indicate that, on exceedance days, the vast majority of
the PM2.5 mass is composed of carbon, an indication of wood combustion, 

exceedances occur during winter heating season where residential wood
combustion is the significant source of pollution,

exceedances occur with calm to low wind speeds where transport from
outside the area is not a consideration,

strong ground-based temperature inversions trap emissions, and

topographical features further trap pollution in the air shed.

Based on analysis of all the factors and analytical tools, EPA concludes
that only the Klamath Falls AQZ is appropriate for designation as
nonattainment for the 24 hour PM2.5 NAAQS in Klamath Falls.   The AQZ
includes all the areas of significant wood smoke emissions and all areas
of potential growth of emissions within the geographic area contributing
to violating monitor. 

 EPA designated nonattainment areas for the 1997 fine particle standards
in 2005.   In 2006, the 24-hour PM2.5 standard was revised from 65
micrograms per cubic meter (average of 98th percentile values for 3
consecutive years) to 35 micrograms per cubic meter; the level of the
annual standard for PM2.5 remained unchanged at 15 micrograms per cubic
meter (average of annual averages for 3 consecutive years).   

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 PAGE   25 

 

 

 

Cite data & provide

 

Move to conclusions section. 

 

Is this sometjhing established for PM10? At a minimum, this needs to be
defined & then explained in terms of PM2.5.

This inventory for PM10 has limited application for PM2.5.

 

Need to define

 

 

Steve, I would like to discuss presentation of this information

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Add citation here or in paragraph that follows. Need this for docket.

 

 

 

 

 

 

 

 

 

 

 

