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BACKGROUND ..................................................................................................................................................................... 3

AFFECTED ENVIRONMENT .............................................................................................................................................................. 3

DESCRIPTION OF PROPOSED PROJECT AND ALTERNATIVES. ................................................................................................ 9

ALTERNATIVE 1 - NO ACTION. ........................................................................................................................................................ 9

PROJECT DESIGN FEATURES COMMON TO ALL ACTION ALTERNATIVES. ................................................................................................... 9

ALTERNATIVE 2 - PROPOSED ACTION.............................................................................................................................................. 10

ALTERNATIVE 3 – NON-COMMERCIAL. ........................................................................................................................................... 12

ENVIRONMENTAL CONSEQUENCES: AIR QUALITY ............................................................................................................. 12

METHODOLOGY ......................................................................................................................................................................... 12

ALTERNATIVE 1 (NO ACTION) ....................................................................................................................................................... 13

ALL ACTION ALTERNATIVES .......................................................................................................................................................... 14

EFFECTS CONCLUSIONS ................................................................................................................................................................ 15

REFERENCES ...................................................................................................................................................................... 15

Rancheria Forest Restoration Project Air Quality Report

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Background

Affected Environment

General Meteorology, Climatology, and Transport Mechanisms

The analysis area lies within the San Joaquin Valley Unified Air District (See Figures 1 and 2) and the Kern County Air Pollution Control District referenced together as APCD). The San Joaquin Valley has a northwest to southwest orientation, and is approximately 100 miles wide by 300 miles long. The district consists of 24,840 square miles, or about 16 percent of California’s geographic area. The California Department of Finance estimates that the San Joaquin Valley Air Pollution Control District (District) has a population of about 3,174,400. The major urban centers include Bakersfield, Fresno, Modesto, and Stockton. The Class I Domeland Wilderness lies east of the analysis area. The Golden Trout and South Sierra Wilderness areas to the north and east are Class II airsheds.

Air movement can be restricted in both vertical and horizontal directions. Vertical air movement is restricted by radiation and subsidence inversions. In the valley, the inversion base is 500 feet or less (at the surface for a ground-based inversion) in the morning during all seasons. In winter, the inversion base is 1,000 to 1,500 feet or lower throughout the day because heating from the sun is reduced (lower sun angle). During the rest of the year, the inversion base is often lifted by mid-day to 1,500 to 3,000 feet or more. In the summer, the inversion layer can sometimes be entirely destroyed. Local nightly radiation inversions in mountain valleys are also common. Horizontal air movement is restricted by the mountains that surround the San Joaquin Valley on three sides. These include the Coastal Mountains to the west, the Tehachapi Mountains to the south, and the Sierra Nevada to the east. In the spring and summer when the marine layer is shallow, westerly winds enter through low coastal gaps, primarily the Carquinez Straits, and flow down the valley toward the southeast. Daytime wind speeds increase as the valley heats up and are strongest in the afternoon. During storm-free periods in the fall and winter, the airflow is more variable, with light wind speeds resulting in less air movement.

During the day, air near the mountain slopes is heated, resulting in upslope and up-valley winds. With sunset, the process is reversed. Terrain-driven winds provide a means to diurnally transport pollution out of, and back into, the valley (Blumenthal et al. 1985). Several tracer studies have demonstrated pollutant transport into the mountains (Lehrman et al. 1994; Shair 1987; Tracer Technologies

Figure 2: Rancheria Project and APCD boundaries

Figure 1: Air Basins

Rancheria Project


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1992).

The meteorology of the San Joaquin Valley has a significant influence on pollutant transport and ozone and secondary particle formation in the region. Weather patterns moving from California’s Central Valley carry pollutants generated in the valley and deposit them in the central and southern Sierra Nevada foothills and mountains (Zabic and Seiber 1993). A nocturnal inversion forms in the San Joaquin Valley nearly every day of the year. During the winter months, wind flows into the San Joaquin Valley area from the south, with stagnant conditions prevailing except during passage of winter storm systems.

Summer wind patterns in the Sierra Nevada Mountains are complex due to the rugged terrain and intense daytime solar radiation. During the summer months, the predominant surface wind direction in the San Joaquin Valley is from the northwest to southeast, down valley from Stockton towards Bakersfield and out the Kern Valley to the Mojave Desert. This can result in abnormal and strong downslope winds in the project area during the day as air from the San Joaquin Valley flows eastward to fill behind the rising hot air from the desert.

An assessment of the impacts of transported pollutants on ozone concentrations by the California Air Resources Board (CARB) in 1993 indicates that transport of pollutants from the broader Sacramento Area, San Francisco Bay Area, and the San Joaquin Valley has overwhelming impact on the central and southern Sierra Nevada.

Demographics

During the time period from 1980 to 1999, the population of the San Joaquin Valley Unified Air District increased 58 percent, from about two million in 1980 to nearly three million in 1999. The statewide average growth during this period was 43 percent. During this same time, the daily vehicle miles traveled more than doubled in the district, rising from about four million miles in 1980 to over nine million miles per day in 2000, a 125 percent rise compared to a statewide average of 87 percent. Because these growth rates are so much higher than the growth rates in other parts of the state, there has not been the same level of air quality improvement in the San Joaquin Valley Unified Air District, especially with respect to ozone (CARB 2001).

Air Regulatory Structure

The air quality regulatory structure and agencies responsible for compliance are as follows:

Federal – Environmental Protection Agency (EPA) State – California Air Resources Board (CARB) Local – San Joaquin Valley Air Pollution Control District (District) and Eastern Kern County Air Pollution Control District

The Federal government, through the EPA, sets air quality standards, oversees state and local actions, and implements programs for toxic air pollutants, heavy duty trucks, locomotives, ships, aircraft, off-road diesel equipment, and some types of industrial equipment. The role of Federal, state, and local governments is defined in the Clean Air Act and its amendments of 1977 and 1990.

State governments (i.e. CARB) are responsible for developing state implementation plans (SIPs) that describe how each state will achieve the requirements of the Clean Air Act. In California, the SIP is a collection of regulations used to direct the clean-up of polluted areas. EPA maintains oversight authority, must approve each SIP, and can take over enforcement action if reasonable progress is not made. CARB has set more stringent standards, oversees state and local actions, and implements programs for toxic air pollutants, heavy-duty trucks, locomotives, ships, aircraft, off-road diesel equipment, and some types of industrial equipment.

Amendments to California’s Title 17 may directly or indirectly affect prescribed burning in the planning area. The Smoke Management Guidelines for Agricultural and Prescribed Burning (Title 17) is the regulatory basis for California’s Smoke Management Program. The guidelines became effective on March 14, 2001. Local air pollution control districts use these guidelines in local rule development.

Local air pollution control districts in California (e.g., San Joaquin Valley Air Pollution Control District) develop plans and implement control measures in their areas of jurisdiction. These collectively make up California’s SIP. These controls primarily affect stationary sources but do include sources of dust and smoke. The District also conducts public education and outreach efforts. The District is comprised of eight counties that share a common air district: Fresno, Kern, Kings, Madera, Merced, San Joaquin, Stanislaus, and Tulare counties. The following District regulations may directly or indirectly affect prescribed burning in the planning area:

Public Nuisance (Rule 4102) – Prohibits air discharge of material that causes nuisance or annoyance to any considerable number of people.


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Prescribed Burning and Hazard Reduction (Rule 4106) – This rule was adopted June 21, 2001, in response to California’s Title 17, and is designed to permit, regulate, and coordinate the use of prescribed burning and hazard reduction burning while minimizing smoke impacts on the public.

Fugitive Dust (Regulation 8) – The existing Regulation 8 rules were developed to implement control strategies for major sources of dust. These include: construction, demolition, excavation, extraction, handling/storage, landfills, paved/unpaved roads, and open areas. EPA has recently cited deficiencies in these existing rules and the District is evaluating a series of new rules aimed at further reductions in particulates.

Pollutants of Concern

Most of the pollutants that have damaged ecosystems and impaired visual conditions existed to some extent within natural systems. Thus, many native species and ecosystem processes evolved in the presence of these pollutants. In fact, trace amounts of many of these pollutants are required for many biogeochemical processes. However, changed availability (including amount and timing) and changed frequency and duration of exposure can have negative effects on ecosystem elements and processes. The important distinction between these differing effects occurs when amounts of air pollution became greater than historical levels.

The primary air pollutants that can cause detrimental effects to public health or ecosystems, or which can impair visual quality, include particulates, include oxides of sulfur and nitrogen compounds, elemental carbon and oxides, ozone, and toxic air pollutants. A more detailed discussion of these pollutants in provided in Chapter 3 of the SNFPA FEIS (USDA Forest Service 2001b). Air pollutants may result from natural or human processes. Natural pollution may occur from volcanic activity, forest fires, decomposition of plants and animals, soil erosion, pollen and mold spores, volatile organic compounds emitted by vegetation, ocean spray, electrical storms, and photochemical reactions. Human pollution sources include industrial sources, prescribed burning, animal production, agricultural burning, residential and business development, and vehicle emissions.

There are two types of pollutants that may be produced by the proposed project: (1) equipment use is considered a mobile source and (2) prescribed burning is an area source.

Current Air Quality Conditions

The District is considered to be in Federal non-attainment (not meeting standards) for ozone and PM10 (particulate matter less than 10 microns in diameter). The District is considered to be in severe non-attainment for ozone and serious non-attainment for PM10 (Procter 2003).

Visibility conditions in the Sierra Nevada improve from south to north and from low elevations to high elevations. Visibility conditions at Sequoia and Kings Canyon National Parks, one of the southernmost and lowest elevation areas, are some of the worst visibility conditions among western Class I Areas are one of three classes of areas provided for in the Clean Air Act for the Prevention of Significant Deterioration program. Class I areas are the "cleanest" area and receive special visibility protection. They are allowed very limited increases (increments) in sulfur dioxide and particulate matter concentrations in the ambient air over baseline concentrations. The Interagency Monitoring of Protected Visual Environments (IMPROVE) site at Domeland Wilderness is considered representative of visibility conditions in the planning area. This site shows high nitrate concentrations, indicating an urban influence.

Amounts of ozone have increased in the San Joaquin Valley as a result of increased levels of nitrogen compounds and volatile organic compounds. The Forest Service and National Park Service have tracked injury to conifers in the southern Sierra Nevada since 1991. Some of the earliest plots have been evaluated for over 20 years. The data confirms injury in Jeffrey and ponderosa pines, with the bulk of injury occurring in stressed trees. There are inadequate monitoring and research data to fully understand the physiological effects.

Nitrogen compounds in the air have shown an overall increase compared to the native system though the total amount has not been quantified (Bytnerowicz 2003) found that wet deposition of nitrogenous and sulfurous pollutants were the highest at elevations below 7,000 feet on the western slopes of the Sierra Nevada. Deposition from urban and agricultural sources may be approaching saturation in southern areas of the Sierra.


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Smoke Sensitive Receptors.

The Table below lists the name, bearing, and distance from the project of smoke sensitive receptors within a 25 mile radius of the middle of the project area.

Table 1: Smoke Sensitive areas

NAME DISTANCE* BEARING DIRECTION Johnsondale 21 09 N

Alta Sierra 5 33 NE

Riverkern 12 45 NE

Kernville 12 58 NE

Kern Valley Airport 11 70 NE

Wofford Heights 9 70 NE

Onyx 21 86 E

Weldon (South Fork School) 18 91 E

South Lake 14 96 E

Mountain Mesa (Hospital) 11 100 E

Lake Isabella 8 112 SE

Bodfish 8 126 SE

Havilah 12 156 SE

Hart Park/Bakersfield 22 223 SW

Glennville 7 305 NW

Sugar Loaf Area 11 347 N

California Hot Springs/Pine Flat 14 350 N

Poso/Balance Rock 10 352 N *Distance is in air miles from the center of the project area.

The Class 1 air shed of the Dome Land Wilderness is approximately 20 miles northeast of the project and is not likely to be impacted by this project. Normal air flow for the project area is a wind out of the south to west. This will cause smoke from the project to move towards smoke sensitive areas such as Alta Sierra, and the Kern River Valley (Wofford Heights, Kernville, Onyx, Weldon, Mountain Mesa, Riverkern, Lake Isabella, and Bodfish). Impacts to the Kern River Valley should be minor because of the rapid burn down time for hand piles. The Kern Valley Floor is approximately 2700 feet and the burning will be conducted in the 5000 to 6800 foot elevation range where smoke will normally disperse beyond the valley, however, night time subsidence could bring the smell of smoke into the Kern River Valley.

It is not uncommon for afternoon winds to blow downhill towards Lake Isabella in the Sawmill and Alta Sierra areas. It is possible that the smoke from the hand pile burning could cross the Greenhorn Mountains and get caught up in these down sloping winds. Past burning experience indicates that this is unlikely, but it could result in smoky haze in the Kern River Valley and the smell of smoke. Figure 3: Sensitive Smoke areas within 25 miles


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A southwest to west wind would be preferred for smoke transport during ignition and burn down stage. Least desirable wind direction would be northeast to southeast. This would transport wind over the San Joaquin Valley and potentially aggravating existing poor air conditions. Should smoke sensitive areas receive negative impact, the following measures may need to be implemented. During the ignition phase of burning, ignition may be temporarily shut down, fire spread may be stopped and mop-up (extinguishment) of burning fuels may be necessary. During the burn-down phase of the prescribed burn, some mop-up may be required to reduce smoke emissions.

More detailed smoke management procedures will be included in the Smoke Management Plan that will be submitted to the San Joaquin Unified Air Pollution Control District for approval.

Emissions Dispersion

Area Source Emissions – Smoke – Air quality issues and problems concentrate on the quality of air at ground level because most people breath air at ground level. The vast majority of the people in the southern Sierra Nevada occupy low lying areas – basins, valleys and canyons. A basic goal of smoke management is to try and disperse emissions at higher elevations so that smoke does not impact people. Typically, night time smoke is problematic because cooler night time air disperses smoke down drainages and peak concentrations can occur at ground level in low lying areas where most people live under night time inversions. Day time dispersion is generally best and acceptable, and should be especially for the RFRP because the emissions would most likely disperse at higher elevations towards the east and into Nevada, over less populated areas compared to the Bakersfield metropolitan area. The project’s elevation ranges from about 5,500' to about 7,500’ above sea level. Smoke produced at these elevations generally disperses much more efficiently compared to lower elevation areas.

Mobile Source Emissions – Equipment and Chainsaws – The types of total mobile equipment needed to implement the project includes logging equipment, chippers, pick-up trucks, water tenders, fire engines, crew transports and chainsaws. Except for logging equipment, the amount and use of the equipment would be spread out over 10 years and the contribution to air quality levels in Kern County would be insignificant.

Fugitive Dust – Fugitive dust was not analyzed for this project because permanent unpaved roads in the project area are exempt from regulation per SJVAPCD / EKAPCD rules. Generation of fugitive dust is mitigated through watering of native surface roads during operations.

Naturally Occurring Asbestos

A review of the Forest Service's Naturally Occurring Asbestos website showed no mapped asbestos mines or areas more likely to contain naturally occurring asbestos in the RFRP area. (Source: U.S. Forest Service website Naturally Occurring Asbestos, National Forests in California, accessed on 06-20-13, http://www.fs.fed.us/r5/noa/)

Green House Gases and Climate Change

This section discusses the regulatory framework associated with climate change analysis, describes the existing condition, and addresses the direct, indirect, and cumulative effects of the proposed RFRP action and its alternatives on climate change and carbon management.

The Forest Service is currently investing in considerable research and study of the potential effects of forest management on climate change. (See http://www.fs.fed.us/climatechange/). Former Chief of the Forest Service Abigail Kimbell organized an agency wide response to climate change and directed the agency to concentrate on 16 priorities for action. While many of these priorities and much of this information is generally not applicable at the project level, the B FHFRP interdisciplinary team has consulted much of this research and maintained a file of scientific data regarding climate change. That file is part of the project record.

Procedures for evaluating site specific effects to climate change and carbon from a proposed federal action are not well developed. In fact, experimental methods for quantifying both sinks and sources of climate warming gasses from forest management activities are still in various draft stages. (See, for example, the California Climate Action Registry’s protocol for the forest sector.) Moreover, the task of linking potential emissions from small forest projects to world-wide indirect effects such as rising sea levels and extreme weather events is extremely complex, to say the least, and is likely to provide only the most speculative of results.

Nevertheless, the environmental community is currently engaged in an effort to force federal agencies to explicitly consider climate change effects under the NEPA process. This effort has involved petitioning the EPA to revise the NEPA implementing regulations at 40 CFR 1500 et. seq. to include specific instructions for considering the effect of major federal


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actions on climate change. (See, CTA, NRDF, and Sierra Club, Petition Requesting That The Council On Environmental Quality Amend Its Regulations To Clarify That Climate Change Analyses Be Included In Environmental Review Documents, submitted 28 February 2008.) Certain groups have also attempted to use the federal courts to force federal agencies to include climate change analysis in their Environmental Analysis documents (See, for example, Center for Biological Diversity v. National Highway Traffic Safety Administration, 508 F.3d 508 (9th Cir. 2007).)

As a result of both the scientific complexity and the regulatory ambiguity, Forest Service attempts to describe the potential effects of small, site-specific forest projects on climate change are fairly rare. For the RFRP Environmental Assessment, this section will explore the information on the topic provided by various guidance documents, will discuss two proposed approaches, will qualitatively discuss potential climate impacts, and quantitatively track carbon. Finally, this section will conclude that the difference in magnitude of likely effects from any of the proposed alternatives is so small as to provide no meaningful choice for the decision maker.

Regulatory Direction

Council on Environmental Quality

The CEQ considered the question of whether the potential impacts of climate change on a particular proposal are appropriate investigations for the NEPA compliance process. In a DRAFT Memorandum released by Dinah Bear on 8 October 1997, the CEQ said, “Because of the potentially substantial health and environmental impacts associated with climate change, the Council on Environmental Quality is issuing this guidance today calling on federal agencies to consider, in the context of the NEPA process, . . . how climate change could potentially influence [major federal] actions.” The CEQ memo goes on to provide specific instruction to federal agencies: “Agencies need to identify those projects and programs which are most sensitive to climate change effects such as higher temperatures, more severe storms, drier or wetter conditions, and sea level rise. Long range decisions concerning agriculture, forestry, and coastal zone resources, as well as decisions regarding sites for proposed facilities, need to be supported by EAs or EISs which analyze, to the extent possible, the reasonably foreseeable impacts of global climatic change.” This “draft” guidance has not been issued in final form,.

USDA Forest Service Policy

On 16 January 2009, the Washington Office of the USDA Forest Service released guidance to Forest Service units regarding the incorporation of climate change science into project level NEPA documents (USDA 2009). This guidance document provides that units should consider two kinds of climate change effects at the project level. First, units may, where appropriate, consider the effect of a project on climate change. Second, units may, where appropriate, consider the effect of climate change on a proposal. It is unlikely that the NEPA effects analysis process is the proper place for this latter discussion, and this report will not address it further. (See, Hapner v. Tidwell, US District Court for the District of Montana, October 30, 2008.) Instead, this document will focus on the potential effect of the project on climate change. Agency direction defines the emission of greenhouse gases (GHG) as the direct climate change effect of a project. The interaction of emissions with atmospheric concentrations of GHG such that they impact the climate is defined as the potential indirect climate change effect.

Association of Environmental Professionals

In a 2007 document entitled “Alternative Approaches to Analyzing Greenhouse Gas Emissions and Global Climate Change in CEQA Documents,” the Association of Environmental Professionals (AEP) provided practical advice to practitioners regarding methodologies for considering climate change under the California Environmental Quality Act. While the authors explicitly state that the document was not written to address NEPA requirements, it does provide a framework for consideration by federal NEPA process managers. In particular, the AEP’s discussion of the strengths and weaknesses of a wide variety of methods by which an agency can consider the effect of its actions on climate change. Two of those approaches are discussed below.

Screening Analysis

The AEP suggests that, in some cases, an agency may adopt a “screening analysis” which allows it to exempt certain classes or categories of projects from climate change analysis. This approach is similar to the federal NEPA concept of categorical exclusions. That is, there are classes of small, routine actions which have been found not to have a significant effect and are, therefore exempt from detailed documentation in an EA or EIS process. The AEP says that an agency might look to the significance criteria under the CEQA regulations at Title 14, Section 15206 of the California Administrative Code for guidance in screening projects. Alternatively, an agency could choose to use emissions of criteria pollutants as a proxy for analysis of greenhouse gasses. Because emissions patterns tend to be similar, a finding that releases of criteria pollutants were insignificant could lead an agency to conclude that releases of GHG were, similarly, insignificant.


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In this case, there are no accepted screening criteria for Forest Service projects and no regulatory framework for compliance. Following the AEP screening approach might, however, be reasonable in the case of small forest restoration and fuels reduction projects such as this project. When considered against the significance criteria enumerated by the state of California, the proposed actions are clearly insignificant. For example, the CEQA regulations include the construction of industrial parks employing 1,000 people and enclosing 650,000 square feet of floor space (Section 15206(b) (2) (E)) as a potential threshold activity. In contrast to this permanent and essentially irreversible impact on the natural world, the RFRP proposal to remove small and medium trees and surface fuels from approximately 2,700 acres will have only temporary and insignificant natural resource and environmental effects.

Qualitative and / or Quantitative Analysis

USDA Forest Service guidance on climate change analysis suggests that two approaches might be possible, quantitative and/or qualitative. In some cases, such as prescribed burning projects, tools may be available for quantitative analysis of GHG emissions or carbon life cycle — the WO guidance mentions FOFEM, CONSUME, and Forest Vegetation Simulator (FVS) in this context. In other cases, describing the nature of the potential emissions rather than their “specific magnitude” may be a good approach. Overall, however, the guidance document points out that “GHG emissions and carbon cycling should be considered in proportion to the nature and scope of the Federal action in question and its potential to [] affect emissions . . . .without enough scientific understanding to draw conclusions about the significance of the quantitative results, qualitative discussions about the potential about the potential” Because this project is of a very small scale, a qualitative approach seems more appropriate.

Similarly, the AEP’s suggestion for projects where quantitative analysis and/or significance conclusions are unavailable or purely speculative is to use a “qualitative analysis without significance determination.” The AEP’s approach includes a discussion of the project and its potential GHG emissions, but does not speculate on significance. The AEP says that this might be the most appropriate approach for small projects which will have very little information about the effect of potential emissions. Two keys to this approach, according to the AEP, are to provide a rationale for using it and to make a good faith effort at disclosure. This remainder of this document does just that. This report demonstrates a good faith attempt to disclose the potential effect of GHG emissions and carbon sequestration associated with the Rancheria Forest Restoration Project and provides reasons for the conclusion that meaningful determination of significance regarding effects of the project beyond local effects and adherence to air resource control board rules cannot be made.

Climate change

The Sequoia National Forest has experienced increases in temperature of about 1 to 1.5 degrees Celsius over the last ¾ century and most high elevation locations on the Forest have experienced moderate increases in precipitation, while most low elevation locations have seen a precipitation drop (Meyer and Safford, 2010). The onset of spring thaw in most major streams in the central Sierra Nevada occurred 5-30 days earlier in 2002 than in 1948, and peak streamflow occurred 5-15 days earlier. Rising winter and spring temperatures appear to be the primary driver of these patterns (Stewart et al. 2005).

Description of Proposed Project and Alternatives.

The proposed action and alternatives are briefly summarized here. For full details please see the environmental

assessment.

Alternative 1 - No Action.

Under the No Action alternative, no change from the current management direction or level of management intensity would take place. No fuels treatment, tree thinning/removal, or ecological restoration would be implemented.

Project Design Features Common to All Action Alternatives.

Air Quality

• Project is subject to San Joaquin and Eastern Kern County Air Pollution Control District Rules and Regulations, rule 417 for Agricultural and Prescribed Burning and Smoke Management Guidelines for Prescribed Burning under Title 17 of the California Code of Regulations.

• Roads would be watered during timber harvest activities for dust abatement. (Alternative 2)

Fire / Fuels


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Fuel reduction prescriptions were developed based on site-specific needs based on the current fuels and vegetation conditions and predicted post-harvest fuel levels. The following design features would be implemented for this project to meet the purpose and need:

• Hand piles – Hand piles would average six feet in diameter and six feet or less in height; piles would be a maximum of ten feet in diameter. Material to be piled would include all material not removed by yarding or needed to maintain a minimum of 50 percent soil cover and retention of 10-15 tons per acres of large woody debris to meet soil quality and wildlife habitat needs.

• All material piled would be bucked to facilitate construction of piles. Piles would be located away from residual snags or live trees to protect them during burning of the piles. Piles would be located and lined as needed to prevent the spread of fire from one pile to the next.

• Yarding/piling/removal – Woody material may be removed from the site by ground based equipment to landings or disposal sites. Yarding and piling of woody material would occur as needed to meet the desired fuel loadings.

• Roadside fuelbreaks – Removal or disposal of dead vegetation in excess of 10 to 15 tons per acre adjacent to roads. Material too large to hand pile would be yarded prior to disposal (e.g. by burning, chipping, or making the material available for firewood). Smaller diameter material would be hand piled and burned on site.

Alternative 2 - Proposed Action.

The Kern River Ranger District of the Sequoia National Forest analyzed 5,880 acres of National Forest System (NFS) lands treatment using a combination of commercial timber harvest, hand thinning, and prescribed fire/wildfire utilized for integrated objectives of ecological restoration. Three hundred eighty-one acres consist of old growth chaparral. It was determined that this area could not be successfully treated and is shown as “no treatment proposed”. Thinned trees, hazard trees, and other vegetation found to be in excess of fuels and forest health needs would be utilized under a timber sale or other forest product contract.

The Kern River Ranger District proposes to restore a healthy, diverse, fire-resistant forest structure within the Rancheria project through vegetative treatments that reduce stand densities and fuel loads. The project seeks to accelerate restoration of late-successional/old forest conditions, across the landscape, using appropriate prescriptions to restore natural stand heterogeneity, including historic tree stand structure, size class distribution and tree species composition. Stand exams of 177 plots were completed in 2011 and used to generate proposed restoration treatments.

The following table provides a summary of treatments and acreage proposed for each of the following existing conditions:

• Natural stands consist of second-growth forests typically overstocked with shade tolerant species.

• Plantations consist of 30-40 year old pine plantations that lack diversity of species, structure or size.

• Meadow is located near Evans Flat Campground and is experiencing conifer encroachment.

• Chaparral is identified as having unique, old manzanita habitat, susceptible to stand replacing fire.

• Goshawk PAC is a protected activity center which will be hand thinned only and burned.

Stands within the project are identified with a unique planning identifier and are called treatment units (unit numbers). Many of the treatment units have multiple treatment prescriptions.

Vegetation Treatments and Methods

The proposed action will involve the following vegetative thinning treatments to promote heterogeneity and allocate growing space consistent with historical stand structures. The prescriptions are designed to maintain the suitability of sensitive species habitat, while remaining meeting fuels and fire objectives.

Table 2: Alternative 2 - Proposed Action

Existing condition Unit numbers Acres Vegetation Treatments and Methods Product Removal

Natural Stands 1, 6, 8, 9, 11, 13, 14, 15, 16, 18, 20, 21, 22, 23, 25, 38,44

842 Mechanical restoration thinning 4-30”/whole tree yard/ pile burn/underburn/pine planting

Timber/Biomass

Natural Stands 17, 18A, 19, 29, 31, 33, 34, 37, 38A, 38B, 41, 42

2735 Hand thinning 3-12”/pile burn/ underburn none

Plantations 2, 3, 4, 4A, 5 26, 27, 28 260 Mechanical restoration thinning 4-30”/whole tree yard/ pile burn/underburn/pine planting

Timber/Biomass

Plantations 7, 10, 12, 24, 30, 32, 35, 36, 1480 Hand thinning 3-12”/pile burn/ underburn none


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39, 40, 43

Meadow 38A, 38B 13 Hand thinning 3-12”/pile burn/ jackpot burn none

Chaparral 100, 101 381 No treatment none

Goshawk PAC 200 168 Hand thinning 3-6”/pile burn/ underburn none

TOTAL 5879

Mechanical Restoration Thinning 4-30”: Mechanical thinning of some areas of both natural stands and plantations can accelerate restoration. Thinning would follow silvicultural prescriptions to achieve desired conditions. The restoration thin prescription is broken down into five zone treatments based on aspect, slope position, site productivity, tree species and recognition of micro-site conditions. This prescription would create varying stand density and structure throughout the project area. Tree harvest methods to be used involve mechanical ground-based equipment to remove conifer trees up to 29.9”. Trees 30 inches and greater would be retained throughout the project area except where they pose a safety or structural hazard.

Whole Tree Yard: This method involves removing the entire tree to a landing for processing. In this way limbs and tops of commercial size trees are brought to landings, thereby reducing forest fuel load. Material would be removed from landings for timber, biomass, firewood, or burned.

Hand thinning 3-12”: Mechanical thinning is not appropriate for the entire area. Some stands already have appropriate densities and species composition. Some are inaccessible due to lack of road access or steep slopes. Some areas are too close to sensitive wildlife and should be avoided. Therefore, some areas of both natural and plantation stands are proposed for hand thinning with chainsaws. Material would be piled or lopped and scattered for later burning. Not all areas would be hand thinned, but only where needed to modify fuel conditions prior to burning.

Hand thinning 3-6”: similar to 3-12” above, would occur in goshawk PACs, to facilitate prescribed burning.

Pile Burn/Jackpot burn/Underburn: Most of the project would be treated with use of prescribed fire. Three prescribed fire methods would be used: pile burning, jackpot burn, and underburn. These activities would occur after proposed vegetation treatments are completed. In stands where the level of dead and down woody debris exceed the fuels objectives of 10 to 15 tons per acre (SNFPA S&Gs 4 and 5), fuels reduction treatments would be used to lower the volume of woody debris across the project area.

Prescribed burning would occur when weather and fuel conditions are appropriate to meet the objectives and prescriptions. Burning would be accomplished over the next 10 years, with piles at risk of bark beetle infestation burned in a timely manner if not removed by other means. Prescribed burning would be designed to be adjacent to other treatments in order to maximize the effectiveness of fuels reduction and create a mosaic of forest openings. Where needed control lines may be constructed using hand crews or a lightweight trail dozer or equivalent in mechanical units to scraping to mineral soil and construct waterbars for erosion control.

Pile burn: Dead and down woody material would be mechanically or manually piled depending on the area and would be later burned. Hand piling of fuels would occur under the restoration thinning prescription, plantation maintenance, and prior to prescribed burning. Landing piles of fuels in plantations, restoration thin, and reforestation treatment areas would be created using whole-tree yarding.

Underburn: Underburning is proposed to accomplish restoration objectives and reintroduce the process of frequent fire by burning the understory of treatment units with tree canopy overstory.

Jackpot burn: Jackpot burning involves burning cut material in place and would be used at the meadow.

Pine Planting: Restoration of native species composition would be accomplished through the replanting of pine species and the enhancement of growing conditions for existing pine and oaks.

Product Removal

Timber: While the emphasis of the project is on “what is left behind, rather than what is taken away”, forest products would be generated during restoration treatments. It is expected that commercial size, merchantable timber (volume to be determined) would be thinned from the forest and sold under a timber contract.

Biomass: Thinning would generate a volume of woody material consisting of limbs, tops, and small trees. This material can be made available as biomass for uses such as electricity generation, landscape chips, or firewood. If not removed by one of these methods in a timely manner, material would be burned.


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Road reconstruction would occur on 2.8 miles to support access to treatment units and mitigation of damage to resources. Activities may include rock and log removal, grading, and brush clearing. Plugged culverts would also be cleared. This type of reconstruction does not change the road standard or intended access. Some road decommissioning would also occur on approximately .4 miles, implementing the 2009 Sequoia National Forest Motorized Travel Management decision. In addition, some screening should be preserved along roadways to provide cover for deer, which is especially important during hunting season.

No new permanent road construction would be required to accomplish proposed actions described in Table 1. About .5 miles

of existing temporary roads would be reopened and .5 miles of new temporary roads would be constructed. These roads

would provide temporary transportation between the treatment area and the FS roads. Following completion of treatment

activities, the temporary roads would be rehabilitated.

Alternative 3 – Non-commercial.

In Alternative 3 the treatment units and acres proposed for treatment are the same as those recommended in Alternative 2, however under this alternative only hand treatment methods would be employed to: thin and/or remove trees and vegetation less than 8 inches at DBH; and treat accumulations of activity and ground fuels with prescribed fire or wildfire utilized for integrated objectives. While no commercial product removal would be permitted, personal firewood gathering would be permitted from treated areas.

Modeling described in the Forest Vegetation Specialist’s Report (Stewart 2013) indicates that in the event of a future wildland fire, surface fire intensities, rates of spread and crown fire and spotting potential would be reduced as a result of treatments compared to no-action. However, this type of “thinning from below” would not address forest health goals. This alternative would result in some benefits for controlling wildland fire.

Table 3: Alternative 3 - Non-commercial Treatment

Existing condition Unit numbers Acres Vegetation Treatments and Methods Product Removal Natural Stands 1, 6, 8, 9, 11, 13, 14, 15, 16, 17, 18, 18A, 19, 20, 21,

22, 23, 25, 29, 31, 33, 34, 37, 38, 41, 42, 44 3577 Hand thinning 3-8”/pile burn/ underburn none

Plantations 2,3,4,4A,5,7,10,12,24,26,27,28,30,32,35,36,39,40,43 1740 Hand thinning 3-8”/pile burn/ underburn none

Meadow 38A, 38B 13 Hand thinning 38”/pile burn/ jackpot burn none

Chaparral 100, 101 381 No treatment none

Goshawk PAC 200 168 Hand thinning 3-6”/pile burn/ underburn none

Total 5879

Environmental Consequences: Air Quality

Methodology

Tools Used to Predict Impacts

FOFEM 5.7 – Bob Keene, Elizabeth Reinhardt, Jim Brown, Larry Gangi; U.S.F.S. Rocky Mountain Research Station. First Order Fire Effects Model, is a computer program that models quantitative fire effects information for tree mortality, fuel consumption mineral soil exposure, smoke emissions and soil heating. Smoke emissions for underburning were estimated based on field fuels data and the prescribed burning prescription the Forest uses. Source: http://www.fire.org/index.php?option=com_frontpage&Itemid=1

Mobile Emissions Spreadsheet – (2010). A spreadsheet was used for estimating emissions from mobile sources (equipment). Emission factors for vehicles used were from the South Coast Air Quality Management District EMFAC2007 (version 2.3). They are factors for a 2011 scenario for both on-road passenger vehicles (pick-up trucks) and heavy-heavy-duty diesel trucks (crew buggies, fire engines, and water tender). Emission factors for chainsaw are from USEPA AP-42 Chapter 3, Table 3.3-1, Emission Factors for Uncontrolled Gasoline and Diesel Industrial Engines. Chipper emissions factors were from the Angeles National Forest FY04 Forest Health Air Quality Analyses (VOC Emission Factor was not available so it used a ROG factor). PM-2.5 Emission Factors were from Appendix A - updated CEIDARS Table with PM2.5 Fractions (for chipper and chainsaw). Source of emissions spreadsheets: RFRP Smoke Emissions.xls, and RFRP Mobile Emissions.xlsx

Piled Fuels Biomass and Emissions Calculator – (2011). The Fire and Environmental Research Applications online calculator was used for estimating smoke emissions from pile burning.


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Alternative 1 (No Action)

Direct, Indirect, and Cumulative Effects of

The No Action alternative would result in a higher likelihood of wildfire with fuel loading characteristics that could produce more emissions per acre. Wildfires generally produce more emissions per acre and most often occur at times of the year when the adjacent air basins have high background pollution concentrations. There is a higher likelihood of adverse effects including cumulative effects to air quality under the No Action alternative. Existing and future fuel accumulations would contribute to increased fire intensities and severities. Consumption of the increased fuel loads would increase the amount of smoke emissions. Emissions from wildfire are typically twice those of a prescribed fire on the same acreage due to greater emission factor (Ottmar 2001), fuel consumption and fire intensity. These emissions would also occur over a period of a few days to several weeks as opposed to intermittent days (approximately 28 days per year) over 10 years for this project. Wildfire emissions would typically occur during the summer under hot, dry conditions. This is also the typical period (May – October) when air quality is typically at its worst due to the higher seasonal temperatures conducive to creating peak ozone concentrations.

Wildfires result in greater emissions per acre when compared to prescribed burns, commonly exceeding ambient air quality standards. They also often occur under conditions of high temperature and low humidity, when high concentrations of ozone are most likely. Prescribed burning reduces existing fuels, thus decreasing the fire hazard and the risk of high intensity wildfire, and decreases the quantity of fuels available to be consumed in a wildfire. However, infrequent large-scale wildfire will still occur naturally in some vegetation types.

The quantity of smoke emissions from fires and the impact of those emissions on local and regional air quality vary dramatically with the size and type of fire that occurs. The number of acres burned is the single most important factor in determining the total emissions within an airshed. Large fires, whether they originate as wildland fires or prescribed fires, produce more total emissions than small fires. Therefore, reducing the total acreage burned, regardless of the type of fire, is the most effective way to reduce the total emissions within an airshed.

Cumulative Effects

Within Kern County on an annual basis, a majority of the anthropogenic air pollution is generated from mobile sources followed by stationary, then area wide sources. Non-anthropogenic sources emissions are the least. The largest anthropogenic source of carbon monoxide (CO), nitrogen oxides (NOX) and reactive organic gases (ROG) in Kern County are mobile sources. Particulates (PM10 and PM2.5) are emitted into the air by sources such as factories, power plants, construction activities, automobiles, fires, agricultural activities and dust from roadways. Most of the particulates in Kern County are produced by area sources including fugitive wind-blown dust, construction and demolition, roadway dust, and fires sources. In Kern County, most of the annual non-anthropogenic particulates are attributed to biogenic sources (a substance produced by life processes and may be either constituents, or secretions, of plants or animals) followed by vegetation burning (wildfires). Wildfires make up about 4% of all particulate emissions.

Data on forest fire frequency, size, total burned area, and severity all show strong increases in the Sierra Nevada over the last two to three decades. (Meyer and Safford, 2010) The Sierra Nevada was one of two geographic areas of especially increased fire activity, which Westerling et al. (2006) ascribed to an interaction between climate and increased fuels due to fire suppression. Westerling et al. (2006) also identified the Sierra Nevada has being one of the geographic regions most likely to see further increases in fire activity due to future increases in temperature.

On a statewide basis, wildfires in California contribute 24 million metric tons (MMT) of carbon dioxide to the statewide total (California Energy Commission (CEC) 2006). This is approximately four times the average emissions associated with forestry each year (CEC 2006). In fact, Bonnicksen (2009, p. 15) has estimated that every automobile in the state of California “would have to be locked in a garage for 3 1/2 years to make up for the global warming impact of the 2001-2007 California wildfires.”

Van Mantgem et al. (2009) recently documented widespread increases in tree mortality in old-growth forests across the west, including in the Sierra Nevada. The highest mortality rates were documented in the Sierra Nevada, and in middle elevation forests (3300-6700). Van Mantgem et al. (2009) ascribed the mortality patterns they analyzed to regional climate warming and associated drought stress. The principle trends are 1) loss of yellow pine dominated forest, 2) increase in the area of forest dominated by shade-tolerant conifers (especially fir species), 3) loss of blue oak woodland, 4) increase in hardwood dominated forests, 5) loss of subalpine and alpine vegetation, and 6) expansion of subalpine trees into previous permanent snowfields (Meyer and Safford, 2010).


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All Action Alternatives

Direct and Indirect Effects

Smoke from prescribed burning associated with fuel reduction activities could potentially affect air quality and is a common concern because of its potential effect on human health and visibility. The smoke could potentially affect visitors and residents in the surrounding communities.

When considering the use of prescribed burning to restore the natural role of fire in ecosystems, effects of wildfire and prescribed burning must be considered. Fires emit particulate matter (PM10 and PM2.5 [particulate matter less than 2.5 microns in diameter]) and carbon monoxide, as well as nitrogen oxides and volatile organic compounds, which are precursors to ozone. Other constituents of smoke (gases and chemicals) may also enter the lungs. Some components can be carcinogenic.

The fire type influences the quantity of emissions from fire. Prescribed fires typically produce lower per-acre emissions than wildland fires; heading fires (a fire that burns with the wind) typically produce lower per-acre emissions but have higher emission rates than backing fires; and surface fires typically produce lower per-acre emissions than crown fires. The differences in emissions among the different fire types may be attributed to differences in the meteorological conditions that typically occur, differences in fuel properties, and differences in the resultant fire behavior and fuel consumption. Because prescribed fire generally produces fewer per-acre emissions than wildland fire, it is possible to burn more acres by prescribed fire than would normally occur with wildland fire and still maintain the same total emissions within an airshed.

The primary benefit of a prescribed fire program is in modifying sizes and types of fires that occur within a particular geographic region. Through prescribed fire, it is possible to replace large high intensity wildland fires that are characterized by high fuel consumption and high total emissions with smaller, lower-intensity prescribed fires that are characterized by lower fuel consumption and lower total emissions.

The following table presents the predicted annual average PM10 emissions for prescribed fire in the first ten years. Emissions are expressed in average annual tons. There is very little variation between alternatives, with the exception of the No Action alternative. The emissions associated with the action alternatives are relatively low and would fall below the Federal conformity de minimus levels.

Each action alternative includes some pile burning in the first ten years. This can be extremely effective in spreading the emissions over time since the pile burning can be accomplished during winter months.

The jackpot burning is important since this material is primarily burned in the more critical spring or fall burn periods. The material burned in piles is candidate for winter burning, therefore removing that load from the more constraining seasons.

Table 4: Alternative 2 approximate tons per year and total project pollutants generated from all emissions sources.

Pollutant Prescribed Burning Emissions Tons Per Year (Area Source)

Equipment Emissions Tons Per Year (Mobile Source)

Total Project Emissions Ten Year Period Tons

PM10 114 0.98 1,146

PM2.5 98 0.087 990

CH4 58 N/A 586

CO 1,227 14.52 3,336

CO2 6,761 N/A 69,535

NOX 3 1.93 28

SO2 5 0.0012 51

Source: Piled Fuels Biomass and Emissions Calculator, Last updated 4/1/2011, http://depts.washington.edu/nwfire/piles/index.php?

Prescribed fire is permitted by the San Joaquin Valley and East Kern Air Pollution Control Districts. Allocations are granted by the District on days when meteorological conditions allow sufficient dispersion to reduce the potential for public exposure. Smoke from prescribed burning may have short-term effects on nearby communities. Efforts made to minimize impacts on the local communities have been successful in the past. The locale of the project, near the top of the ridge, in an area with generally good smoke dispersal to the east contributes to successful smoke management.

The regulatory environment for smoke has shown an overall emphasis on accommodating prescribed fire out of recognition of the severe fuels risk in the western United States. In California, the public nuisance rule provides an important protection


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measure for property, safety, and health. This rule essentially requires the APCD to investigate and take action to remedy any air discharge that is causing injury, detriment, nuisance, or annoyance to any considerable number of persons.

Good smoke management techniques, improved burn day forecasts, and public communication can mitigate some complaints. Public Nuisance issues are more commonly associated with changing or unforeseen conditions in the burn day forecast or lower elevation projects when the smoke is not fully dispersed during the daytime hours.

Cumulative Effects of All Action Alternatives

The regulatory framework (Title 17) that controls agricultural and wildland prescribed fire in California is designed to control cumulative effects through allocations based on meteorological conditions influencing smoke dispersion. The Sequoia National Forest and other cooperating wildland agencies work closely with the District and the CARB to prioritize wildland prescribed fire within the emissions constraints allowed by the regulatory agencies. Under this regulatory structure cumulative effects are not expected to occur.

Effects conclusions

If the Project is implemented following APCD rules, no significant impacts would be expected. The Forest will need to coordinate with residents and visitors within the sensitive smoke areas identified in Table 1. The Rancheria project would produce less than 10% of the air basin's emissions inventories concerning relevant criteria pollutants. Based on the information presented in this report the Project will comply with the federal Clean Air Act and would not significantly affect greenhouse gas emissions. Total number of days that burning would occur on average each year is approximately 32 in the first year and 28 days during years 2 through 10. Burning can only occur on days with meteorological conditions meeting those specified in the SJVAPCD / EKAPCD Smoke Management Plan. Following these criteria, it is expected that residents located around the mountain top might see or smell smoke. It is expected that most impacts will be in the form of “nuisance” smoke, the smell of smoke that would not exceed NAAQS.

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