HomeMy WebLinkAboutSmoke Mgmt LtrBoard of Coun Commissioners
P .O. Box 6005 • Bend , OR 97708-6005
1300 NW Wall St, Suite 206 • Bend, OR 97701-1960
(541] 388-6570· Fax (541] 385-3202
www .deschutes .org
July 28, 2014 boa rd@deschutes . org
Tammy Baney
Anthony DeBone
Doug Decker, State Forester Alan Unger
Oregon Department of Forestry
2600 State Street, Salem, OR 97310
Dick Pederson, Director
Oregon Department of Environmental Quality
811 SW 6th Avenue
Portland, OR 97204-1390
Re: Forest Restoration and Smoke Management
Dear State Forester Decker and Director Pederson,
We are seeking your help in resolving an issue created by the need to increase the pace and scale of
forest restoration and the limitations imposed by the State Smoke Management Plan . Currently, the
forests bordering Bend and other communities within Deschutes County are at an increased risk to
wildfire . The Two Bulls and Pole Creek wildfires are just two recent examples of the immediate threat
wildfire brings to homes and communities in Deschutes County. Not only are homes, public lands, and
private forestlands threatened; it also threatens those whose livelihoods are dependent upon tourism,
recreation , and timber harvesting. In addition, when wildfire smoke remains in the area for weeks at a
time as it did during the Pole Creek fire, it impacts community health and deters visitors to the County .
After a century of widespread fire exclusion, we recognize the need to increase the pace and scale of
forest restoration efforts in order to lower risk of large wildfires and increase forest health and
resiliency. The Deschutes Forest Collaborative Project is a local example of collaborative efforts taking
place statewide where environmentalists, the forest products industry, private land owners, and
government agencies among others are working together to secure funds, develop agreement and
implement projects with an emphasis on accelerated forest restoration and reduced wildfire risk .
While striving towards these goals we are attempting to overcome barriers that limit large landscape
implementation. One of those that has recently come to our attention are limitations imposed by
regulations in the State Smoke Management Plan .
We understand that the objectives of the State Smoke Management Plan seek to balance two opposing
issues: 1) To provide maximum opportunities to conduct essential forestry prescribed burning; and 2)
Minimize smoke intrusions into smoke sensitive receptor areas (SSRA's) such as Bend and Redmond .
While these are adm i rable goals, one barrier we see is that smoke intrusions from prescribed burning
are defined very stringently, with no basis in effects on health .
DC 20 1 4 422
Enhancing the Li ve s of Citi ze ns by Deliverin g Quality Services in a Cost-Effecti ve Manner
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The National Ambient Air Quality Standards are health based standards that receive frequent updates
based upon the best available science. Our understanding is that Oregon smoke intrusion levels are not
based upon effects to health but are rather a no tolerance policy where zero smoke is allowed to enter
into SSRA's. As an example, a "light intrusion" resulting from a prescribed burn, would be characterized
as "good" air quality if it occurred during a wildfire. Perhaps a more scientifically based threshold such
as the National Ambient Air Quality Standard is a more appropriate threshold of acceptance when
weighed against the concerns of wildfire and forest health risk.
Because of the fire adapted environment in which we live, we feel there is a need to balance the risk of
smaller amounts of smoke in the air for planned short duration periods during prescribed fire, vs. the
tradeoff of extreme amounts of wildfire smoke filling the air over longer unplanned periods. We would
like the State to recognize that there are tradeoffs in air quality which occur during a prescribed burn
and that which occur during a wildfire. The frequency, duration, and magnitude of smoke experienced
in Bend during recent wildfires were much more harmful than the smoke experienced during recent
intrusions caused by prescribed burning in the forest.
We understand that federal Clean Air rules allows smoke from wildfires to be treated as exempt from
compliance with national ambient air quality standards, and thus there is little motivation to reduce air
quality impacts during wildfire from a regulatory standpoint. However, our communities still
experience the health and economic effects of smoke during these events. We believe increasing the
pace and scale at which forest restoration occurs can have an underlying effect on the amount of smoke
released due to wildfires. As a community, we would gladly trade a little bit of smoke under planned
circumstances for less smoke during wildfires. Obviously, there are times when the risks due to air
quality concerns outweigh the need to conduct prescribed burning on a given day. However, it seems
as though a zero tolerance policy of smoke in SSRA's will not allow prescribed fire treatments to occur
where the need to provide community safety is the greatest, especially in forests next to those
communities.
The West Bend Vegetation Management Project is one example which illustrates how the State Smoke
Management Plan is restricting our ability to restore forests at our desired rate. The project is a 22,000
acre project located adjacent to the west side of Bend. Approximately 18,950 acres are to be treated
with brush mowing and/or prescribed burning in combination with commercial harvest or understory
treatments. The environmental impacts of this project have been disclosed through the National
Environmental Protection Act (NEPA) process. This past spring, approximately 275 acres were treated
with fire, and one intrusion occurred in Bend. As a result of that intrusion, requests were made for burn
units to be even smaller. Implementation of the State Smoke Management Plan as currently written
and administered has the potential to slow the rate of treated acres down to the point it may take
decades to complete this project.
Therefore, we are seeking to identify potential solutions so these projects can be implemented faster
while still upholding National or State ambient air quality standards. In your capacity as the State
Forester and the Director of the Department of Environmental Quality, we hope you can work together
to find a solution to this difficult problem in the near future. We recognize that the State just went
through a revision to its smoke management plan, but this issue has come to the forefront since that
process concluded, and is too urgent to wait another five years for the next State Smoke Management
plan revision.
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We would gladly participate in further discussion with you on this issue and look forward to your
assistance. Thank you for your prompt consideration of this matter.
Sincerely,
Deschutes County Board of Commissioners
Tammy Baney, Chair
Anthony DeBone, Vice Chair
Alan Unger, Commissioner
Cc: Doug Grafe and Nick Yonker, Oregon Department of Forestry
David Collier and Brian Finneran, Oregon Department of Environmental Quality