Requested Public Comment for Klamath Falls PM2.5 Maintenance Plan

Environmental ConsultingEnvironmental Consulting
04/11/2024
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The Oregon Department of Environmental Quality (ODEQ or Oregon DEQ) is proposing to submit to U.S. EPA a request to redesignate the Klamath Falls air shed from nonattainment to attainment with the 24-hour National Ambient Air Quality Standard (NAAQS) for small particulate, diameter less than 2.5 microns (PM2.5). This involves the Oregon DEQ submitting a revision to the State of Oregon Clean Air Act Implementation Plan (aka SIP) that will both redesignate the Klamath Falls airshed as attainment for the 24-hour PM2.5 NAAQS and include a maintenance plan to keep air quality within the PM2.5 health standards for at least 10 years after the redesignation.

Klamath Falls, with boundaries defined in OAR 340-204-0010, was designated as nonattainment for the 2006 daily PM2.5 standard in 2009. A nonattainment area means a “geographical area of the state, as designated by the EQC or the EPA, that exceeds any state or federal primary or secondary ambient air quality standard” [OAR 340-200-0020(97)]. The Oregon DEQ and the community of Klamath Falls developed a 2012 Attainment Plan to bring air quality to compliance with the 24-hour PM2.5 NAAQS; it was approved by the EPA in 2016. Through the execution of this plan, Klamath Falls achieved attainment of the 2006 PM2.5 NAAQS in 2014 and continues to attain that standard. Note, that attainment status is verified with monitored concentrations for the Klamath Falls vicinity. Major wildfires which occurred in 2012, 2013, 2015, 2017, 2018, 2020, and 2021 are considered Exceptional Events and are not included as potential violations. The Oregon DEQ seeks to request redesignation of the Klamath Falls Nonattainment Area to attainment for this pollutant. With the redesignation request, DEQ submits a maintenance plan to ensure the Klamath Falls area maintains compliance with the 24-hour PM2.5 NAAQS.

With the proposed maintenance plan, the DEQ is requesting to institute new control strategies in addition to those in effect from the 2023 Attainment Plan. These new control strategies will include a Revised Klamath County Clean Air Ordinance, Public Education Efforts on Woodsmoke, ASTM Fireplace Standard for New Construction, and Oregon Smoke Management Plan Limitations on Prescribed Burning. These updates are not included within the rule changes that are available for public comment, but rather demonstrates efforts to maintain the attainment status. The Oregon DEQ has provided a copy of the Redesignation Request and Maintenance Plan on the air quality website for public access here: Klamath Falls Redesignation Request and Maintenance Plan for PM2.5. Additionally, the Oregon DEQ is requesting public comment on proposed regulations to reflect the Klamath Falls area to “maintenance” status. Updates to the regulations do not have an impact to industrial sources because requirements are typically considered for sources located in nonattainment or maintenance areas.

DEQ offered three ways to comment on the proposed rulemaking: emailing [email protected], attending the public hearing on April 29, 2024 at 5:30 p.m., and via postal mail. You can find the zoom link for the public hearing and the address for postal mail here: Klamath Falls PM2.5 Maintenance Plan 2024. The comment period closes on April 29, 2024 at 11:50 p.m. If you have questions about the Oregon DEQ’s designated air maintenance areas and how changes to the Klamath Falls maintenance plan could impact reporting and regulations, please email Beth Ryder or call 458.206.6770.

I joined Trinity Consultants because I wanted to take my experience as an engineering student and apply it to a job that was people-oriented and allowed me to explore a wide range of industries. In my time at Trinity, I’ve had the opportunity to both work on a variety of projects and develop my own areas of expertise. As someone who was interested in air dispersion modeling early on, I’ve had the opportunity to grow my experience in that subject area without sacrificing opportunities to try new projects and work with great people. As a Senior Consultant, I now support clients in a variety of industries including data centers, surface coating, Portland cement, lime manufacturing, oil and gas, and more. My project work covers a broad range as well, including air dispersion modeling, routine compliance support, new construction permitting, and stack testing support.

Sam Najmolhoda
Senior Consultant

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