Houston East (CAMS 1) monitoring site

AUGUST 26, 2011

EXCEPTIONAL EVENTS DEMONSTRATION PACKAGE

For the Houston-Galveston-Brazoria One-hour Ozone Nonattainment Area

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY P.O. BOX 13087 AUSTIN, TEXAS 78711-3087

September 30, 2014 TABLE OF CONTENTS

Table of Contents ...... i List of Acronyms ...... iii List of Tables ...... v List of Figures ...... vi Executive Summary ...... viii Chapter 1: Introduction ...... 1-1 1.1 A Conceptual Model of Ozone for the HGB Area ...... 1-1 1.2 Trends in HGB Area Emissions and Ozone Levels ...... 1-2 1.3 Ozone Reduction Progress at the Houston East (CAMS 1) Monitoring Site ...... 1-4 1.4 The Exceptional Event of August 26, 2011 ...... 1-5 Chapter 2: Exceptional Event Rule Requirements for States ...... 2-1 2.1 Environmental Protection Agency Requirements ...... 2-1 2.2 Responses to Exceptional Event Rule Requirements ...... 2-2 2.2.1 The Event Affected Air Quality ...... 2-2 2.2.2 The Event is not Reasonably Controllable or Preventable ...... 2-3 2.2.3 The Event is not Likely to Recur or is Natural ...... 2-3 2.2.4 The State Follows the Public Comment Process...... 2-3 2.2.5 Mitigation Requirements of 40 CFR §51.930 ...... 2-3 2.2.6 A Clear Causal Relationship Exists ...... 2-5 2.2.7 In Excess of Normal Historical Fluctuations ...... 2-6 2.2.8 There Would Have Been no Exceedance but for the Event ...... 2-6 Chapter 3: Normal Historical Fluctuations at the Houston East (CAMS 1) Monitoring Site ...... 3-1 3.1 An Analysis of Historic Seasonal Fluctuation of Maximum Daily Ozone Values at the Houston East (CAMS 1) Monitoring Site ...... 3-1 3.2 An Analysis of Annual Daily Maximum One-Hour Ozone meAsurements at the Houston East (CAMS 1) Monitoring Site ...... 3-2 3.3 An Analysis of Diurnal Profiles at the Houston East (CAMS 1) Monitoring Site3-3 3.4 Short-Term Analysis of the Houston East (CAMS 1) Monitoring Site Daily Maximum Ozone measurements ...... 3-5

3.5 Comparisons Between Nitrogen Oxides (NOX) and Ozone Data Collected at the Houston East (CAMS 1) and Nearby Monitoring Sites ...... 3-6

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3.6 Southeast Texas Monitoring Sites ...... 3-10 Chapter 4: A Clear Causal Relationship Between Fire Emissions and Higher Ozone .... 4-1 4.1 Literature Review ...... 4-1 4.2 Wildfires of 2011 ...... 4-5 4.3 Timing of Hourly Fine Particulate Matter less than or equal to 2.5 microns in diameter (PM2.5) and Ozone Measurements on August 26, 2011 ...... 4-11 4.4 Trajectory Analyses ...... 4-12 4.4.1 Trajectory Analysis 1 – Backward Trajectories from the Houston East (CAMS 1) Monitoring Site ...... 4-13 4.4.2 Trajectory Analysis 2 – HYSPLIT Matrix Forward Trajectories from Areas with Clusters of Fires ...... 4-16 4.4.3 Trajectory Analysis 3 – HYSPLIT Matrix 6 ...... 4-23 4.4.4 Ozonesonde Analysis ...... 4-28 4.4.5 Uncertainties ...... 4-32 4.5 GOES Satellite Imagery ...... 4-33 4.6 Satellite Aerosol Optical Depth Images with HYSPLIT Backward trajectories4-36 4.7 Pathfinder Satellite observations ...... 4-42 4.8 Monitor Values in Louisiana display Westerly Trend ...... 4-49 Chapter 5: No Exceedance but for the Exceptional Event ...... 5-1 5.1 Houston Area Background Ozone Levels ...... 5-1 5.2 Analysis of a Surrogate Day ...... 5-4 5.2.1 Introduction ...... 5-4 5.2.1 Surface Trajectories ...... 5-5 5.2.2 Surrogate Days ...... 5-7 5.2.3 Sinuosity ...... 5-8 5.3 Meteorological Similarities of The Exceptional Event Day and Surrogate Day . 5-9 5.4 Similarities of HRVOCs on The Exceptional Event and Surrogate Days ...... 5-12 5.5 Conclusions ...... 5-14 Chapter 6: Documentation of the Public Comment Process ...... 6-1 Chapter 7: Conclusions ...... 7-1 Chapter 8: References ...... 8-1 Appendix A: Press Releases/Media Reports ...... 1 Appendix B: Public Comments ...... 1

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LIST OF ACRONYMS

AutoGC Automatic Gas Chromatograph AOD Aerosol Optical Depth AQI Air Quality Index AQS Air Quality System CALIOP Cloud-Aerosol Lidar with Orthogonal Polarization CALIPSO Cloud-Aerosol Lidar and Infrared Pathfinder Satellite Observation CAMS Continuous Air Monitoring Station CASTNET Clean Air Status and Trends Network CFR Code of Federal Regulations CO Carbon Monoxide CST Central Standard Time EPA Environmental Protection Agency EDAS Eta Data Assimilation System EER Exceptional Events Rule F Fahrenheit FCAA Federal Clean Air Act GOES Geostationary Operational Environmental Satellite HGB Houston-Galveston-Brazoria HMS Hazard Mapping System HRM 3 Houston Regional Monitoring Site #3 HRVOC Highly Reactive Volatile Organic Compounds HYSPLIT Hybrid Single Particle Lagrangian Integrated Trajectory km Kilometer LDT Local Daylight Time LEADS Leading Environmental Analysis and Display System LIDAR Light Detection and Ranging LST Local Standard Time m Meter MODIS Moderate Resolution Imaging Spectroradiometer NAAQS National Ambient Air Quality Standard NASA National Aeronautics and Space Administration nm Nanometer NOAA National Oceanic and Atmospheric Administration NOX Oxides of Nitrogen NOY Total Reactive Nitrogen NO2 Nitrogen Dioxide NWS National Weather Service OC Organic Carbon PAN Peroxyacetyl Nitrate PM Particulate Matter PM2.5 Fine Particulate Matter less than or equal to 2.5 microns in diameter PM10 Particulate Matter less than or equal to 10 microns in diameter ppb parts per billion ppbC parts per billion by Carbon ppm parts per million TCEQ Texas Commission on Environmental Quality TOMS Total Ozone Mapping Spectrometer U.S. United States

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UTC Coordinated Universal Time VOC Volatile Organic Compounds WFABBA Wildfire Automated Biomass Burning Algorithm

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LIST OF TABLES

Table 1-1: Siting Details of the Houston East (CAMS 1) Monitoring Site...... 1-4 Table 3-1: Seasonal Daily Maximum One-Hour Ozone for the Houston East (CAMS 1) and Nearby Monitors, 2009 through 2011 ...... 3-9 Table 3-2: Seasonal Daily One-Hour NOX Statistics for the Houston East (CAMS 1) and Nearby Monitors During 2009 through 2011 and Comparison with August 26, 2011 ...... 3-10 Table 3-3: Daily Maximum Values and Percentile Rankings of August 26, 2011 at Monitors in Southeast Texas ...... 3-11 Table 4-1: Number of Fires Identified by NOAA, by Day, August 20 through 26, 2011 ...... 4-7 Table 4-2: HYSPLIT Matrices Defined for Forward Trajectory Computations ...... 4-17 Table 4-3: The Definition of HYSPLIT Matrix 6 ...... 4-23 Table 4-4: Ozone Concentrations (ppb) at the Surface and Peak Ozone Concentrations (ppb) in the Lower Troposphere (Measured by Ozonesondes) ...... 4-29 Table 5-1: HBG Background Ozone Monitoring Sites ...... 5-2 Table 5-2: Maximum One-Hour Ozone on Final Candidate Surrogate Days ...... 5-8 Table 5-3: Sinuosity Results for Final Candidate Surrogate Days...... 5-9 Table 5-4: Meteorological Conditions on Event and Surrogate Days ...... 5-10 Table 5-5: Neighboring AutoGC Monitoring Sites ...... 5-12 Table 5-6: Comparison of Means Hypothesis Testing Results ...... 5-14

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LIST OF FIGURES

Figure 1-1: HGB Area Point Source VOC and NOX Trends 1997 through 2012 ...... 1-2 Figure 1-2: 2002 through 2011 NOX Emissions Inventory Trend for the HGB Area ...... 1-3 Figure 1-3: HGB Area Ozone Design Value and Population Growth 1991 through 2013 ...... 1-3 Figure 1-4: Houston East (CAMS 1) Location ...... 1-4 Figure 1-5: Houston East (CAMS 1) Design Values 1990 through 2013 ...... 1-5 Figure 3-1: Percentile Rankings of Seasonal Daily Maximum One-Hour Ozone Concentrations at the Houston East (CAMS 1) Monitoring Site from 2009 through 2011 ...... 3-2 Figure 3-2: Percentile Rankings of Annual Daily Maximum One-Hour Ozone Concentrations at the Houston East (CAMS 1) Monitoring Site from 2009 through 2011 ...... 3-3 Figure 3-3: August Diurnal Profile Analysis for Ozone at the Houston East (CAMS 1) Monitoring Site during 2008 through 2012 ...... 3-4 Figure 3-4: Hour-by-Hour Percent Rank for Ozone Measurements at the Houston East (CAMS 1) Monitoring Site on August 26, 2011...... 3-5 Figure 3-5: A Comparison of August 26, 2011 to its Neighboring Days in 2011 and a Comparison of 2011 to the Years 2009 and 2010 ...... 3-6 Figure 3-6: Seasonal Percent Rankings of Daily Maximum One-Hour NOX Concentrations at the Houston East (CAMS 1) Monitoring Site from 2009 through 2011 ...... 3-7 Figure 3-7: Map of Monitors in Close Proximity to the Houston East (CAMS 1) Monitoring Site3- 8 Figure 4-1: Locations of Wildfires and Prescribed Burns Identified by NOAA ...... 4-6 Figure 4-2: Annual Number of Wildfires in the U.S...... 4-9 Figure 4-3: Annual Acreage Burned in the U.S...... 4-10 Figure 4-4: Ozone and PM2.5 Diurnal Profiles Measured at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 ...... 4-12 Figure 4-5: Twenty HYSPLIT Backward Trajectories Originating at the Houston East (CAMS 1) Monitoring Site, August 26, 2011 at 17:00 UTC ...... 4-14 Figure 4-6: Altitudes of HYSPLIT Backward Trajectories Originating at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC ...... 4-15 Figure 4-7: Altitudes of HYSPLIT Backward Trajectories Originating at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC Shown on a Logarithmic Scale ...... 4-16 Figure 4-8: Map of Matrices Defined for Computing Forward Trajectories Using the HYSPLIT Matrix Option ...... 4-17 Figure 4-9: 84-Hour HYSPLIT Forward Trajectories from Matrix 2 at Selected Starting Altitudes Originating on August 23, 2011 at 5:00 UTC...... 4-19 Figure 4-10: 84-Hour HYSPLIT Forward Trajectories from Matrix 2b at Selected Starting Altitudes Originating on August 24, 2011 at 17:00 UTC ...... 4-20 Figure 4-11: Locations (Left Panels) and Altitudes (Right Panels) of HYSPLIT Forward Trajectories Passing Near the Houston East (CAMS 1) Monitoring Site on August 26, 2011 ... 4-22 Figure 4-12: Map of HYSPLIT Matrix 6 Overlaid on the HGB Area ...... 4-24 Figure 4-13: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 50 m at Houston East on August 26, 2011 at 17:00 UTC ...... 4-25 Figure 4-14: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 100 m at Houston East on August 26, 2011 at 17:00 UTC...... 4-25 Figure 4-15: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 250 m at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC ...... 4-26 Figure 4-16: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 500 m at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC ...... 4-27 Figure 4-17: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 750 m at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC ...... 4-28

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Figure 4-18: Ozone Concentrations Measured by Ozonesondes Launched from University of Houston Campus, August 19, August 27, and August 29, 2011, Below 20 km Altitude ...... 4-30 Figure 4-19: Ozone Concentrations Measured by Ozonesondes Launched from University of Houston Campus, August 19, August 27, and August 29, 2011, Below 4 km Altitude ...... 4-30 Figure 4-20: Average Ozone Concentrations (ppb) in 1 km Layers of the Atmosphere...... 4-32 Figure 4-21: GOES Imagery on August 24, 2011 (22:08 UTC) ...... 4-34 Figure 4-22: GOES Imagery on August 25, 2011 (22:08 UTC) ...... 4-35 Figure 4-23: GOES Imagery on August 26, 2011 (21:08 UTC) ...... 4-36 Figure 4-24: HYSPLIT 72-Hour Backward Trajectories Overlaid on AOD Imagery from MODIS Aqua Satellite, August 23, 2011 ...... 4-37 Figure 4-25: HYSPLIT 48-Hour Backward Trajectories Overlaid on AOD Imagery from MODIS Aqua Satellite, August 24, 2011 ...... 4-38 Figure 4-26: HYSPLIT 24-Hour Backward Trajectories Overlaid on AOD Imagery from MODIS Aqua Satellite, August 25, 2011 ...... 4-39 Figure 4-27: AOD Imagery from MODIS Aqua Satellite, August 26, 2011 ...... 4-40 Figure 4-28: HMS Smoke and HYSPLIT 72-Hour Back Trajectories from AirNowTech.org on August 26, 2011 ...... 4-41 Figure 4-29: Close-up of Partial CALIPSO Orbital Path on August 26, 2011 ...... 4-42 Figure 4-30: Attenuated Backscatter of Partial CALIPSO Orbital Path on August 26, 2011 .... 4-43 Figure 4-31: Total Attenuated Backscatter for the Partial CALIPSO Orbital Path on August 26, 2011 ...... 4-44 Figure 4-32: Detail of Total Attenuated Backscatter for the Partial CALIPSO Orbital Path on August 26, 2011 ...... 4-45 Figure 4-33: Vertical Feature Mask for the Partial CALIPSO Orbital Path on August 26, 2011 ... 4- 46 Figure 4-34: CALIPSO Aerosol Subtype Plot for the Partial CALIPSO Orbital Path on August 26, 2011 ...... 4-47 Figure 4-35: Attenuated Color Ratio from Two Wavelengths Detected by the CALIOP Instrument on August 26, 2011 ...... 4-48 Figure 4-36: Detail of Attenuated Color Ratio from Two Wavelengths Detected by the CALIOP Instrument on August 26, 2011 ...... 4-48 Figure 4-37: Monitored Daily Maximum Hourly PM2.5 Concentrations in Louisiana August 24 through 26, 2011 ...... 4-50 Figure 4-38: Monitored Hourly Ozone Daily Maximums in Louisiana August 24 through 26, 2011 ...... 4-51 Figure 5-1: HGB Regional Background August 1-31, 2008-2013 ...... 5-3 Figure 5-2: Distribution of Annual and Seasonal Regional Background Estimates ...... 5-4 Figure 5-3: Selected HYSPLIT Clusters (3, 4, and 5) Containing Candidate Surrogate Days..... 5-5 Figure 5-4: Surface Backward Trajectories for Candidate Surrogate Days ...... 5-7 Figure 5-5: NOAA Surface Level Weather Maps on August 26, 2011 and August 27, 2009 ...... 5-11 Figure 5-6: Hourly HRVOC Measurements at Clinton on Event and Surrogate Days ...... 5-13 Figure 5-7: Hourly HRVOC Measurements at HRM3 on Event and Surrogate Days ...... 5-13

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EXECUTIVE SUMMARY

On August 26, 2011, the Houston East (CAMS 1) monitoring site measured a daily maximum one-hour ozone concentration of 128 parts per billion (ppb) during the 1:00 p.m. to 2:00 p.m. monitoring hour. Large wildfire plumes from the Northwestern and Southeastern United States (U.S.) enhanced ozone levels beyond what it would otherwise have been and caused the measured value to exceed 125 ppb. This exceedance of the one-hour ozone National Ambient Air Quality Standard (NAAQS) created a violation of this standard. Without this exceedance, the Houston-Galveston-Brazoria (HGB) area, comprised of Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties, would be in attainment of the one-hour ozone NAAQS based on the 2010 through 2012 area design value. Based on its initial analysis, the Texas Commission on Environmental Quality (TCEQ) flagged this day at the Houston East (CAMS 1) monitoring site as an exceptional events day and notified the U.S. Environmental Protection Agency (EPA) as required by the Exceptional Events Rule (EER). The TCEQ submits this Exceptional Events Demonstration Package in support of the agency’s claim that the HGB area experienced an exceptional event on August 26, 2011, which caused an exceedance of the one-hour ozone NAAQS. The TCEQ requests that the EPA concur with the technical demonstration contained in this document and enter an exceptional event concurrence flag into the appropriate Air Quality System (AQS) records for the Houston East (CAMS 1) monitoring site on August 26, 2011.

The TCEQ’s claim is substantiated through the accumulated weight of evidence documented in this demonstration package. Chapter 1: Introduction outlines the event and complexities of ozone formation in the HGB area as well as an overview of the significant progress made in reducing ozone in the HGB area. Chapter 2: Exceptional Event Rule Requirements for States discusses the various requirements for satisfying the EER and how the TCEQ meets those requirements. Chapter 3: Normal Historical Fluctuations at the Houston East (CAMS 1) Monitoring Site, Chapter 4: A Clear Causal Relationship Between Fire Emissions and Higher Ozone, and Chapter 5: No Exceedance but for the Exceptional Event lay out the strong technical case that leads the TCEQ to conclude that this exceedance was an exceptional event as required in 40 Code of Federal Regulations (CFR) §50.14(a). The case is based on the following information.

 August 26, 2011 is clearly outside of the normal historical fluctuations for ozone at this site.

 Of the 19 HGB area ozone monitoring sites reporting data to the EPA’s AQS database, 18 had daily maximum one-hour ozone measurements that were in the top 5% of 2009 through 2011 measurements. This establishes the unique nature of this event as it suggests an area wide event rather than local.

 High pressure off the coast of southeast Texas combined with subsiding air along and behind a weak frontal boundary passing over east Texas and the Lower Mississippi River Valley resulted in air masses passing over wildfires in the Lower Mississippi River Valley before entering the Houston area.

 An exhaustive analysis of Hybrid Single Particle Lagrangian Integrated Trajectory (HYSPLIT) trajectories shows that trajectories arriving at the Houston East (CAMS 1) monitoring site on August 26, 2011 passed over or near areas of concentrated wildfires outside of Texas on the way to the HGB area.

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 A review of scientific literature shows a clear basis for the causal relationship between smoke emitted by wildfires and enhanced ozone production downwind.

 An analysis of satellite imagery shows that there were extensive areas of wildfires outside of Texas that affected air quality in the HGB area generally and at the Houston East (CAMS 1) monitoring site in particular.

 A surrogate day analysis concludes that, but for the smoke event, there would likely have been no ozone exceedance at the Houston East (CAMS 1) monitoring site on August 26, 2011.

The accumulated weight of evidence meets the requirements necessary for the EPA to concur with the TCEQ and flag August 26, 2011 as an exceptional event day for ozone at the Houston East (CAMS 1) monitoring site.

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CHAPTER 1: INTRODUCTION

Extensive research and many regulatory activities have been conducted to address the ozone air quality of the Houston-Galveston-Brazoria (HGB) area, which is comprised of Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties. Ozone formation in the HGB area is complex, multi-faceted, and occurs under a variety of conditions. A population over 6.2 million, one of the largest concentrations of petrochemical refining and chemical production activities in the United States (U.S.), and plentiful biogenic emissions from large tracts of oak forests all provide a complex mix of sources that can contribute to exceedances of the ozone National Ambient Air Quality Standard (NAAQS) established under the Federal Clean Air Act (FCAA). Complex meteorological patterns common to Texas coastal areas add to the challenge of determining the contribution of local emissions sources. The HGB ozone picture becomes even more complex as transported ozone and ozone precursors play an increasingly important role in the area’s ozone levels as local emissions decrease.

This introduction briefly examines a conceptual model of ozone formation in the HGB area, reviews HGB ozone and emissions trends over time, and introduces the exceptional event of August 26, 2011 that created the one-hour exceedance at the Houston East (CAMS 1) monitoring site.

1.1 A CONCEPTUAL MODEL OF OZONE FOR THE HGB AREA Ozone formation in the HGB area peaks at the same time of year and for many of the same reasons as in other areas of Texas and the U.S. However, the ozone season in HGB lasts longer than in many other areas. The ozone season in HGB and other coastal areas in Texas is 12 months, whereas in more inland areas the ozone season is March through October. Elevated ozone levels usually form in the HGB area under the persistent hot, sunny, and relatively stagnant conditions associated with high pressure in the Gulf of Mexico during the summer, in the presence of emissions from the mobile, area, and industrial sources in the area.

Ozone production is generally associated with relatively clear skies, light winds, abundant sunshine, and warm temperatures. Typically, these meteorological conditions are associated with high pressure areas that migrate across the U.S. during the summer season. However, the persistent summertime high pressure area in the Gulf of Mexico and air mass flow reversals associated with the land/sea breeze phenomenon make the HGB area situation unusual, if not unique, among U.S. metro areas. High pressure areas have two characteristics that encourage ozone formation: light winds and subsidence inversions. Typically, winds circulating around a high pressure system are too weak to ventilate the urban area well, so local emissions tend to accumulate. Subsidence inversions hamper or limit vertical mixing and further aggravate the situation by concentrating local and transported pollutants in the boundary layer and near the surface. High pressure areas also create a clockwise rotation that transports ozone, particulate matter (PM), and ozone precursors into the HGB area from the northeast.

Ozone formation in the HGB area is also associated with the daytime/nighttime flow reversal of the land/sea breeze, which was identified as a cause during the 1993 Gulf of Mexico Air Quality Study and confirmed by several more recent studies by state and federal researchers. Land/sea breezes are common in coastal areas near 30 degrees (º) north latitude and have been associated with ozone formation in other large metropolitan areas such as Athens, Greece and Barcelona, Spain in addition to the Houston area. Land/sea breeze flow reversal requires a light synoptic scale forcing associated with high pressure areas, thereby allowing local phenomena to dominate the local circulations. Light winds and the restricted vertical mixing allow high

1-1 concentrations of pollutants to accumulate during the night and morning hours, and the nocturnal land breeze carries the pollutants out over Galveston Bay and into the Gulf of Mexico. Then, during the afternoon, the sea breeze flow reversal carries the ozone and ozone precursors back into the city. In contrast, on low ozone days, precursor emissions are generally diluted and carried out of the area by stronger and more persistent winds.

Other area-specific factors also add to the complexity of ozone formation in the HGB area. For example, the large cluster of petrochemical industries and other sources in the Houston Ship Channel emit nitrogen oxides (NOX) along with a variety of volatile organic compounds (VOC) precursors not typically found in other urban areas. Oak forests near the city emit large amounts of isoprene, which reacts strongly with the NOX emitted from these industries and numerous other anthropogenic sources in the area. While local emissions sources routinely contribute to ozone levels in the HGB area, transport and exceptional events have become increasingly important as locally generated emissions and ozone decrease.

1.2 TRENDS IN HGB AREA EMISSIONS AND OZONE LEVELS The HGB area is the fifth largest core-based metropolitan area in the U.S., home to nearly 6.2 million residents as of 2012 (U.S. Census Bureau, 2013). Houston itself is the fourth largest city in the nation as of 2012 (U.S. Census Bureau, 2013). The following figures highlight the tremendous strides the area has made to reduce ozone-forming emissions and ground level ozone.

Over time, the HGB area has made great strides in reducing emissions of ozone precursors. Figure 1-1: HGB Area Point Source NOX Trends 1997 through 2012 shows that annual point source emissions of NOX in the eight-county HGB area decreased approximately 85% over the 1997 through 2012 period. The HGB area has also made great strides in reducing overall and, in particular, point source NOX emissions as shown in Figure 1-2: 2002 through 2011 NOX Emissions Inventory Trend for the HGB Area.

250,000

200,000

150,000

100,000

50,000

NOX Emissions Ozone Precursor Emissions per(tonsyear)

VOC Emissions 0 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Figure 1-1: HGB Area Point Source VOC and NOX Trends 1997 through 2012

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Figure 1-2: 2002 through 2011 NOX Emissions Inventory Trend for the HGB Area

Even more significantly, one-hour and eight-hour ozone design values have sharply decreased while population has steadily increased. Figure 1-3: HGB Area Ozone Design Value and Population Growth 1991 through 2013 shows that while population in the eight-county HGB nonattainment area has grown by almost 60%, the area’s one-hour ozone design value has decreased by approximately 43% and the eight-hour ozone design value has decreased by approximately 26%.

Figure 1-3: HGB Area Ozone Design Value and Population Growth 1991 through 2013

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1.3 OZONE REDUCTION PROGRESS AT THE HOUSTON EAST (CAMS 1) MONITORING SITE The Houston East (CAMS 1) monitoring site is located east of downtown Houston and near a major interstate highway, Interstate 610 loop and major industrial sources. (See Figure 1-4: Houston East (CAMS 1) Location). Siting details of the monitor are provided in Table 1-1: Siting Details of the Houston East (CAMS 1) Monitoring Site .

Figure 1-4: Houston East (CAMS 1) Location

Table 1-1: Siting Details of the Houston East (CAMS 1) Monitoring Site EPA Site Number: 482011034

CAMS: 1

Activation Date: January 1, 1973

Current Status: Active

Address: 1262 ½ Mae Dr., Houston, Texas

County: Harris

Latitude: 29º 46' 5'' North (29.7679707º)

Longitude: -95º 13' 14'' West (-95.2205867º)

The Houston East (CAMS 1) monitoring site epitomizes the air quality improvements made in the HGB area. As shown by Figure 1-5: Houston East (CAMS 1) Design Values 1990 through 2013, ozone design values for the Houston East (CAMS 1) monitoring site have decreased

1-4 significantly over the past 20 years. Since having a one-hour ozone design value of 210 parts per billion (ppb) in 1990, the Houston East (CAMS 1) monitoring site’s one-hour ozone design value decreased over 40% to 121 ppb in 2013. The site’s one-hour design value has not been above 125 ppb since 2006. The site’s eight-hour ozone design value has decreased significantly as well. Starting from 110 ppb in 1990 the Houston East (CAMS 1) monitoring site’s eight-hour design value decreased more than 25% to 80 ppb in 2013. The site has monitored attainment of the 1997 eight-hour ozone standard beginning since 2006. In Figure 1-5, the 1994 through 1996 design values for the eight-hour ozone NAAQS and the 1995 ozone design value for the one-hour ozone NAAQS are blank due to insufficient data return.

Figure 1-5: Houston East (CAMS 1) Design Values 1990 through 2013

1.4 THE EXCEPTIONAL EVENT OF AUGUST 26, 2011 As levels of ozone decrease across the entire HGB area, the contributions made by exceptional events and transport from regions outside the HGB area become more apparent. For years, the HGB area has received noticeable contributions of PM from fires in Central America, Mexico, Canada and several regions of the U.S. including Alaska (Morris et al. 2006; Wotawa and Trainer 2000; Forster et al. 2001). The HGB area also sees high levels of dust transported across the Atlantic Ocean, Caribbean Sea, and Gulf of Mexico from Northern Africa (Bozlaker 2013, TCEQ 2013). However, until recently, the focus has not been on ozone contributions from exceptional events unless those events were record events such as the Central American fires in April and May of 1998.

On August 26, 2011, during the 1:00 to 2:00 p.m. Central Standard Time (CST) hour, the Houston East (CAMS 1) monitoring site experienced a daily maximum ozone measurement of 128 ppb, which was an exceedance of the one-hour ozone NAAQS. The TCEQ believes that this one-hour exceedance was due to an exceptional event attributable to wildfires in the Pacific Northwest and in the Mississippi River Valley in Northeast Louisiana, Northwest Mississippi, and Southeast Arkansas that started during the last week of August 2011. Appendix A: Press Releases/Media Reports provides Web-related news reports (links and PDFs) that document the

1-5 occurrence of the fires. Background ozone on August 26, 2011 was unusually high, as demonstrated in Chapter 5: No Exceedance But For the Exceptional Event, and Chapter 4: A Clear Causal Relationship Between Fire Emissions and Ozone demonstrates that Fine Particulate Matter less than or equal to 2.5 microns in diameter (PM2.5) and ozone measurements at the Houston East (CAMS 1) site peaked at the same time.

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CHAPTER 2: EXCEPTIONAL EVENT RULE REQUIREMENTS FOR STATES

2.1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REQUIREMENTS On March 22, 2007, the United States (U.S.) Environmental Protection Agency (EPA) published the final Exceptional Events Rule (EER). The rule provided a process by which states could request that the EPA exclude monitoring data showing exceedances or violations of a criteria pollutant National Ambient Air Quality Standard (NAAQS) that were directly related to an exceptional event. When a state identifies a possible exceptional event, the state places a “flag” in the appropriate field of the data record in question for informational purposes in the Air Quality System (AQS) database. Prior to July 1 of the year following a state’s placement of the informational flag, it must inform the EPA of the flag and provide some initial reason for its placement. From that point, a state has three years after the quarter in which the flagged data were reported to the EPA to submit (after notice and opportunity for public comment) a package to the EPA demonstrating the reasons that the event should be considered exceptional. If the EPA is satisfied with the state’s demonstration package, it places a concurrence flag in the appropriate field and record in the AQS database.

The EER specifies at 40 Code of Federal Regulations (CFR) §50.14(c)(3)(iv) that states proposing to exclude monitoring data from consideration based on exceptional events must provide evidence that:

 the event satisfies criteria set out in the definition of exceptional event (40 CFR §50.1(j));

 there is a clear causal relationship between the measurement under consideration and the event;

 the event is related to a measured concentration in excess of normal historical fluctuations;

 there would have been no exceedance but for the event; and

 the public comment process was followed.

The EPA defines “exceptional event” in the EER (40 CFR §50.1(j)) as an event that:

 affects air quality;

 is not reasonably controllable or preventable; and

 is an event caused by human activity that is unlikely to recur at a particular location or a natural event, and is determined by the Administrator to be an exceptional event.

Additionally, the EER (40 CFR §51.930) requires that a state requesting a concurrence on an exceptional event day must take “appropriate and reasonable actions to protect public health from exceedances or violations of the national ambient air quality standards.” A state, at a minimum, must provide for:

 prompt public notification when air quality concentrations are expected to exceed a criteria NAAQS;

2-1  public education regarding actions that individuals may take to reduce exposure to unhealthy levels of the pollutant during and following an event; and

 implementation of appropriate measures to protect health from exceedances of criteria NAAQS caused by exceptional events.

The EPA has released three packages of interim guidance information to provide direction on how states are to meet these requirements and to consolidate documents and memos relating to high wind events and wildfires. The latest of these guidance packages, issued May 10, 2013, remains primarily focused on high wind events and other particulate matter (PM)-related events. The EPA expects to publish additional guidance more focused on ozone exceptional events related to fires later this year. Texas appreciates the EPA’s commitment to provide this guidance.

2.2 RESPONSES TO EXCEPTIONAL EVENT RULE REQUIREMENTS The following section summarizes the Texas Commission on Environmental Quality’s (TCEQ) adherence to the EER guidance and presents the necessary evidence and circumstantial information to support marking ozone data at the Houston East (CAMS 1) monitoring site as impacted by an exceptional event on August 26, 2011. Consistent with the guidance (page 2; EPA 2013), the TCEQ relies on a weight of evidence approach for its demonstration. As the EPA notes in the guidance (page 2; EPA 2013), the different requirements are inter-related, and thus, sections of this demonstration may support more than requirements and may refer to other sections of the demonstration package. Chapter 3: Normal Historical Fluctuations at the Houston East (CAMS 1) Monitoring Site, Chapter 4: A Clear Causal Relationship between Fire Emissions and Higher Ozone, and Chapter 5: No Exceedance but for the Exceptional Event provide a more detailed demonstration of how data from August 26, 2011 meet the rule requirements that:

 the event is related to a measured concentration in excess of normal historical fluctuations;

 there is a clear causal relationship between the measurement under consideration and the event; and

 there would have been no exceedance but for the event.

2.2.1 The Event Affected Air Quality The event under consideration is the wildfire-induced exceedance of the one-hour ozone NAAQS measured at the Houston East (CAMS 1) monitoring site on August 26, 2011. Although the one- hour ozone NAAQS (0.12 parts per million) has been revoked and replaced with the eight-hour NAAQS of 1997 and 2008, states are still required to adhere to specific requirements based on attainment or nonattainment of the one-hour ozone NAAQS. Consequently, the TCEQ is submitting this event as an exceptional event under the one-hour ozone NAAQS.

When the EPA published the final version of the EER on March 22, 2007 (U.S. National Archives and Records Administration 2007, 13569) it noted in the preamble that:

“The final rule permits a case-by-case evaluation, without prescribed threshold criteria, to demonstrate that an event affected air quality. The demonstration would be based on the weight of available evidence, but must consider the historical frequency of such measured

2-2 concentrations. While a State may determine the specific approach to use for such analysis, it must compare contemporary concentrations with the distribution of all measured data during the past several years.”

The August 26, 2011 event did affect air quality as evidenced by the following reasons. First, the event occurring on this day was well outside the normal historical fluctuations of recent monitored values (see Sections 3.1: An Analysis of Historic Seasonal Fluctuation of Maximum Daily Ozone Values at the Houston East (CAMS 1) Monitoring Site through 3.4: Short-Term Analysis of the Houston East (CAMS 1) Monitoring Site Daily Maximum Ozone Measurements). The maximum one-hour measurement at the Houston East (CAMS 1) monitoring site on this day was 128 parts per billion (ppb). This maximum ranks above the 99th percentile when considering the population of daily maximum one-hour measurements for a contemporary period of 2009 through 2011, which contains over 700 days at this monitoring site (see Section 3.1). Wildfires across the northwestern and southeastern U.S. produced significant amounts of ozone precursors. Winds transported these emissions to the Houston- Galveston-Brazoria (HGB) area and this fire-induced event caused ozone levels that were well outside the normal historical fluctuation of ozone values at the Houston East (CAMS 1) monitoring site. Second, the fire-induced event caused the day’s maximum hourly ozone value for August 26, 2011 to climb above the one-hour ozone NAAQS and exceed the standard. Through a weight of evidence approach, the TCEQ demonstrates the causal relationship between these fires and the measured ozone concentrations at the Houston East (CAMS 1) monitoring site and how this event affected air quality by causing an exceedance of the one-hour ozone NAAQS and higher ozone concentrations than would have been experienced without the transported wildfire emissions.

2.2.2 The Event is not Reasonably Controllable or Preventable The fires causing elevated ozone measurements at the Houston East (CAMS 1) monitoring site on August 26, 2011 occurred outside of Texas (see Section 4.3.2: Trajectory Analysis 2 – HYSPLIT Matrix Forward Trajectories from Areas with Clusters of Fires for a list of active fires outside of Texas that may have contributed to the ozone exceedance of August 26, 2011). The State of Texas could not have taken any action to prevent or control the fires.

2.2.3 The Event is not Likely to Recur or is Natural Of the active fires that might have contributed to this exceptional event, human activity initiated some and others started naturally. Once an area has been burned out, the likelihood of that area burning again declines for an extended period (assuming that the fire was completely extinguished), and the biomass available to burn is significantly reduced such that a fire in the same area in the next several years would likely yield significantly fewer emissions. Any of the fires attributable to human causes that occur outside of Texas are not controllable or preventable by the State of Texas.

2.2.4 The State Follows the Public Comment Process The details of the public comment process followed by the TCEQ appear in Chapter 6: Documentation of the Public Comment Process of this demonstration package, and the public comments received will be included - prior to submittal of this demonstration package to EPA Region 6.

2.2.5 Mitigation Requirements of 40 CFR §51.930 Section 51.930 of the EER requires that “a State requesting to exclude air quality data due to exceptional events must take appropriate and reasonable actions to protect public health from

2-3 exceedances or violations of the national ambient air quality standards.” The TCEQ addresses each of the specific requirements individually below.

2.2.5.1 Prompt Public Notification The first mitigation requirement is to “provide for prompt public notification whenever air quality concentrations exceed or are expected to exceed an applicable ambient air quality standard.” The TCEQ provided (and continues to provide) ozone, Fine Particulate Matter less than or equal to 2.5 microns in diameter (PM2.5), and Particulate Matter less than or equal to 10 microns in diameter (PM10) Air Quality Index (AQI) forecasts for the current day and the next three days for 14 areas in Texas including the HGB area. These forecasts are available to the public on the Today’s Texas Air Quality Forecast Web page of the TCEQ website (http://www.tceq.texas.gov/airquality/monops/forecast_today.html), and on the EPA’s AIRNOW website (http://airnow.gov/). The TCEQ provides near real-time hourly ozone measurements from monitors across the state, including the HGB area, which the public may access on the Current Ozone Levels page of the TCEQ website (http://www.tceq.texas.gov/cgi- bin/compliance/monops/select_curlev.pl). The TCEQ also publishes an AQI Report for a number of Texas metropolitan areas including the HGB area on the Air Quality Index page of the TCEQ website (http://www.tceq.state.tx.us/cgi-bin/compliance/monops/aqi_rpt.pl), which displays current and historical daily AQI measurements. Finally, the TCEQ publishes daily updates to its air quality forecast to interested parties through electronic mail . Any person wishing to receive these updates may register on the TCEQ website (http://www.tceq.texas.gov/airquality/monops/ozone_email.html). These measures provide daily and near real-time notification to the public of current, expected, and changing air quality conditions. 2.2.5.2 Public Education The second mitigation requirement is to “provide for public education concerning actions that individuals may take to reduce exposures to unhealthy levels of air quality during and following an exceptional event.” Through its website, the TCEQ provides the public with technical, health, personal activity, planning, and legal information and resources concerning ozone pollution.

The TCEQ maintains an ozone fact sheet (http://www.tceq.texas.gov/airquality/monops/ozonefacts.html), which provides important information regarding the health effects of ozone, steps that individuals can take to limit ozone formation, and actions they may wish to take to reduce their exposure to higher levels of ozone. A hyperlink to this fact sheet is located on the TCEQ daily air quality forecast page. The fact sheet points individuals towards additional health-related information from the Centers for Disease Control, the Texas Department of State Health Services, and the EPA.

The TCEQ’s main Web page for air (http://www.tceq.texas.gov/agency/air_main.html) provides air quality information on topics such as advisory groups, emissions inventories, air quality modeling and data analysis, scientific field studies, state implementation plans (SIP), air permits, rules, air monitoring data, and how to file complaints.

The TCEQ provides a specific “Air Pollution from Ozone” Web page (http://www.tceq.texas.gov/airquality/sip/criteria-pollutants/sip-ozone), which provides the latest information on air quality planning activities by both the TCEQ and the EPA.

The TCEQ’s website provides a hyperlink to the Texas “AirNow” website operated by the EPA (http://www.airnow.gov/index.cfm?action=airnow.local_state&stateid=45&tab=0). This website links the public to additional information regarding health effects of ozone,

2-4 strategies for reducing one’s exposure to ozone, and actions that individuals can take to reduce pollution levels.

The Texas Department of Transportation sponsors the public education and awareness campaign, “Drive Clean Across Texas” (http://www.drivecleanacrosstexas.org). The campaign raises awareness about the impact of vehicle emissions on air quality and motivates drivers to take steps to reduce air pollution. The campaign’s activities are concentrated during the summer months when ozone levels rise.

The TCEQ sponsors the “Take Care of Texas” program (http://takecareoftexas.org/air- quality), which addresses air quality and provides the public with proactive steps to reduce air pollution particularly on days when air quality forecasts are issued predicting greater potential for ozone formation.

2.2.5.3 Implementation of Measures to Protect Public Health When dealing with exceptional events originating from outside Texas (e.g., the case of August 26, 2011), there is very little that the TCEQ can do to mitigate the impact of additional ozone created by the exceptional event. Because the HGB area is an ozone nonattainment area classified as “Severe” for the one-hour standard, the TCEQ has implemented an extensive set of creative and innovative control strategies designed to reduce emissions of ozone precursors such as volatile organic compounds (VOC) and nitrogen oxides (NOX). Texas Attainment Demonstration SIP revisions for the HGB area include both Reasonably Available Control Measures and Reasonably Available Control Technologies analyses conducted by the TCEQ and have been approved by the EPA for the 0ne-hour and the 1997 eight-hour ozone NAAQS. These steps in conjunction with the ozone forecasts and notifications for the public strongly support the conclusion that Texas has taken every reasonable step to protect its citizens from exceedances of the ozone NAAQS. Sections 1.2: Trends in HGB Emissions and Ozone Levels and 1.3: Ozone Reduction Progress at the Houston East (CAMS 1) Monitoring Site of this demonstration package show that Texas’ strategies have been remarkably successful at reducing both precursor emissions and ozone levels across the HGB area and at the Houston East (CAMS 1) monitoring site. More detailed information about the state’s ozone reduction strategies can be found on the following Web pages:

Control Strategies for Stationary Sources: http://www.tceq.texas.gov/airquality/stationary- rules/ozone

Control Strategies for On-Road Mobile Sources: http://www.tceq.texas.gov/airquality/mobilesource/mobile_source.html

Air Permitting: http://www.tceq.texas.gov/permitting/air

Texas Emissions Reduction Plan Program: http://www.tceq.texas.gov/airquality/terp/erig.html

2.2.6 A Clear Causal Relationship Exists Scientific consensus exists that emissions from fires can increase ozone levels downwind of the fire area. In Chapter 4: A Clear Causal Relationship Between Fire Emissions and Higher Ozone, the TCEQ provides scientific evidence of a causal relationship with a review of the current technical literature regarding wildfires and ozone formation. Following the review, this demonstration package uses a variety of corroborative information to conclude that the ozone exceedance on August 26, 2011 was caused by fire emissions transported into the HGB area

2-5 from outside Texas. The TCEQ presents analyses of ambient monitoring data at the Houston East (CAMS1) and other nearby monitoring sites, trajectory modeling, aerosol modeling, synoptic meteorological conditions, satellite imagery, and a surrogate day analysis. These analyses show through a weight of evidence approach that fires in the Pacific Northwest and in the Mississippi River Valley in Northeast Louisiana, Northwest Mississippi, and Southeast Arkansas caused ozone levels measured at the Houston East (CAMS 1) monitoring site on August 26, 2011 to exceed the one-hour ozone standard.

2.2.7 In Excess of Normal Historical Fluctuations Although the EPA has not precisely defined when a measured concentration is “in excess of normal historical fluctuations,” the 128 ppb ozone measurement observed at the Houston East (CAMS 1) monitoring site on August 26, 2011 is clearly in excess of normal fluctuations. The daily maximum one-hour ozone value measured at the Houston East (CAMS 1) monitoring site on August 26, 2011 exceeds the 99th percentile of data from the 12 months of seasonal daily maximum ozone concentrations over a three-year period. The same day’s maximum one-hour ozone measurement also exceeds the 99th percentile of data from the annual daily maximum ozone concentrations for 2009 through 2011. In Chapter 3: Normal Historical Fluctuations at the Houston East (CAMS 1) Monitoring Site, the TCEQ analyzes monitoring data from the Houston East (CAMS 1) monitoring site from four different perspectives and shows the unique nature of this day.

2.2.8 There Would Have Been no Exceedance but for the Event In Chapter 5: No Exceedance but for the Exceptional Event, the TCEQ uses an analysis of a surrogate day to demonstrate that without the transported emissions of fires in other states, the exceedance of August 26, 2011 would not have occurred. The surrogate day analysis compares August 27, 2009 to August 26, 2011. These two days are very similar except for the presence of significant transported fire emissions on August 26, 2011, based on satellite imagery and HYSPLIT trajectories. Ozone levels measured on this surrogate day are below the one-hour ozone NAAQS. The lack of an exceedance on a day that is very similar to August 26, 2011 in terms of meteorology and local emissions provides powerful evidence that without emissions from the fires present immediately before the exceptional event, an ozone exceedance would not have occurred.

2-6 CHAPTER 3: NORMAL HISTORICAL FLUCTUATIONS AT THE HOUSTON EAST (CAMS 1) MONITORING SITE

The United States (U.S.) Environmental Protection Agency (EPA), in Attachment 1 (“Interim Exceptional Events Rule Frequently Asked Questions”) of its most recent interim guidance for the Exceptional Events Rule (EER) (pages 5-6; EPA 2013, Att. 1), suggests that states use more than one approach to establish that a claimed event day is outside of normal historical fluctuations in monitored measurements at the site. The EPA also suggests that, in most cases, analyses involve data over a three to five-year period and contain at least 300 observations (pages 5-6; EPA 2013, Att. 1). The Texas Commission on Environmental Quality (TCEQ) chose four different analyses to demonstrate the uniqueness of August 26, 2011:

 a historic comparison of seasonal one-hour daily maximum ozone measurements at the Houston East (CAMS 1) monitoring site;

 a historic comparison of annual one-hour daily maximum ozone measurements at the Houston East (CAMS 1) monitoring site;

 an analysis of the historic diurnal profile at the Houston East (CAMS 1) monitoring site for the month of August; and

 a 15-day time series comparison of one-hour ozone daily maximum ozone measurements from neighboring days in the years 2009, 2010, and 2011 at the Houston East (CAMS 1) monitoring site.

3.1 AN ANALYSIS OF HISTORIC SEASONAL FLUCTUATION OF MAXIMUM DAILY OZONE VALUES AT THE HOUSTON EAST (CAMS 1) MONITORING SITE On August 26, 2011 the Houston East (CAMS 1) monitoring site observed a daily maximum one- hour ozone concentration of 128 parts per billion (ppb), which exceeded the one-hour ozone National Ambient Air Quality Standard (NAAQS). The TCEQ’s analysis of ozone measurements at the Houston East (CAMS 1) monitoring site during the years 2009 through 2011 shows that this event is clearly outside of the normal historical fluctuations of seasonal ozone measurements at the site. The daily maximum ozone concentration from August 26, 2011 was compared to seasonal daily maximum ozone concentrations measured during those years.

For a seasonal analysis of historical one-hour ozone measurement fluctuations, the TCEQ chose the months of March through October and the years 2009 through 2011. The EPA has declared as a matter of rule that ozone season in the HGB area is year-round. The TCEQ has found that, historically, the months of March through October tend to measure higher ozone concentrations and exhibit a higher frequency of ozone exceedances than the other four months (TCEQ, 2010), thus the TCEQ review focused on these months to ensure a conservative review. The TCEQ used data from its Leading Environmental Analysis and Display System (LEADS). The data set used in this analysis contained data collected over a three-year period with 705 individual data points. Of these data points, August 26, 2011 is in the top 1% of observations, which indicates that it is well outside the historical norm. The result of this analysis is displayed in Figure 3-1: Percentile Rankings of Seasonal Daily Maximum One-Hour Ozone Concentrations at the Houston East (CAMS 1) Monitoring Site from 2009 through 2011. The only two days measuring higher than August 26, 2011 were August 29, 2011 at 136 ppb and July 16, 2010 at 129 ppb. August 29, 2011 was also likely influenced by the fire emissions described in this demonstration.

3-1 Given daily maximum one-hour ozone measurements from 705 ozone season days, the measurement of 128 ppb ozone occurs rarely – less than 0.5% of the time.

Figure 3-1: Percentile Rankings of Seasonal Daily Maximum One-Hour Ozone Concentrations at the Houston East (CAMS 1) Monitoring Site from 2009 through 2011

3.2 AN ANALYSIS OF ANNUAL DAILY MAXIMUM ONE-HOUR OZONE MEASUREMENTS AT THE HOUSTON EAST (CAMS 1) MONITORING SITE As discussed in this chapter, the TCEQ’s analysis of seasonal daily maximum one-hour ozone measurements provides strong evidence that the observed daily one-hour maximum on August 26, 2011 was outside of normal historical fluctuations. The TCEQ also compared the August 26, 2011 maximum one-hour ozone measurement to annual hourly ozone collected at Houston East over the years 2009 through 2011. The TCEQ used data from its LEADS. The data set used in this analysis contained data over a three-year period with 1,054 individual data points. Of these, the measurement on August 26, 2011 is in the top 1% of observations which again is well outside the historical norm observed values. The result appears in Figure 3-2: Percentile Rankings of Annual Daily Maximum One-Hour Ozone Concentrations at the Houston East (CAMS 1) Monitoring Site from 2009 through 2011. The only two days measuring higher than August 26, 2011 were August 29, 2011 at 136 ppb and July 16, 2010 at 129 ppb. August 29, 2011 was also influenced by the fire emissions described in this demonstration. Given the daily maximum one- hour ozone concentrations from these 1,054 individual data points, the measurement of 128 ppb ozone occurs very rarely – less than 0.5% of the time.

3-2

Figure 3-2: Percentile Rankings of Annual Daily Maximum One-Hour Ozone Concentrations at the Houston East (CAMS 1) Monitoring Site from 2009 through 2011

3.3 AN ANALYSIS OF DIURNAL PROFILES AT THE HOUSTON EAST (CAMS 1) MONITORING SITE In addition to analysis of daily maximum ozone measurements to view the historical fluctuation of ozone values, diurnal profiles of ozone may also be examined. This section examines diurnal profiles to provide further evidence that August 26, 2011 was clearly outside of normal historical fluctuations for ozone measurements at the Houston East (CAMS 1) monitoring site.

The TCEQ constructed a diurnal profile of ozone data collected at the Houston East (CAMS 1) monitoring site. Hourly ozone data from the month of August for 2008 through 2012 were obtained from the EPA’s Air Data website (http://www.epa.gov/airdata). August was chosen because the period contained August 26, 2011. A diurnal profile for the month of August provides a representative basis on which to compare hour-by-hour data from August 26, 2011. The years 2008 through 2012 were chosen to enlarge the time period analyzed, while allowing comparison of representative emission activity and meteorological conditions. The TCEQ arranged the data to generate a table with dates comprising the rows and hours of the day comprising the columns. Five invalid sampling days were removed due to lack of data, leaving a possible 150 observations for each hour of the day. The TCEQ calculated percentiles for each hour of the day. The analysis used 3,561 hourly observations out of a total 3,600 possible hourly observations because approximately 49 observations did not contain a sample measurement. The diurnal ozone profile at the Houston East (CAMS 1) monitoring site for August 26, 2011 was then compared to the standard fifth, 25th, Median, 75th, 95th, and 99th percentile values on an hour-by-hour basis. These percentile levels were used because they provide information regarding the central tendency and variability of the distribution at each hour of the day.

The results are shown in Figure 3-3: August Diurnal Profile Analysis for Ozone at the Houston East (CAMS 1) Monitoring Site during 2008 through 2012. Figure 3-3 clearly shows that the

3-3 day’s maximum ozone measurement of 128 ppb, occurring at the 13:00 hour Central Standard Time (CST) and based on a percentile calculation using 149 observations, is in the top 1% of values for this hour of the day. Further, the figure shows that hourly ozone measurements “follow” the 99th percentile curve beginning in the 12:00 hour CST and continuing for the rest of the day. Clearly, the ozone measurements observed at the Houston East (CAMS 1) monitoring site were outside of historical fluctuations on an hourly basis as well as a daily basis. This evidence makes an even stronger case for August 26, 2011 having met the requirement for ozone being outside of normal historical fluctuations. Figure 3-4: Hour-by-Hour Percent Rank for Ozone Measurements at the Houston East (CAMS 1) Monitoring Site on August 26, 2011shows that after the 11:00 hour CST, hourly ozone values “following” the 99th percentile curve never drop below the 97th percentile. This is additional evidence that a large portion of hourly ozone measurements at the Houston East (CAMS 1) monitoring site on August 26, 2011 were outside the normal historical fluctuation of ozone values on an hour-by-hour basis.

Figure 3-3: August Diurnal Profile Analysis for Ozone at the Houston East (CAMS 1) Monitoring Site during 2008 through 2012

3-4

Figure 3-4: Hour-by-Hour Percent Rank for Ozone Measurements at the Houston East (CAMS 1) Monitoring Site on August 26, 2011

3.4 SHORT-TERM ANALYSIS OF THE HOUSTON EAST (CAMS 1) MONITORING SITE DAILY MAXIMUM OZONE MEASUREMENTS Although its interim EER guidance calls for at least three to five years of data and a minimum of 300 observations for analysis of historical fluctuations, the EPA also notes that states could choose to analyze shorter time periods containing less data as an additional piece of evidence to substantiate a claim that the day in question is outside of normal historical fluctuations at the site (page 6; EPA 2013, Att. 1). In addition to evaluating a large historical data set as shown in the previous sections of this chapter, the TCEQ prepared a time series of 15 days so that the daily maximum one-hour ozone measurement for August 26, 2011 could be compared to calendar days immediately surrounding it in 2011. The time series began on August 19, 2011 and concluded on September 2, 2011. The 15 day period contained August 26, and seven days on both sides. The TCEQ also prepared similar time series for the corresponding calendar days 2009 and 2010 so that a comparison to 2011 might be made.

The resulting time series evaluations appear in Figure 3-5: A Comparison of August 26, 2011 to its Neighboring Days in 2011 and a Comparison of 2011 to the Years 2009 and 2010. This figure reveals another candidate exceptional event day in 2011. On August 29, 2011, the Houston East (CAMS 1) monitoring site experienced an exceedance of the one-hour ozone NAAQS that measured 136 ppb – 8 ppb higher than the exceptional event on August 26, 2011. This day experienced meteorological conditions similar to August 26, 2011 and had smoke and emissions emitted from wildfires in the northwestern and southeastern U.S. present in the HGB area. Although the TCEQ could submit a demonstration package in support of excluding August 29, 2011, it has not done so for the time being. The EPA requests that states only submit packages for exceptional event days that are of regulatory significance (page 5; EPA 2013). Since exclusion

3-5 of either day would bring the HGB area into attainment of the one-hour ozone NAAQS, only one of the days is of regulatory significance, and the TCEQ has chosen at this time to submit a request for exclusion for August 26, 2011.

Figure 3-5: A Comparison of August 26, 2011 to its Neighboring Days in 2011 and a Comparison of 2011 to the Years 2009 and 2010 shows that, with the exception of August 29, 2011, the daily maximum ozone concentration for August 26, 2011 is much higher than any neighboring days. The next highest day after August 26 in 2011 is August 28, 2011 with a daily maximum of 104 ppb – a difference of 24 ppb. Averaging across all of its 14 neighboring days in 2011 (including August 29) the daily maximum for August 26 is 49.6 ppb higher than the neighboring days. As a whole, the 15 days in 2011 are higher than their corresponding days in 2010 by 40.3 ppb and in 2009 by 16.9 ppb. When one compares August 26, 2011 to each of the other 44 days in this three-year window, August 26, 2011 is higher than the other days by 66.8 ppb on average. While this comparison of immediate neighboring days lacks the preferred number of observations, it offers a striking illustration of just how unique August 26, 2011 is for this period both in 2011 and compared to other recent years.

Figure 3-5: A Comparison of August 26, 2011 to its Neighboring Days in 2011 and a Comparison of 2011 to the Years 2009 and 2010

3.5 COMPARISONS BETWEEN NITROGEN OXIDES (NOX) AND OZONE DATA COLLECTED AT THE HOUSTON EAST (CAMS 1) AND NEARBY MONITORING SITES

Biomass burning is known to produce elevated concentrations of NOX, an important precursor of ozone, which can be transported far downwind (Morris, 2006; Val Martin, 2008). The TCEQ compared daily maximum hourly concentrations of NOX from August 26, 2011 at the Houston

3-6 East (CAMS 1) monitoring site to seasonal daily maximum NOX concentrations for 2009 through 2011 because of the important relationship between NOX and ozone formation.

Figure 3-6: Seasonal Percent Rankings of Daily Maximum One-Hour NOX Concentrations at the Houston East (CAMS 1) Monitoring Site from 2009 through 2011

Figure 3-6: Seasonal Percent Rankings of Daily Maximum One-Hour NOX Concentrations at the Houston East (CAMS 1) Monitoring Site from 2009 through 2011 plots three years of ozone season daily maximum one-hour NOX concentrations in rank order. The data set used by the TCEQ consists of 690 observations. The value for August 26, 2011, 122.42 ppb, ranks in the 94th percentile of the distribution, i.e., 94% of observed daily maximum NOX concentrations fell at or below this level. This value should be considered anomalous for the series, or outside normal historical fluctuation. This is not a surprising result since NOX is emitted from wildfires and is a precursor to ozone, and ozone concentrations were elevated at multiple HGB area monitors on August 26, 2011.

Because the fires that affected the Houston East (CAMS 1) monitoring site were quite distant from the region and required from several hours up to several days to reach the HGB area, the plume of emissions from the fires, including NOX, would likely have been dispersed over a wide area. Additional monitors near the Houston East (CAMS 1) monitoring site were also selected for similar analysis, to determine whether the patterns observed for ozone and NOX at the Houston East (CAMS 1) monitoring site were observed elsewhere, suggesting a regional phenomenon. If events at the Houston East (CAMS 1) monitoring site were isolated and not observed elsewhere, it would suggest a more localized emissions event likely influenced the Houston East (CAMS 1) measurements. Nearby monitors selected for analysis include Houston Aldine (CAMS 8), Channelview (CAMS 15), Clinton (CAMS 403), and Houston Deer Park (CAMS 35). These monitors were chosen because they all measure ozone and NOX , they are in close geographic proximity to Houston East (CAMS 1) monitoring site and share similar meteorology patterns. The monitors are shown on Figure 3 7: Map of Monitors in Close Proximity to the Houston East (CAMS 1) Monitoring Site.

3-7

Figure 3-7: Map of Monitors in Close Proximity to the Houston East (CAMS 1) Monitoring Site

Statistics from the distributions of daily maximum one-hour ozone concentrations at each of the monitors were computed over 2009 through 2011 and are presented in Table 3-1: Seasonal Daily Maximum One-Hour Ozone for the Houston East (CAMS 1) and Nearby Monitors, 2009 through 2011. The table includes the maximum one-hour ozone on August 26, 2011 and the percentile of that peak compared to the three ozone seasons of observations. The distributions of daily maximum one-hour ozone concentrations are remarkably similar across the five monitors. Ozone concentrations on August 26, 2011 were unusually high with respect to the three ozone seasons under consideration at all of these monitors. The data suggest that a more widely dispersed emission event from outside the HGB area impacted numerous monitors, and it was not a local source affecting only the Houston East (CAMS 1) monitoring site on August 26, 2011.

3-8 Table 3-1: Seasonal Daily Maximum One-Hour Ozone for the Houston East (CAMS 1) and Nearby Monitors, 2009 through 2011 Houston Houston Houston East Channelview Clinton Aldine Deer Park Statistic (CAMS 1) (CAMS 15) (CAMS 403) (CAMS 8) (CAMS 35) (ppb) (ppb) (ppb) (ppb) (ppb) Minimum 8 14 10 12 11 25th Percentile 35 37 32 39 35 Median 46 48 43 49 47 75th Percentile 61 61 57 63 61 90th Percentile 77 79 71 79 76 Maximum 136 126 125 129 139

Maximum on 128 97 114 129 104 8/26/2011

8/26/2011 99% 97% 99% 99% 98% Percentile

Statistics from the distributions of the daily maximum one-hour NOX concentrations at each of the monitors computed for the 2009 through 2011 ozone seasons are presented in Table 3-2: Seasonal Daily One-Hour NOX Statistics for the Houston East (CAMS 1) and Nearby Monitors During 2009 through 2011 and Comparison with August 26, 2011 along with the daily peak one-hour NOX concentration on August 26, 2011 and the percentile of that peak compared to the three ozone seasons of observations. The distributions are somewhat similar across monitors, although there is a great deal of variability in the maximum concentrations. Daily maximum one-hour concentrations measured at Channelview (CAMS 15), Clinton (CAMS 403), Houston Aldine (CAMS 8), and Houston Deer Park (CAMS 35) on August 26, 2011 were all higher than normal and ranged between the 79th and 95th percentiles. The daily maximum NOx one-hour concentrations on August 26, 2011 for Channelview (CAMS 15), Clinton (CAMS 403), Houston Aldine (CAMS 8), and Houston Deer Park (CAMS 39) exceeded their median values by 39 ppb, 67 ppb, 29 ppb, and 46 ppb, respectively. The complexity of NOX behavior in the atmosphere, the large variability of these measurements due to local sources, and transport complicate determination of whether these monitors are experiencing a regional or local event based solely on the NOX data. It is evident however that some event is influencing the area and values are higher than normal across a wide geographic area encompassing large parts of east Texas, Louisiana, Arkansas and Mississippi.

3-9 Table 3-2: Seasonal Daily One-Hour NOX Statistics for the Houston East (CAMS 1) and Nearby Monitors During 2009 through 2011 and Comparison with August 26, 2011 Houston Houston Houston Channelview Clinton Aldine Deer Park Statistic East (CAMS (CAMS 15) (CAMS (CAMS 8) (CAMS 35) 1) (ppb) (ppb) 403) (ppb) (ppb) (ppb) 2 4 4 0 0 Minimum 25th 17 15 26 13 9 Percentile 30 23 40 23 15 Median 75th 58 42 58 38 25 Percentile 90th 91 85 90 63 43 Percentile 341 400 265 160 133 Maximum Maximum 122 62 107 52 64 on 8/26/2011 8/26/2011 94% 85% 95% 79% 86% Percentile

For August 26, 2011, the Houston East (CAMS 1) monitoring site observed high hourly ozone values above recent historical fluctuation. The surrounding monitors, Houston Aldine (CAMS 8), Channelview (CAMS 15), Clinton (CAMS 403), and Houston Deer Park (CAMS 39), exhibited exceptionally high hourly ozone concentrations. With the other area monitors and Houston East (CAMS 1) measuring historically high hourly ozone, this ozone event is above historical fluctuation and qualifies as an exceptional event.

3.6 SOUTHEAST TEXAS MONITORING SITES To get a better understanding of where August 26, 2011 stood with respect to other days and other monitors, the TCEQ compared the daily maximum one-hour ozone measurements for all ozone season days in the years 2009 through 2011 across a larger area. Such an evaluation can reveal patterns that suggest either local or regional influences, as well as temporal anomalies. For this period of time, there were 21 monitoring sites in the HGB area, nine monitoring sites in the Beaumont/Port Arthur area, and one Clean Air Status and Trends Network (CASTNET) site at the Alabama-Coushatta Tribal Reservation in Polk County that regularly submitted data to the EPA Air Quality System, These monitoring sites are the entire complement of federally registered ozone monitoring sites in Southeast Texas. The TCEQ examined the daily maximum one-hour ozone measurements on August 26, 2011 as well as the percent rank of these measurements at each of the 31 monitoring sites over the 2009 through 2011 ozone seasons.

The detailed results are in Table 3-3: Daily Maximum Values and Percentile Rankings of August 26, 2011 at Monitors in Southeast Texas. Of the 31 sites, two did not collect sufficient measurements to have what EPA considers a valid monitoring day according to the one-hour ozone NAAQS, two monitoring sites exceeded the one-hour ozone NAAQS, four of the

3-10 monitoring sites ranked below their 95th percentile, and 25 monitoring sites exceeded their 95th percentile on August 26, 2011. These results are especially compelling when one notes that 18 of 19 sites in the HGB area had measurements that exceeded their site’s 95th percentile, regardless of geographical location.

On a typical high ozone day in the HGB area, high one-hour ozone values are more likely to occur in only one part of the HGB area (for example near the Ship Channel, on the eastern side of Harris County, or in the southern part of Harris County) on a single day (TCEQ, 2010). The fact that so many unusually high ozone values (greater than the 95th percentile) occurred on the same day and were spread throughout the entire HGB area leads to a conclusions that a highly unusual factor was at work. As shown in Section 5.1: Analysis of a Surrogate Day, meteorology and emissions in the HGB area on August 26, 2011 were typical in many ways. The only apparent factor that most likely explains the breadth of high ozone measurements in southeastern Texas on August 26, 2011 is the transport of fire-related ozone and ozone precursors into the HGB area and mixing down where they could cause unusually high ozone values in the HGB area on this day.

Table 3-3: Daily Maximum Values and Percentile Rankings of August 26, 2011 at Monitors in Southeast Texas Site* Daily Maximum (ppb) Percentile (%) Houston East (CAMS 1) 128 99.7% Northwest Harris County MISSING N/A (CAMS 26) Houston Westhollow 94 99.4% (CAMS 410) Bunker Hill Village 91 98.3% (CAMS 562) Houston Bayland Park 102 98.6% (CAMS 53) Houston Lang (CAMS 408) 110 99.0% Houston Croquet 98 98.7% (CAMS 409) Lake Jackson (CAMS 1016) 80 97.8% Conroe Relocated 90 98.3% (CAMS 78) Manvel Croix Park 117 99.1% (CAMS 84) Houston Texas Avenue 106 99.0% (CAMS 411) Houston Aldine (CAMS 8) 129 100.0% Houston Regional Office 120 99.5% (CAMS 81)

3-11 Site* Daily Maximum (ppb) Percentile (%) Houston Park Place (CAMS 104 98.5% 416) Houston North Wayside 131 100.0% (CAMS 405) Houston Clinton 114 99.0% (CAMS 403) Deer Park (CAMS 35) 104 98.5% Channelview (CAMS 15) 97 97.2% Lynchburg Ferry 88 95.3% (CAMS 1015) Seabrook Friendship Park 70 89.8% (CAMS 45) Galveston 99th Street MISSING N/A (CAMS 1034) Alabama-Coushatta 71 82.7% Reservation (CASTNET) Hamshire (CAMS 64) 70 91.5% Beaumont Downtown 88 98.0% (CAMS 2) Nederland High School 92 99.3% (CAMS 1035) SETRPC Jefferson Co 92 99.4% Airport (CAMS 643) Port Arthur West 88 98.0% (CAMS 28) SETRPC Port Arthur 76 96.6% (CAMS 628) SETRPC Sabine Pass 78 93.1% (CAMS 640) SETRPC Mauriceville 97 100.0% (CAMS 642) West Orange (CAMS 9) 81 95.9% *Except for Houston East (CAMS 1), the monitoring sites are listed in order of increasing longitude (from West to East).

3-12 CHAPTER 4: A CLEAR CAUSAL RELATIONSHIP BETWEEN FIRE EMISSIONS AND HIGHER OZONE

4.1 LITERATURE REVIEW In this section, the Texas Commission on Environmental Quality (TCEQ) reviews the scientific literature on fire emissions and ozone in order to answer the following questions about ozone and wildfires; Can wildfire emissions produce ozone or ozone precursors? Can the ozone and ozone precursors produced by wildfires be transported long distances? Have ozone and precursors produced by wildfire transported over long distances and affected surface ozone in Texas?

Jaffe (2012) provides an excellent overview and summary of research on characterization, transport and fate of emissions from wildfires, and their effects on air quality including contributions to exceedances of the ozone National Ambient Air Quality Standard (NAAQS). The peer-reviewed studies agree that wildfires can be a source not only of smoke, particulate matter, and carbon dioxide but also of the ozone precursors non-methane organic gases and nitrogen oxides (NOX). Ozone can be enhanced above background concentrations far downwind of fires due to transport of ozone in photochemically active or photochemically dormant plumes. In fact, ozone may not be formed immediately downwind of a fire but may form much further downwind when the chemical atmosphere of the fire plume becomes more conducive to ozone formation (Andreae, et al. 1994). Under suitable chemical conditions, emissions from fires can remain in the atmosphere for many days and can be tracked and detected thousands of kilometers (km) downwind. The discussion below presents more details about the large body of work related to wildfire-generated ozone.

Wildfire emissions can produce ozone and ozone precursors as well as smoke aerosols. Some of the earliest work published on the topic of wildfire emissions reported ozone concentrations at 40 to 50 parts per billion (ppb) (Westberg, 1981) and 44 ppb (Stith, 1981) above ambient levels in regions downwind or near biomass fires. Ozone is enhanced due to the substantial quantities of ozone precursors emitted by wildfires and other biomass burning. Pickering (1996) reported that biomass burning significantly increased NOX and hydrocarbons downwind resulting in ozone formation rates of 7 to 8 ppb per day. Mauzerall (1998) determined that ozone production in fire plumes was limited by available NOX but that ozone continued to be produced as a plume aged. Cheng (1998) observed 50 to 150% enhancements in nitrogen dioxide (NO2) and ozone downwind from fires and that forest fires had a noticeable influence on air quality in urban areas even though local emissions were much higher. Jonquieres (1998) reported ozone production of 15 to 35 ppb per day in plumes from 1987 African fires as well as circulation patterns that contributed to long-range transport.

Fires have affected ozone concentrations throughout the world. Large fires in Alaska, Canada, , Colorado, Indonesia, Central America, Africa, and Siberia have all affected ozone concentrations in areas downwind. Goode (2000) found an ozone production rate of about 50 ppb per hour in smoke plumes from four Alaskan fires in 1997. Jaffe (2008) reported that inter- annual variation in ozone was related to the size of the area burned and the types of biomass consumed by wildfires in the western United States (U.S.). Large fire years exhibited widespread enhanced ozone with mean regional ozone elevated by 2 ppb and 8.8 ppb in maximum fire years. The presence of fires was a more important predictor of ozone than temperature. Pfister (2008) modeled increases of about 10 ppb in eight-hour averages of surface ozone from fires in California in 2007.

4-1 Fujiwara (1999) used ozonesondes to study emissions from Indonesian fires in 1994 and 1997 and reported that ozone exceeded 80-100 ppb within different layers of the troposphere, due to photochemical production of ozone from precursors emitted by the fires. Hauglustaine (1999) reported 20 to 25 ppb enhancements to tropospheric ozone from 1997 Indonesian fires. Kita (2000) observed significant increases in ozone from 1994 and 1997 fires in Indonesia and noted the importance of horizontal advection in the lower troposphere and vertical transport. Verma (2009) reported ozone was enhanced by up to 90 ppb in locations close by and distant from Siberian fires in areas where sunlight and NOX are abundant and lower ozone in the free troposphere where thick aerosol plumes occur. Kaufman (1992) found a strong relationship between spatial distribution of fires and ozone concentrations for 1989 fires in South America. Chandra (2009) estimated that El Nino-related drought and resultant fires in 2006 contributed 2 to 3% of the global ozone.

Ozone production from wildfires is influenced by factors including availability and types of precursors, weather patterns, fuel type, combustion characteristics, extent of burn area, photochemistry, proximity of urban areas, and other factors (Jaffe, 2012). Ozone can form rapidly after precursors are emitted from fires. Trentmann (2003) noted elevated ozone of 70 ppb in a young biomass burning plume. Models were used to simulate behavior of smoke plumes as they were transported at high altitudes and later mixed to the surface. Yokelson (2009) found within fire plumes ozone concentrations increased by about 15% in less than one hour, which is faster and at finer spatial scales than some models can simulate.

Ozone can also be formed from wildfire-generated precursors far downwind from the original source. Val Martin (2006) studied impacts of boreal wildfire emissions six to 15 days downwind at a high altitude site in the Azores including long-range transport, large enhancements of total reactive nitrogen (NOY) and NOX, and decomposition of peroxyacetyl nitrate (PAN) to NOX leading to continuing ozone formation reaching 75 ppb in well-aged plumes.

The scientific literature clearly indicates that wildfires and other types of biomass burning can generate ozone precursors in large quantities, and these precursors can form ozone near the original fire source and can continue ozone formation far downwind.

Ozone, ozone precursors, and smoke generated by wildfires can be transported thousands of km from the fires and can influence ozone concentrations far downwind and over a large area. Thompson (1996) found elevated ozone over the Atlantic Ocean, up to 90 ppb, in layers all the way up to the tropopause, from African biomass burning. Ozone formation rates of up to 15 ppb per day were observed within the lowest 4 km of the troposphere. The ozone maximum was attributed to abundant precursors from fires, long residence time in stable air, and convective transport with additional NOX from lightning and biogenic sources.

Singh (2000) found maximum PAN and ozone over the Pacific Ocean in very dry air from 5 to 7 km altitude and traced these to biomass burning in South Africa with large perturbations in ozone and precursors due to long-distance transport and subsiding trajectories.

Phadnis (2000) compared ozone with and without influences from 1987 fire emissions in China and found increases of 5 to 10 ppb with an increase in the monthly average of about 30% in the boundary layer close to the fire.

Forster (2001) found that large-scale haze over Europe in 1998 was caused by emissions from Canadian fires transported over thousands of km at altitudes from 3 to 6 km.

4-2 Jaffe (2001) observed significantly higher carbon monoxide (CO), ozone, NOX, PAN, and non- methane hydrocarbons at an ostensibly “clean” site on the coast of Washington (state) attributable to unusually large areas of biomass burning in Asia in 1997 and 1998.

McKeen (2002) reported enhancements of 10 to 30 ppb of ozone in transported air, found that most of the increase in ozone from fires in Canada was attributable to NOX emitted by the fires, and that urban receptor areas are more sensitive to influences from long-range transport from fires because of the many local precursor sources.

Staudt (2002) identified a considerable influence of biomass burning on ozone up to 12 km in altitude with long-range transport from Africa and South America. Biomass burning, with decomposition of PAN, was the predominant source of NOX in the lower troposphereand lightning was the predominant source of NOX in the upper troposphere with subsidence of NOX from the uppermost troposphere.

Duncan (2003) reported on emissions from 1997 Indonesian wildfires enhancing ozone concentrations 10%, and CO by 50%.

Sinha (2003) observed transport of smoke plumes from southern Africa westward over the Atlantic Ocean to South America and the southern Pacific Ocean in 2000, with ozone of 76 ppb aloft and thin, relatively clean layers between thick layers of pollution at about 3 km aloft.

Honrath (2004) traced an enhancement of ozone at a tropospheric site in the Azores backward to North American fire emissions due to long-range transport.

Jaffe (2004) modeled transport of smoke from Siberian fires to North America and found ozone enhancements of 5 to 9 ppb linked to these global processes and that this elevated background contributed to exceedances in the U.S. Pacific northwest.

Konda (2004) reported that 70% of ozone from Asian fires was transported to the western Pacific, PAN was conserved during transport, and NOX decreased with altitude.

Bertschi (2004, 2005) found well-defined layers of enhanced ozone and other emissions from fires from 0 to 6 km altitude with ozone exceeding 100 ppb in some cases. These layers were found to be efficient in transporting fire emissions from Asia to North America. These researchers traced these layers back to Siberia using the HYSPLIT trajectory model and found that under certain conditions this Siberian smoke was transported down to the surface.

DeBell (2004) studied the largest Canadian fire plume to impact the U.S. in a decade and found elevated ozone and Total Reactive Nitrogen (NOY), as well as nitrate, ammonium, and sulfate ions that varied with elevation and latitude attributable to transport and surface deposition.

Lapina (2006) found significant impact of boreal wildfires on ozone in the lower free troposphere.

Pfister (2006) estimated an increase of 7 to 9% in ozone in the Azores from well-aged boreal forest fire plumes.

Real (2007) observed long-range transport of chemically active plumes from 2004 Alaskan fires. A plume was tracked by aircraft over North America, the North Atlantic Ocean and Europe. Ozone was observed to increase by 17 ppb over five days, while enhanced concentrations of CO,

4-3 VOC, and NOy were also measured. Ozone production was determined to be dependent on temperature during transport and water vapor in the lower troposphere.

Yokelson (2007a) reported smoke from African fires was transported over 2,000 km with elevated ozone, NO2, and other reactive species.

Tanimoto (2008) reported ozone enhancements in Japan from biomass burning in Siberia ranged from slightly negative to up to 40%.

Val Martin (2008) found year-round potential for substantial ozone formation in the Azores downwind of North American fire sources due to transport and decomposition of PAN.

Nassar (2009) examined the contribution of Indonesian fires to ozone enhancements and found a range of 10 to 75% depending on season.

Oltmans (2010) observed unusually high ozone over 35 continuous hours in Alaska related to enhanced lower troposphere ozone enhancements likely from biomass burning in Russia.

Singh (2010) found widespread influences in the Arctic from 2008 biomass burning in Europe and Asia with PAN-dominant plumes transported in the mid to upper troposphere.

Jaffe (2011) found that ozone generated by biomass burning in the western U.S. strongly influenced both surface and free troposphere ozone concentrations, with mixing ratios frequently exceeding 65 ppb between 3 to 6 km above ground level. Further, Jaffe (2011) determined that “wildfires significantly increase the number of exceedance days across the western US.” This extensive body of evidence supports the supposition that elevated concentrations of ozone can be found at locations far distant from the sources of precursors.

Widger et al. (2013) analyzed 32 wildfire events between 2004 through 2011 that may have influenced ozone concentrations observed at the Mount Bachelor observatory in Oregon.Two events were linked to wildfire emissions that had been transported long distances (from and British Columbia), and both of these had enhanced ozone. They found an apparent link between higher ozone production in biomass burning plumes and the interaction of the plumes with urban emissions.

In conclusion, the scientific literature clearly shows that ozone generated from fires can be transported thousands of km across oceans and continents to affect air quality in places distant from the original fire sources.

Wildfire-produced ozone and precursors have been transported long distances to affect surface ozone in Texas. In the recent scientific literature, three examples of long-distance transport of fire-generated smoke, ozone, and/or ozone precursors into eastern Texas have been documented, as discussed below:

 May 1998 Central American fires;

 July 19-20, 2004 Alaskan and western Canadian wildfires; and

 September 25-26, 2006 Southern California wildfires.

4-4 The largest event in recent history occurred in May 1998 when the springtime agricultural fires that are set annually in Mexico and Central America to clear the fields went out of control and burned large areas. The smoke from these fires was transported thousands of km into Texas and the central U.S., and the ozone resulting from the emissions affected many cities. Peppler et al. (2000) documented smoke in Oklahoma at the Atmospheric Radiation Measurement field station as the smoke and associated emissions were transported through Texas. They observed smoke aerosols with several different remote sensing tools and with standard surface particulate matter monitors. In addition, high ozone was observed coincidently with the smoke at sites in central Oklahoma and Dallas-Fort Worth with the highest concentrations observed on May 11, 1998. Rogers and Bowman (2001) observed high aerosol concentrations during May 1998 by satellite with the Total Ozone Mapping Spectrometer (TOMS) and tracked the observed aerosol back to the source regions in Central America with trajectory modeling. Cheng and Lin (2001) also used back trajectories to track smoke to the sources but used the Potential Source Contribution Function technique. In et al. (2007) modeled the smoke episode using the Community Multi-scale Air Quality chemical transport model. During May 1998, the TCEQ documented strong enhancements of background ozone resulting in eight-hour ozone exceedances in cities that rarely, if ever, observe ozone exceedances, e.g., Brownsville.

Another event occurred in July 2004. Morris et al. (2006) reported observations by satellite, ozone sounding balloons, surface monitoring, and back trajectories that were consistent with an enhancement of background ozone concentrations by wildfire emissions. Ozonesonde measurements on July 19-20, 2004 showed a layer of enhanced ozone that could be traced with trajectories back to a region where large wildfires had been occurring in Alaska and western Canada, a distance of over 4,000 km.

During the Texas Air Quality Study field campaign conducted in 2005 and 2006, two research groups observed smoke aerosols, CO, and ozone in a layer of the lower troposphere that may have been able to mix down to the surface (Schwarz et al., 2008; Brioude et al. 2007). On September 25-26, 2006, the two groups intercepted smoke plumes aloft in eastern Texas. Brioude et al. presented satellite images of smoke plumes apparently traveling from the southwest U.S. into Texas. Back trajectory analyses linked the smoke plumes to wildfires that were occurring at the time in southern California.

Based upon these and related studies, emissions from distant fires have been shown to strongly influence the air quality in Texas including enhancing surface ozone concentrations. The studies listed above identified three different source regions for fire emissions affecting Texas cities indicating that a variety of transport patterns are capable of carrying fire emissions and ozone for long distances into Texas.

4.2 WILDFIRES OF 2011 Figure 4-1: Locations of Wildfires and Prescribed Burns Identified by NOAA, shows locations of wildfires and prescribed burns identified by the National Oceanic and Atmospheric Administration (NOAA) using satellite measurements and the Wildfire Automated Biomass Burning Algorithm (WFABBA) during the week preceding the proposed exceptional event on August 26, 2011. Fires were detected in almost every state, as well as Canada and Mexico, but were concentrated in the Pacific Northwest, Central Plains, and Southeastern U.S.

4-5

Figure 4-1: Locations of Wildfires and Prescribed Burns Identified by NOAA

Because the exceptional event at the Houston East (CAMS 1) monitoring site on August 26, 2011 was the result of transport of ozone and ozone precursors from fires burning upwind, it is informative to examine the size and intensity of the fires in the latter half of August 2011. Numerous federal and state agencies identify, monitor, and combat wildfires and prescribed burns in the U.S. and North America, including the U.S. Forest Service, the National Park Service, the Bureau of Land Management, the U.S. Fish and Wildlife Service and the Federal Emergency Management Administration. These and other agencies participate in the National Interagency Coordination Center. Some fires are reported by monitoring agencies, while others are only identified from satellite measurements using computer algorithms and manual inspection.

The NOAA uses the WFABBA (http://wfabba.ssec.wisc.edu/algorithm.html) to identify likely fires for each day using satellite measurements and imagery, computer algorithms, and manual error correction. These fires could be wildfires or prescribed burns and could be as small as two acres depending on conditions (personal communication, 2013). Some fires might not be detected due to cloud cover or poor timing of satellite overpass. The algorithm can also incorrectly identify as fires thermal anomalies that are actually reflection of solar radiation off reflective surfaces, such as clouds, sand, water, or even solar panels. As many of these fire

4-6 anomalies as possible are removed from the database by NOAA analysts using a manual correction technique. Exact locations of fires are difficult to determine because many fires are smaller than a single satellite image pixel, fire fronts are mobile, the Geostationary Operational Environmental Satellites (GOES) platform provides two measurements per day, and different satellites, due to different viewing angles (azimuths), might detect fires in slightly different locations. However, though locations of fires are only estimates, most are believed to be actual fires and to be within about 2 km of the estimated location. Larger fires, which emit more ozone precursors, are more likely to be correctly identified with the algorithm because they provide a clearer thermal anomaly when compared to surrounding thermal conditions. The number of fires identified in each state and the countries of Canada and Mexico are reported in Table 4-1: Number of Fires Identified by NOAA, by Day, August 20 through 26, 2011.

Table 4-1: Number of Fires Identified by NOAA, by Day, August 20 through 26, 2011 Region/Sta Aug. Aug. Aug. Aug. Aug. Aug. Aug. te 20 21 22 23 24 25 26 Lower Mississippi River Valley Arkansas 16 3 21 11 5 13 24 Louisiana 24 27 40 48 3 24 43 Mississippi 22 11 57 57 10 56 61

Upper Mississippi River Valley Illinois 0 1 3 0 4 0 2 Iowa 0 0 0 0 1 1 1 Minnesota 1 9 3 9 9 32 22 Missouri 1 0 0 1 4 6 8 Wisconsin 0 0 4 0 0 3 1

Southeastern US Alabama 11 5 23 6 21 17 19 Florida 10 23 20 15 43 9 15 Georgia 11 15 20 25 35 32 33 North Carolina 1 5 6 11 7 18 0 South Carolina 0 0 2 2 0 1 4 Tennessee 0 1 6 4 9 1 4

South Central Plains Kansas 0 11 9 27 25 26 15 Oklahoma 7 3 1 2 3 9 7 Texas 23 25 21 15 19 25 15

4-7 Region/Sta Aug. Aug. Aug. Aug. Aug. Aug. Aug. te 20 21 22 23 24 25 26 North Central Plains Nebraska 0 1 1 0 1 2 1 North Dakota 1 7 5 4 11 3 24 South Dakota 1 5 1 4 1 1 1

Southern Rocky Mountains/Pacific Southwest Arizona 2 3 2 2 2 1 0 California 4 32 27 19 5 17 25 New Mexico 6 1 2 2 2 1 0 Nevada 3 0 0 0 3 6 13

Utah 15 0 14 1 1 1 2

Northern Rocky Mountains/Pacific Northwest Alaska 0 1 0 0 0 0 1 Idaho 23 78 99 63 73 40 79 Montana 16 28 194 254 166 57 105 Oregon 1 6 32 31 8 89 251 Washington 9 8 4 20 4 4 11 Wyoming 6 37 114 137 45 13 31

Eastern/Midwest US Indiana 0 0 0 0 1 0 0 Kentucky 0 1 4 1 3 0 3 Michigan 0 0 0 0 1 0 2 New Jersey 0 0 2 0 0 0 0 Ohio 0 0 5 0 0 0 0 Pennsylvania 0 2 0 0 0 0 0 Virginia 1 11 7 7 18 19 11

West Virginia 0 2 1 0 0 0 0

International Canada 18 41 109 48 46 17 92 Mexico 4 22 73 64 72 48 15 Note: Locations of fires identified by WFABBA and expert review were supplied by NOAA.

The number of fires identified varied greatly from day to day. Some fires could be prescribed burns that are often agricultural in nature. Others could be smaller wildfires that ended quickly.

4-8 A few were larger fires that persisted across many days and consumed larger areas of biomass. Though fires were scattered throughout nearly every state in the U.S., fires were mostly clustered in the central and western states. These areas included the Mississippi Delta in Mississippi, Louisiana, and Arkansas, the central plains of Kansas and Oklahoma, the northern plains of North Dakota plus Manitoba and Saskatchewan provinces in Canada, and in the Pacific Northwest in Idaho, Montana, and Oregon.

Figure 4-2: Annual Number of Wildfires in the U.S., shows that the number of wildfires recorded from 1960 through 2013 was also variable, with an upward trend peaking in 1983 bounded between 50,000 and 100,000 ever since. The total number of wildfires in 2011 (65,500) was not unusually large. However, as shown in Figure 4-3: Annual Acreage Burned in the U.S., the acreage burned by wildfires in 2011 (6.6 million acres) is one of the highest on record.

300,000

250,000

200,000

150,000 AnnualNumber ofFires

100,000

50,000

0 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 Year (1960-2013)

Figure 4-2: Annual Number of Wildfires in the U.S.

4-9 10,000,000

9,000,000

8,000,000

7,000,000

6,000,000

5,000,000

4,000,000 AnnualAcreage Burned (acres)

3,000,000

2,000,000

1,000,000

0 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 Year (1960-2013)

Figure 4-3: Annual Acreage Burned in the U.S.

The trajectory analyses presented in Section 4.4: Trajectory Analyses show that fires burning in several states along the Mississippi River (Arkansas, Louisiana, and Mississippi) could have contributed ozone and ozone precursors to the Houston-Galveston-Brazoria (HGB) area during the days and hours preceding the ozone exceedance on August 26, 2011. These analyses also determined that emissions from wildfires burning in the northern Rocky Mountains region and the Pacific Northwest during the week preceding the elevated ozone event, were delivered to the HGB area by August 26, 2011.

The U.S. EPA’s guidance on preparation of exceptional events demonstrations suggests that states include news reports, special weather statements, advisories, and related information on fires, dust storms, or other phenomena published at the time of the event that help establish the occurrence and geographic extent of an event in support of exceptional events evidence. Not all fires identified through remote sensing will be covered by the news media. TCEQ provides a sampling of news reports below. These news reports give an idea of how quickly wildfires can grow and start.

On August 20, 2011, the Missoulian, the newspaper in Missoula Montana, (Florion 2011) reported on three fires that had burned a combined 4760 acres in the (northwestern Montana). One of the fires had grown from 2000 to 2600 acres just that day and two of the fires were not actually being suppressed because they were in a wilderness area.

Two days later, on August 22, 2011, the Missoulian (Scott 2011) was reporting that the two wilderness area fires had grown from 3,850 acres to 4,100 acres and were expected to burn for weeks. The third fire which had grown from 910 acres to 1215 acres, was not being actively suppressed. This fire, too, was expected to burn for a number of weeks.

That same day, the Missoulian ran three other articles on wildfires in Montana and neighboring Idaho. A local wildfire had just started and already burned 1,000 to 2,000 acres (Nickell 2011).

4-10 A second article covered the beginning of a new fire on the Montana-Wyoming border (Associated Press August 24, 2011). The third article (Erickson 2011) reported on the Saddle Complex fire which had burned about 1,045 acres near the Idaho-Montana border. In the case of the Saddle Complex fire, the paper noted that “The Saddle Complex fire burning in a remote portion of Idaho's Frank Church-River of No Return Wilderness moved onto the Bitterroot National Forest on Sunday afternoon and grew to 1,018 acres during the day Monday. The complex is comprised of two wildfires burning near the Montana-Idaho border about 20 miles southwest of Painted Rocks State Park - the Saddle fire on the Idaho side and the 27-acre Stud fire on the Montana side of the border. According to Salmon-Challis National Forests public information officer Jesse Bender, both fires are burning in an area that has not been impacted by fire in more than 100 years. The Saddle fire is being managed for resource benefits, meaning it is not actively being suppressed.”

On August 24, 2011, the Missoulian was reporting on additional fires in southeastern Montana that had burned over 14,000 acres (Associated Press August 24, 2011). The previously mentioned fire in the Frank Church-River of No Return Wilderness had grown to 18,275 acres and crossed into Montana (Associated Press August 24, 2011). The Missoulian published an additional five articles on August 24, including a report that smoke plumes were visible in Missoula from a prescribed burns set on August 12 and 15, 2011 in the Nez Perce National Forest (Idaho) (Missoulian August 24, 2011).

The local CBS television affiliate in Sacramento, California, reported on August 26, 2011 that “The main highway into Yosemite National Park remains closed as firefighters continue to battle a wildfire outside of the park. A U.S. Forest Service officials [sic] says the blaze has consumed more than 1,000 acres since it was reportedly sparked Thursday when a motor home caught fire (CBS Sacramento 2011).” Another CBS affiliate in San Francisco reported that “Officials say the blaze has consumed about 400 acres along Highway 140 since it was first reported a little before 1 p.m. Thursday.”

4.3 TIMING OF HOURLY FINE PARTICULATE MATTER LESS THAN OR EQUAL TO 2.5 MICRONS IN DIAMETER (PM2.5) AND OZONE MEASUREMENTS ON AUGUST 26, 2011

Hourly PM2.5 and ozone measurements at the Houston East (CAMS 1) monitoring site provide good evidence that the measured ozone exceedance is related to smoke from wildfires in the northwestern and southeastern U.S. Figure 4-4: Ozone and PM2.5 Diurnal Profiles Measured at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 shows that ozone and PM2.5 reach their daily maximum during the same hour. The PM2.5 data for this figure relies on five data points from 11:00 AM (Local Standard Time (LST)/ Central Standard Time (CST)) through 3:00 PM (LST/CST) that were used for the purposes of the EPA’s Air Now website, but were subsequently determined to be invalid because the internal station temperature rose above 87º Fahrenheit (F). TCEQ monitoring staff do not believe that the increased internal temperature, which did not rise above 89.7º F, would significantly impact to the quality of the data collected during those hours. In fact, the TCEQ believes that higher temperatures may have caused some semi-volatile particles to evaporate, thereby underestimating the actual PM2.5 values. Because the internal station temperature is unlikely to have seriously altered PM2.5 measurements, the TCEQ presents the results for consideration with the appropriate caveats. Regardless of the absolute accuracy of the PM2.5 data, Figure 4-4 shows the rising and peaking of PM2.5 values at the same time that ozone rises and peaks.

4-11

Figure 4-4: Ozone and PM2.5 Diurnal Profiles Measured at the Houston East (CAMS 1) Monitoring Site on August 26, 2011

4.4 TRAJECTORY ANALYSES The TCEQ performed numerous analyses of trajectories to determine whether emissions from wildfires and prescribed burns (i.e., unspecified fires) could have contributed to the one-hour ozone exceedance observed at the Houston East (CAMS 1) monitoring site on August 26, 2011. The four approaches employed the NOAA Hybrid Single Particle Lagrangian Integrated Trajectory (HYSPLIT) trajectory and dispersion model (Draxler and Rolph, 2014) to trace possible trajectories that could have transported biomass-burning emissions from fires to the HGB area and the Houston East (CAMS 1) monitoring site. The first method initialized backward trajectories at varying altitudes from the Houston East (CAMS 1) monitoring site at the time of the one-hour ozone exceedance event to estimate their likely paths backward in time to their origins. These trajectories were compared to locations of known or likely fires identified by NOAA. The second method estimated forward trajectories from areas throughout the U.S. where extensive fire activity was detected during the week prior to the one-hour exceedance event using the HYSPLIT matrix option to determine whether emissions from these areas could have been transported to the HGB area. Third, a small-scale matrix was defined over the HGB area, and HYSPLIT backward trajectories were estimated to explore local-scale atmospheric behavior during the week prior to the event. Finally, forward trajectories were initialized from locations of fires identified by NOAA for each day of the week prior to the event and evaluated to determine if emissions from those fires were delivered to the HGB area and the Houston East (CAMS 1) monitoring site.

The first method revealed many backward trajectories that traveled over or near areas with substantial wildfire activity the week prior to the one-hour exceedance event before arriving at the location of the Houston East (CAMS 1) monitoring site. The trajectory analysis indicates that emissions of ozone or precursors from these fires were carried by prevailing winds to the HGB area. The second method identified two matrices of five that were tested where fire activity was

4-12 extensive, which could have provided ozone or precursors that were delivered to the HGB area. The third method identified a strong subsidence event over the HGB area beginning late August 24 or early August 25 and continuing through August 26, 2011 that transported air parcels from the upper troposphere, where long distance transport occurs, down into the mixing layer and near the surface at the Houston East monitor. The fourth method tracked forward trajectories from every detected fire in North America during the week prior to the exceedance event and found that many trajectories approached the HGB area and the Houston East (CAMS 1) monitor. The combination of these multiple approaches provides strong evidence that emissions from fires burning throughout the continent were transported to the HGB area at altitudes low enough to mix with local emissions and background ozone precursors in the ambient air and be detected by the surface monitoring network.

4.4.1 Trajectory Analysis 1 – Backward Trajectories from the Houston East (CAMS 1) Monitoring Site The first trajectory analysis computed 168-hour, or seven-day, backward trajectories from the Houston East (CAMS 1) monitoring site on August 26, 2011 using the HYSPLIT model (Draxler and Rolph, 2013) available on-line from NOAA. Twenty trajectories were estimated using starting altitudes from 50 meters (m) to 4,500 m above ground level, including 50 m, 100 m, and 250 m to 4,500 m at 250 m increments. Output from HYSPLIT includes maps and coordinates of the vertices of the estimated trajectories at one-hour increments, as well as estimates of the altitude of the boundary layer, also called the mixing layer, at each vertex and other measures including altitude of the terrain, relative humidity, and solar radiation.

Vertices of estimated HYSPLIT backward trajectories are plotted in Figure 4-5: Twenty HYSPLIT Backward Trajectories Originating at the Houston East (CAMS 1) Monitoring Site, August 26, 2011 at 17:00 UTC. NOAA-detected fires for August 20 through 26, 2011 are shown as red triangles. Twenty trajectories were initialized at 50 m, 100 m, and then at 250 m increments (250 m through 4,500 m altitude) and run backward 168 hours (7 days), terminating on August 19, 2011 at 17:00. Dark blue circles indicate vertices that were within the mixing layer and below 1 km altitude; light blue circles are vertices within the mixing layer but above 1 km; grey circles are vertices below 1 km but above the mixing layer; and open (unshaded) circles are vertices above 1 km and above the mixing layer. Many of the trajectories, particularly those at high altitudes, originated over the Pacific Ocean on Saturday, August 20, 2011, traveled northeast over the Rocky Mountains region the next day (August 21, 2011), and began traveling east-southeast over the northern Great Plains the day after that (August 22,2011). The trajectories continued southeasterly over the central Mississippi Valley on August 23, 2011, though some began that day in the Pacific Northwest, encountered very high wind speeds, and were transported near the Mississippi Valley the same day. On August 24, 2011, most of these trajectories reversed direction and began heading southwest over the lower Mississippi Delta region, continued in a west-southwest or southwesterly direction across that region on August 25, 2011, and then terminated at the Houston East (CAMS 1) monitoring site on August 26, 2011. Other trajectories, notably those at much lower altitudes, originated in the Gulf of Mexico or over land in the southeastern U.S. These trajectories traveled much more slowly in a westerly direction before arriving at the Houston East (CAMS 1) monitoring site at 17:00 UTC on August 26, 2011.

4-13

Figure 4-5: Twenty HYSPLIT Backward Trajectories Originating at the Houston East (CAMS 1) Monitoring Site, August 26, 2011 at 17:00 UTC

Figure 4-6: Altitudes of HYSPLIT Backward Trajectories Originating at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC shows altitudes of the 20 trajectories hour by hour, starting at the left where they began at 17:00 UTC on August 19, 2011 and following their altitudes until they arrived at the Houston East (CAMS 1) Monitoring Site at 17:00 UTC on August 26, 2011. From Figure 4-7: Altitudes of HYSPLIT Backward Trajectories Originating at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC Shown on a Logarithmic Scale, it can be noted that trajectories that terminated at the Houston East (CAMS 1) monitoring site at higher elevations generally also began seven days earlier at higher altitudes and did not descend below the boundary layer. However, several trajectories that terminated at the Houston East (CAMS 1) monitoring site at elevations below 2 km began seven days earlier at similar elevations below 2 km, as well, and passed into and out of the mixing layer at various points along the journey. Generally, these trajectories entered the mixing layer during the day, as the mixing layer expanded, then exited at night as it contracted. These trajectory paths suggest that it was possible that fire emissions could have been carried aloft from locations of fires to the HGB area and the Houston East (CAMS 1) monitoring site.

Note that estimated trajectories terminating at the Houston East (CAMS 1) monitoring site at 17:00 UTC at heights of 1 km and below (six total trajectories) all entered and exited the mixing layer numerous times during transit, except for the 50 m termination height trajectory, which resided entirely within the mixing layer during transit. All estimated trajectories up to 1 km terminated within the mixing layer when they reached the Houston East (CAMS 1) monitoring site. A sharp subsidence event late in the evening of August 25, 2011 brought air parcels from

4-14 altitudes above 2 km down below 1 km over the course of only 3 or 4 hours on the morning of August 26 and into the mixing layer only hours before the exceedance event at Houston East (CAMS 1). Many trajectories that were transported at altitudes above 3 km descended very sharply as well to altitudes below 2 km. All estimated trajectories that terminated at Houston East (CAMS 1) at 750 m and below (50 m, 100 m, 250 m, 500 m, and 750 m) originated at altitudes below the mixing layer several days previously, were lofted above the mixing layer, as high as 2,500 m in some cases, over August 23, 2011 through August 25,2011 and then descended into the mixing layer late on August 25, 2011.This result suggests that these trajectories rose and fell at many points while in transit offering numerous opportunities to entrain ozone and precursors from fires while in transit to the Houston East (CAMS 1) monitoring site. 3000 m in mixing layer 2750 2500 above mixing layer 2250 2000 2000 1750 1500 1250 1000 1000 750 500 250 100 0 50 19 20 21 22 23 24 25 26 27 Day of August 2011 Source: HYSPLIT, NOAA Figure 4-6: Altitudes of HYSPLIT Backward Trajectories Originating at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC

4-15 m 2750 10000 2500 2250 2000 1750 1500 1250 1000 1000 750 500

250

100 100

50 in mixing layer Note logarithmic above mixing layer axis scale. 10 19 20 21 22 23 24 25 26 27 Source: HYSPLIT, NOAA Day of August 2011 Figure 4-7: Altitudes of HYSPLIT Backward Trajectories Originating at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC Shown on a Logarithmic Scale

4.4.2 Trajectory Analysis 2 – HYSPLIT Matrix Forward Trajectories from Areas with Clusters of Fires The HYSPLIT model offers a powerful option for performing trajectory analysis using a matrix or grid of starting locations. To assess the possibility that emissions from areas with active fires could have been transported to the HGB area, forward trajectories were computed using the matrix option in HYSPLIT. This option enables the user to compute trajectories for starting points arrayed in a grid with coordinates supplied by the user. In this way, a large number of trajectories can be computed simultaneously for an area of a specified size to determine whether trajectories originating from that area could have traveled to a specific location downwind.

Five matrices were defined for five source regions with large numbers of identified fires. These matrices are detailed in Table 4-2: HYSPLIT Matrices Defined for Forward Trajectory Computations and shown in Figure 4-8: Map of Matrices Defined for Computing Forward Trajectories Using the HYSPLIT Matrix Option . Matrix 1 covered Kansas, Oklahoma, and the northern part of Texas. Matrix 2 covered the Mississippi Delta region of Arkansas, Louisiana, Mississippi, and Tennessee, plus Alabama and parts of Georgia and other southeastern states. Matrix 3 covered the northern plains states of Minnesota, North Dakota, South Dakota, and parts of Iowa, Wisconsin, and Nebraska. Matrix 4 covered the northern Rocky Mountains states of Idaho, Montana, Wyoming, and parts of Nevada and Utah. Matrix 5 covered the Pacific Northwest including Oregon, Washington, and parts of California and Idaho.

The 84 hour forward trajectories, the maximum duration permitted by the HYSPLIT matrix option, were computed starting on August 23, 2011 at 5:00 UTC. Matrix number 2 was also run over 48 hours since it is much closer to the HGB area and emissions could have easily reached the Houston East (CAMS 1) monitoring site much sooner than 84 hours. Computed trajectories were then evaluated to determine if any (1) entered the mixing layer near a fire, and (2) passed

4-16 close enough to the Houston East (CAMS 1) monitoring site to have carried fire emissions to the monitor.

Table 4-2: HYSPLIT Matrices Defined for Forward Trajectory Computations Total Duration Southwest Northeast Corner Matrix Description Trajectories (hrs) Corner of Matrix of Matrix in Grid

Lat Lon Lat Lon

(deg) (deg) (deg) (deg)

1 OK/KS/TX 84 33º -103º 40º -94º 80

2 AR/LA/MS/AL/TN 84 28º -95º 37º -84º 120

2b AR/LA/MS/AL/TN 48 28º -95º 37º -84º 120

3 MN/ND/SD/IA/WI 84 43º -105º 50º -91º 120

4 ID/MT/WY/NV/UT 84 41º -118º 49º -104º 135

5 OR/WA/CA/NV 84 41º -125º 49º -117º 81

Figure 4-8: Map of Matrices Defined for Computing Forward Trajectories Using the HYSPLIT Matrix Option

Examination of forward trajectories computed for these matrices determined that fire emissions, which were not distinguished by type, originating in Matrices 3 and 4 likely did not travel to the HGB area. A couple of trajectories originating from Matrix 1 entered Texas and approached the HGB area while several trajectories originating from Matrices 2 and 5 approached the HGB area and the Houston East (CAMS 1) monitoring site on August 25 and August 26, 2011.

4-17 Trajectories originating from Matrix 1 at lower altitudes, e.g. 50 m and 100 m, were impacted by a clockwise rotation that carried them north then east then south. For other starting altitudes, most of the trajectories traveled northeast or east. Several started east then reversed direction and traveled southwest into Texas and other southeastern states. Two trajectories were seen to travel near the HGB area, and these originated in western Kansas and southeastern Colorado. The latter originated at an altitude of 1 km, dropped into the mixing layer in central Kansas, and passed through a cluster of fires in Kansas near several more fires in Arkansas and Louisiana before traveling within about 20 miles of the Houston East (CAMS 1) monitoring site. However, the ones that entered Texas did so on August 25, 2011, a day in advance of the exceedance event. Remnants of fire emissions in these air parcels could have lingered in the atmosphere another day and contributed to the exceedance event.

As shown inFigure 4-9: 84-Hour HYSPLIT Forward Trajectories from Matrix 2 at Selected Starting Altitudes Originating on August 23, 2011 at 5:00 UTC, many trajectories originating from Matrix 2 were affected by a clockwise rotation pattern suggesting a synoptic weather pattern impacting the entire central plains region that week. Trajectories originating from the northern part of Matrix 2 continued to the northeast, and those to the south curved southwest into the Gulf of Mexico and Texas. Winds in the center of this matrix were variable. Several trajectories traveled into the HGB area and near the Houston East (CAMS 1) monitoring site, one at the 750 m starting height and one at 1 km.

For both Figure 4-9 and Figure 4-10: 84-Hour HYSPLIT Forward Trajectories from Matrix 2b at Selected Starting Altitudes Originating on August 24, 2011 at 17:00 UTC, dark blue circles are coordinates that are below 1 km and in the mixing layer; light blue are above 1 km but in the mixing layer; grey are below 1 km but above the mixing layer; and open (unshaded) circles are above 1 km and above the mixing layer. Houston East is represented by the brown circle.

4-18

MATRIX 2 – 50 meters MATRIX 2 – 100 meters

MATRIX 2 – 250 meters MATRIX 2 – 500 meters

MATRIX 2 – 750 meters MATRIX 2 – 1 km

Figure 4-9: 84-Hour HYSPLIT Forward Trajectories from Matrix 2 at Selected Starting Altitudes Originating on August 23, 2011 at 5:00 UTC

Because Matrix 2 is in close proximity to the HGB area, HYSPLIT models for Matrix 2 were re- run with a shorter duration of 48 hours. Results of these models are presented as Matrix 2b. As shown in Figure 4-10, many trajectories originating from Matrix 2b (identical to Matrix 2 only of shorter duration) traveled to the HGB area and approached the Houston East (CAMS 1)

4-19 monitoring site, including seven at 250 m starting altitude, four at 750 m, and six at 1 km. Emissions from fires burning in this region on August 24 and August 25 were likely transported to the HGB area over the next 48 hours and contributed to the exceedance event at the Houston East (CAMS 1) monitoring site on August 26, 2011.

MATRIX 2b – 50 meters MATRIX 2b – 100 meters

MATRIX 2b – 250 meters MATRIX 2b – 500 meters

MATRIX 2b – 750 meters MATRIX 2b – 1 km Figure 4-10: 84-Hour HYSPLIT Forward Trajectories from Matrix 2b at Selected Starting Altitudes Originating on August 24, 2011 at 17:00 UTC

4-20 Most trajectories originating from Matrix 5 traveled northeast or south. None of the 84-hour trajectories reached Texas. However, because the HYSPLIT matrix option is limited to trajectories of 84 hours duration or less, this matrix analysis was limited. Analyses of forward trajectories from the locations of NOAA-detected fires presented below indicate that over longer durations, trajectories originating from the area of Matrix 5 do reach the HGB area and could have affected the Houston East (CAMS 1) monitoring site.

Details of specific trajectories from Matrix 1 and Matrix 2b that approached the HGB area and the Houston East (CAMS 1) monitoring site are presented in Figure 4-11: Locations (Left Panels) and Altitudes (Right Panels) of HYSPLIT Forward Trajectories Passing Near the Houston East (CAMS 1) Monitoring Site on August 26, 2011. Left panels in this figure are maps of Texas and/or the coast of the Gulf of Mexico. The dark red circle is the location of the Houston East (CAMS 1) monitoring site. Black squares are the grids defined for the HYSPLIT Matrix noted. Dark blue circles are trajectory vertices within the mixing layer below 1 km altitude; light blue circles are within the mixing layer above 1 km; grey circles are above the mixing layer but below 1 km; open (unshaded) circles are above the mixing layer and above 1 km. Right panels show altitude by day: red circles are trajectory vertices within the mixing layer; and grey squares are above the mixing layer. These trajectories are presented alongside their vertical profiles to show that they entered and exited the mixing layer at various points along their paths during which time they could have encountered fire emissions. Several trajectories terminated on August 26, 2011 within the mixing layer, which suggests an influence on surface ambient air quality. Trajectories arriving from the Gulf of Mexico experienced over night mixing heights under 2 km, whereas trajectories arriving from the east and northeast over Louisiana and Mississippi saw over night mixing heights up to 4 km. Along several trajectories terminating at Houston East (CAMS 1), HYSPLIT reports mixing heights as low as 10 m during night time hours on August 23 and 24, 2011 and as low as 50 m during night time hours on August 25 and 26, 2011.

4-21

Figure 4-11: Locations (Left Panels) and Altitudes (Right Panels) of HYSPLIT Forward Trajectories Passing Near the Houston East (CAMS 1) Monitoring Site on August 26, 2011

4-22 4.4.3 Trajectory Analysis 3 – HYSPLIT Matrix 6 Previously, in Figure 4-6: Altitudes of HYSPLIT Backward Trajectories Originating at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC, an extreme subsidence event is evident during the later hours of August 25, 2011 and the morning hours of August 26, 2011. In meteorological terms, subsidence occurs when an air mass sinks or loses altitude, usually over a broad area. From the course of the HYSPLIT trajectories shown, it appears the event occurred over many meters of altitude in the atmosphere above 500 m, up to at least 3 km, with the sharpest downward motion occurring near 750 m altitude. This event could have brought transported emissions from active fires burning elsewhere in North America down to the surface where they contributed to ozone formation and the subsequent exceedance of the one-hour ozone NAAQS on August 26, 2011 as explained in Section 4.4.4: Ozonesonde Anlaysis.

From Figure 4-6, it appears the event began at lower altitudes in the afternoon hours of August 25, 2011 where the vertical slopes of the trajectories began their descent to lower altitudes. Later, in the late hours of August 25, 2011 and the early hours of August 26, 2011, higher altitude trajectories exhibit a sharp descent over a very brief period of only a few hours. The trajectory that terminates at the Houston East (CAMS 1) monitoring site at 750 m on August 26, 2011 began the day at nearly 2.5 km altitude and shows the steepest descent.

To investigate this phenomenon further, 84-hour HYSPLIT backward trajectories for termination heights from 50 m to 1,250 m were estimated using the matrix option for a set of matrix points in close proximity to the Houston East (CAMS 1) monitoring site. The definition of this matrix, termed Matrix 6, is presented in Table 4-3: The Definition of HYSPLIT Matrix 6, yielded 110 grid cells. Matrix 6 is defined over an area that is large enough to facilitate examination of the event over an area that covers a large portion of the urban area but uses a grid spacing that is small enough to observe smaller scale distinctions in the behavior and extent of the event. A map of the grid overlaid onto the HGB area is displayed in Figure 4-12: Map of HYSPLIT Matrix 6 Overlaid on the HGB Area.

Table 4-3: The Definition of HYSPLIT Matrix 6 Attribute Latitude Longitude

Southwest Corner 29.50º -95.50º

Northwest Corner 30.00º -95.00º

Grid Spacing 0.05º 0.05º

Houston East 29.7679707º -95.2205867º

4-23

Figure 4-12: Map of HYSPLIT Matrix 6 Overlaid on the HGB Area

HYSPLIT backward trajectories estimated from Matrix 6 are presented in the following seven figures. Trajectory coordinates that were resident in the mixing layer are colored blue and those above the mixing layer are colored red. Trajectory coordinates for trajectories terminating at the four matrix cells closest to the Houston East (CAMS 1) monitoring site are colored green. For Matrix 6 termination heights of 50 m and 100 m, shown in Figure 4-13: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 50 m at Houston East on August 26, 2011 at 17:00 UTC and Figure 4-14: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 100 m at Houston East on August 26, 2011 at 17:00 UTC, no subsidence is apparent over August 25, 2011 and August 26, 2011 as these trajectories traverse a relatively stable altitude over those two days. However, prior to August 25, 2011 both sets of trajectories descended from much higher altitudes beginning on August 23, 2011 and continuing on August 24, 2011. For these two figures and the following five, trajectory coordinates resident in the mixing layer are blue, while those above the mixing layer are red. Trajectories for the four matrix points nearest the Houston East (CAMS 1) monitoring site are green.

4-24 800 meters

600

400 altitude 200

0 23 24 25 26 27 Date in August 2011 Figure 4-13: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 50 m at Houston East on August 26, 2011 at 17:00 UTC

1200 meters

900

600 altitude

300

0 23 24 25 26 27 Date in August 2011 Figure 4-14: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 100 m at Houston East on August 26, 2011 at 17:00 UTC

4-25 For the Matrix 6 termination height of 250 m, shown in Figure 4-15: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 250 m at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC, the extreme subsidence event beginning on August 25, 2011 becomes apparent. Most of these trajectories began at lower altitudes on August 23, 2011 within the mixing layer, and then ascended above the mixing layer throughout August 24, 2011 and early August 25, 2011. Beginning about mid-day on August 25, 2011, these trajectories all began a sharp descent, which stabilized early on August 26, 2011. This finding indicates that air parcels over the HGB area just one or two days prior to the exceedance event were transported down near the surface. Air containing fire emissions transported to the HGB area by the long-range trajectories shown earlier would have been subject to this vertical transport upon arrival in the HGB area the day before and early on the day of the exceedance event.

1200 meters

900

600 altitude 300

0

23 24 25 26 27 Date in August 2011 Figure 4-15: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 250 m at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC

4-26 For the Matrix 6 termination height of 500 m, shown in Figure 4-16: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 500 m at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC, the trajectories began on August 23, 2011 from altitudes ranging from 400 m to above 2 km. Most of these trajectories remained above the mixing layer throughout August 23, 24, and 25, 2011. Beginning very early on August 25, 2011, these trajectories began a sharp descent that continued throughout the day. Many of these trajectories entered the mixing layer late on August 25, 2011. By the early hours of August 26, 2011, these trajectories stabilized at around 400 m to 500 m, rising above the mixing layer in the early hours of that day and then returning to the mixing layer just a few hours before the exceedance event occurred.

2400meters

2000

1600

1200 altitude 800

400

0 23 24 25 26 27 Date in August 2011 Figure 4-16: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 500 m at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC

4-27 The altitude changes revealed for the Matrix 6 termination heights of 750 m, shown in Figure 4- 17: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 750 m at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC, are very informative. These trajectories began on August 23, 2011 at a very wide range of altitudes, from about 140 m to over 5 km, though all were above the mixed layer. Over the next two days, lower altitude trajectories ascended in the atmosphere passing into and out of the mixing layer. Higher altitude trajectories descended somewhat. All trajectories began a rapid descent late in the evening of August 25, 2011, some into the mixing layer, and converged by early August 26, 2011 to end at 750 m, within the mixing layer. Therefore, emissions transported into the area aloft (up to 3 km) were brought down into the layer that could mix ozone and ozone precursors with air measured by the monitor at the time the exceedance was monitored.

3000 meters

2000

altitude 1000

0 23 24 25 26 27 Date in August 2011 Figure 4-17: Altitudes of Estimated HYSPLIT Backward Trajectories for Matrix 6 Terminating at 750 m at the Houston East (CAMS 1) Monitoring Site on August 26, 2011 at 17:00 UTC

4.4.4 Ozonesonde Analysis Weather balloons with ozone-measuring instruments are periodically launched in the HGB area and elsewhere around Texas. These balloons, termed “ozonesondes,” “radiosondes,” or just “sondes,” sample the atmosphere and radio these measurements to ground-based receivers providing nearly continuous measurement of characteristics of the atmosphere, including ozone concentrations, at different altitudes as the balloons ascend. These measurements provide details of the meteorology of the upper atmosphere, which are not obtainable with ground-based sensors, as well as showing the presence of atmospheric layers containing greater or lesser concentrations of ozone. Launches conducted for the TCEQ are intended to sample when meteorological conditions suggest imminent arrival of synoptic weather systems that could be transporting elevated concentrations of ozone or precursors in the upper atmosphere.

4-28 Information derived from these launches provides additional weight of evidence to support there was transport of elevated ozone and precursors from long distances during August 2011. While no launch was performed on August 26, 2011, launches were conducted on August 19, 2011, August 27, 2011, and August 29, 2011. Radiosondes containing ozone instruments were released from the campus of the University of Houston, located about nine miles west of the Houston East (CAMS 1) monitoring site. These launch dates were selected in order to sample synoptic, or large scale, weather systems potentially delivering air parcels containing elevated concentrations of ozone and precursors into the HGB area. Decisions to launch on these days were made independent of the observation of elevated ozone at the Houston East (CAMS 1) monitoring site but were made based on forecasts of synoptic weather patterns over North America, southeast Texas, and the HGB area. Ozone concentrations measured at the surface of the location of the launch ranged from 57 ppb to 136 ppb on the three days. Ozone concentrations at upper elevations were higher, substantially higher in two cases, indicating air parcels in the upper atmosphere contained high concentrations of ozone. In particular, August 29, 2011 was impacted by the same fires and weather pattern as August 26, 2011 and has ozone measurements aloft of 153 ppb. This coupled with the back trajectory evidence showing that there was some mixing between altitudes of up to 3 km and the boundary layer on or just prior to the August 26, 2011 exceptional event is supportive of long range transport of elevated ozone. Table 4-4: Ozone Concentrations (ppb) at the Surface and Peak Ozone Concentrations (ppb) in the Lower Troposphere (Measured by Ozonesondes) provides these measurements.

Table 4-4: Ozone Concentrations (ppb) at the Surface and Peak Ozone Concentrations (ppb) in the Lower Troposphere (Measured by Ozonesondes) Ozone at Surface Peak Ozone in Altitude of Peak Date (ppb) Troposphere (ppb) Ozone (km)

August 19, 2011 57 84 1.887

August 27, 2011 89 95 0.927

August 29, 2011 136 153 2.600

Figure 4-18: Ozone Concentrations Measured by Ozonesondes Launched from University of Houston Campus, August 19, August 27, and August 29, 2011, Below 20 km Altitude shows ozone concentrations as the balloons rose through the atmosphere from ground level (0.1 km altitude) to 20 km altitude. Figure 4-19: Ozone Concentrations Measured by Ozonesondes Launched from University of Houston Campus, August 19, August 27, and August 29, 2011, Below 4 km Altitude shows the same information for measurements below 4 km to facilitate closer inspection of the lower ozone concentrations observed in the lower atmosphere. Above about 15 km altitude, ozonesondes encounter the lower boundary of the stratospheric ozone layer, which contains exceptionally high concentrations of ozone compared to surface concentrations. While ozone from this layer can be transported downward and impact ozone concentrations at lower altitudes (Jacob, 1992), this section is focused on ozone transported in atmospheric layers at lower altitudes, that is, those below 15 km.

4-29 20 km

15

19-Aug-11

27-Aug-11

10 29-Aug-11 altitude 5

0 0 250 500 750 1000 ozone (ppb) Figure 4-18: Ozone Concentrations Measured by Ozonesondes Launched from University of Houston Campus, August 19, August 27, and August 29, 2011, Below 20 km Altitude

4 km 19-Aug-11 27-Aug-11 3 29-Aug-11

2

altitude 1

0 0 50 100 150 200 ozone (ppb)

Figure 4-19: Ozone Concentrations Measured by Ozonesondes Launched from University of Houston Campus, August 19, August 27, and August 29, 2011, Below 4 km Altitude

Figures 4-18 and 4-19 show that ozone concentrations at the surface are slightly lower than ozone concentrations only a few hundred meters aloft. Above that, up to about 1 to 1.5 km, ozone concentrations are roughly constant. On August 19, 2011, ozone concentrations began increasing sharply at a point just below 1 km altitude, from about 60 ppb up to 84 ppb at about 1.9 km. On both August 27, 2011 and August 29, 2011, ozone concentrations were nearly constant from ground level up to roughly 1.5 km altitude, at about 90 ppb and 140 ppb, respectively. On August

4-30 27, 2011, ozone concentrations decreased from about 90 ppb with increasing altitude above 1.5 km, falling to around 30 ppb at 3.5 km altitude. On August 29, 2011, ozone concentrations increased up to about 2 km altitude by 10 ppb, varied or fell up to about 2.5 km altitude, then began falling to about 60 ppb by about 3.5 km altitude. On both the later dates, ozone concentrations fell by about 40 ppb on August 27, 2011 and about 90 ppb on August 29, 2011 in atmospheric layers above about 2.5 km altitude. On August 19, 2011, however, a 2 km thick layer of elevated ozone with concentrations reaching up to 84 ppb is evident between 1 and 3 km altitude. In all cases, ozone concentrations above about 3 km altitude were much lower than ozone concentrations between about 1 and 3 km altitude.

These findings suggest that there are layers of air in the upper atmosphere that contain elevated concentrations of ozone, in some cases substantially elevated, compared to ozone measured at the surface. Elevated concentrations of ozone reside in layers just above the surface layer. In two cases, August 19, 2011 and August 29, 2011, other layers at higher altitudes contained parcels with even higher ozone concentrations exceeding 150 ppb on August 29, 2011. These layers of elevated ozone are a possible mechanism by which parcels of air containing elevated ozone, and possibly ozone precursors, are transported from distant sources (EPA, 1998; Brock et al., 2004; Chin et al., 2007; Lin et al., 2012). These parcels were observed above the HGB area one week prior to the August 26, 2011 one-hour ozone exceedance event and one and three days after.

The pattern of elevated ozone aloft corresponding with arrival of synoptic weather systems is observed at every launch location in the state. Currently, ozonesonde launches are conducted periodically from Houston, Beaumont, and Idabell, Oklahoma, at a location just north of the Red River in southeastern Oklahoma. In prior years, launches have been conducted from other locations around the HGB area. Figure 4-20: Average Ozone Concentrations (ppb) in 1 km Layers of the Atmosphere shows average ozone concentrations across all launches at a location in 1 km layers, up to 10 km altitude, measured at various locations. In the majority of cases, it is clear that ozone concentrations aloft are elevated above those at or near ground level. The plots for each location show higher ozone concentrations aloft with noticeable notches where ozone is particularly elevated in certain layers. Whereas ozone concentrations in the lowest layer range from 42 to 65 ppb, on average depending on launch location, from 9 to 10 km altitude ozone concentrations range from 59 to 77 ppb, on average. Ozonesonde analysis supports the finding that ozone concentrations can be much higher at higher altitude than at the surface, that this ozone can be transported in air parcels by synoptic weather systems, and that under the appropriate conditions, such as a subsidence event, this ozone can be brought down to the lower atmosphere to affect ozone concentrations measured by the surface monitoring network.

4-31

Figure 4-20: Average Ozone Concentrations (ppb) in 1 km Layers of the Atmosphere

4.4.5 Uncertainties Although locations of identified fires and HYSPLIT model inputs and outputs are reported to very high precision, there are still a number of uncertainties in the computations and results obtained from the methods presented above. Some of these uncertainties are briefly discussed below. The HYSPLIT model estimates trajectory pathways and reports coordinates of these trajectories at one-hour increments. However, the HYSPLIT model does not report confidence bounds or standard errors on these coordinate estimates. Because HYSPLIT uses the 40 km Eta Data Assimilation System (EDAS) there may be errors in the estimates of the hourly coordinates. Further, these errors could be compounded by the longer the duration of a trajectory.

HYSPLIT documentation available at: http://ready.arl.noaa.gov/edas40.php, notes that to create the input EDAS data set “48 km data are interpolated to a 40 km, Lambert Conformal Grid, covering the continental United States.” This interpolation could introduce a source of uncertainty of unknown magnitude due to averaging and smoothing inherent in an interpolation procedure.

Uncertainties also could arise in conversion among projection systems in geographic information systems used to analyze and interpret model results. Different geographic projections handle different aspects of conversion with greater or less precision, depending on the intended purpose of the system. The HYSPLIT model and the WFABBA fire detection and

4-32 identification system may use different coordinate projection systems when computing and reporting latitudes and longitudes.

Finally, the HYSPLIT model provides estimates of the mixing layer height to an unknown level of accuracy. The true boundary layer could be higher or lower than these estimates, which could affect determinations of whether or not fire emissions were mixed or lofted above the boundary layer and transported.

Even with the uncertainties, the tools and procedures used in this analysis are quite sophisticated and provide substantial evidence suggestive of the impact of fire emissions on ozone concentrations in the HGB area.

4.5 GOES SATELLITE IMAGERY In addition to monitoring data, the TCEQ has made extensive use of satellite imagery in its analysis. The NOAA satellite program includes a number of different satellite platforms. One of the most useful satellite series is the GOES satellite program that provides nearly continuous monitoring and imagery of the western hemisphere. In addition to the many meteorological parameters they measure, GOES satellites also detect several airborne pollutants such as smoke and dust.

In this demonstration, the TCEQ analyzed GOES imagery for August 24, 2011 through August 26, 2011 supplemented by written descriptions of GOES imagery published by NOAA. The narrative and imagery published by NOAA provides independent evidence that smoke from the northwestern and southeastern U.S. was transported to the Texas Gulf Coast. On August 24, 2011, the afternoon narrative issued by NOAA at 18:14 UTC read in part:

“…Montana/Wyoming through Northern/Central Plains to Midwest/Great Lakes region: An expansive area of aerosol composed of a mixture of remnant smoke and elevated dust particles from eastern Montana covered much of the northern U.S. this morning. The mixture stretched from Montana/Wyoming southeastward as far as Oklahoma/northeast Texas/Arkansas and as far east as the western Great Lakes, Ohio, and Kentucky. The remnant smoke that makes up a large part of this aerosol mixture has mostly originated from wildfires burning in the Northwestern U.S.; with fires in Montana, Wyoming, and Idaho contributing the most.

Gulf Coast: Aerosol seen this morning along the Gulf is believed to be a mixture of light smoke, haze, and possibly other unknown aerosols. Fires along the Lower Mississippi River Valley and in the rest of the Southeast U.S., including a large smoke producing fire in southern Georgia, are the likely source points for this light smoke…” (Dept. of Commerce, NOAA, August 24, 2011 18:14 UTC)

Figure 4-21: GOES Imagery on August 24, 2011 (22:08 UTC) shows a GOES image focused on East Texas and the southern U.S. taken later that same afternoon. The image clearly shows (in the circled areas) the smoke from the northwestern and southeastern U.S. described by NOAA.

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Figure 4-21: GOES Imagery on August 24, 2011 (22:08 UTC)

Figure 4-22: GOES Imagery on August 25, 2011 (22:08 UTC) shows more convincing evidence of smoke in Texas. The NOAA narrative for August 25, 2011 at 15:22 UTC paints a similar picture:

“…Montana/Wyoming through Northern/Central Plains to Midwest region: Large area of remnant smoke plume extends from southeastern Saskatchewan southward into southwest Texas and portions of northeastern Mexico. Plume is seen extending as far east to central Kentucky, western Tennessee and northern Mississippi. However since GOES WEST satellite does not allow for viewing any further east and sun angle is not ideal for thin smoke detection using GOES East it is likely that light smoke extends across portions of southeast U.S. but cannot be seen in morning satellite imagery. Source of smoke plume is mostly from several wildfires that have been burning for days across Montana, Idaho, and Wyoming…”

4-34

Figure 4-22: GOES Imagery on August 25, 2011 (22:08 UTC) On August 26, 2011, NOAA issued a narrative at 15:15 UTC and made note of the heightened levels of smoke blanketing Texas and the southern plains:

“… Southcentral U.S.: A ridge of high pressure over NE TX continues to hold smoke from emissions earlier this week from the fires in ID/MT and WY. This smoke is thin with small linear shaped pockets/strands of moderate smoke covering all of KS, OK, TX, LA and NM with portions of smoke affecting SW AR, and SW MS and the coastal Gulf of Mexico from Brownsville, TX over to Mobile, AL. Smoke over SE KS/E OK/SW AR and LA is moving SEward into the Gulf, while influence from the upper level ridge is moving smoke in TX, W OK, W KS due south into Old Mexico and southwestward across NM starting to move into SE AZ…”

Figure 4-23: GOES Imagery on August 26, 2011 (21:08 UTC) shows these heightened smoke levels over Texas and the HGB area.

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Figure 4-23: GOES Imagery on August 26, 2011 (21:08 UTC)

4.6 SATELLITE AEROSOL OPTICAL DEPTH IMAGES WITH HYSPLIT BACKWARD TRAJECTORIES Wildfires produce aerosols, which are solid particles or droplets of liquid suspended in the air. Common aerosols include smoke, dust, and clouds. These aerosols can be detected by satellites and analyzed using satellite imagery. The MODIS (Moderate Resolution Imaging Spectroradiometer) Aqua satellite (modis.gsfc.nasa.gov), launched and monitored by the National Aeronautics and Space Administration (NASA), is equipped with instruments to measure aerosol optical depth (AOD), a measure of visibility within a column of atmosphere based on light extinction. Measures of AOD can be used to track emissions from fires that release aerosols or smoke into the air. Aerosol satellite imagery can be paired with NOAA HYSPLIT model (Draxler and Rolf, 2013) backward trajectories to show that air parcels passed through fire-generated aerosol plumes in transit to a particular area or that aerosol plumes from wildfires moved into an area over time.

The HYSPLIT trajectory model was used to estimate backward trajectories for three days prior to August 26, 2011. Trajectory durations were chosen to correspond to the length of time necessary for the trajectory to reach the Houston East (CAMS 1) monitoring site on August 26, 2011 at 13:00 LST, the hour of the one-hour ozone exceedance. Therefore, for August 23, 2011 a 72-hour trajectory was estimated; for August 24, 2011 a 48-hour trajectory was estimated; and for August 25, 2011 a 24-hour trajectory was estimated. Three termination heights were used for each day: 1 km, 1.5 km, and 2 km. These are shown as red, blue, and green trajectories, respectively, in the following figures. The three trajectories for each day were overlaid on images of AOD obtained from the MODIS Aqua satellite.

On August 23, 2011, two of the 72-hour HYSPLIT backward trajectories originate from Illinois and Indiana, as shown in Figure 4-24: HYSPLIT 72-Hour Backward Trajectories Overlaid on AOD Imagery from MODIS Aqua Satellite, August 23, 2011. One trajectory, the 1.5 km termination height, originated somewhere over the southeast in Alabama or Tennessee. Aerosols are shown on the following maps with red representing the thickest AOD, meaning more aerosols that block light reflectance, and therefore, likely more smoke, while blue represents the thinnest AOD. The red trajectory represents 1 km starting height, blue represents 1.5 km starting

4-36 height, and green represents 2 km starting height. The MODIS instrument detected a large aerosol plume, likely from fires, in the northern plains over South Dakota and parts of Nebraska, Iowa, and Minnesota. While the detected aerosol plume is beyond the trajectory path for August 23, 2011, it is in the proper direction. Based on other trajectories presented in this report that showed prevailing winds from the northwest U.S. passing over the northern plains at very high speeds, it is likely the aerosol smoke from fires in this area could have been transported to the HGB area by August 26, 2011.

2000m

1000m

1500m

Figure 4-24: HYSPLIT 72-Hour Backward Trajectories Overlaid on AOD Imagery from MODIS Aqua Satellite, August 23, 2011

Forty-eight hour HYSPLIT backward trajectories, shown in Figure 4-25: HYSPLIT 48-Hour Backward Trajectories Overlaid on AOD Imagery from MODIS Aqua Satellite, August 24, 2011 originated from the southeastern U. S. over Alabama and Tennessee on August 24, 2011. By this day, the aerosol plume was detected over a wide area of the midwestern U.S. centered over Illinois, Indiana, and Kentucky and including portions of Ohio, Tennessee, West Virginia, Virginia, and Missouri. The 2 km trajectory appears to originate within this plume area suggesting the likelihood of aerosol transport into the HGB area. In the top left of the satellite image, there is another aerosol plume detected over southwest South Dakota and western Nebraska.

4-37 2000m

1500m

1000m

Figure 4-25: HYSPLIT 48-Hour Backward Trajectories Overlaid on AOD Imagery from MODIS Aqua Satellite, August 24, 2011

4-38 The 24-hour HYSPLIT backward trajectories, shown in Figure 4-26: HYSPLIT 24-Hour Backward Trajectories Overlaid on AOD Imagery from MODIS Aqua Satellite, August 25, 2011 originated from the southeastern U. S. over Louisiana, Mississippi, and Alabama. The satellite AOD image shows moderate to high concentrations of aerosols over these states. Each of the three trajectories passes through the aerosol plume indicating that aerosols from fires in the northern plains or Midwest were likely to be transported to the HGB area. The satellite AOD image shows that there may be some aerosols from these northwest wildfires arriving in Houston.

1000m

2000m

1500m

Figure 4-26: HYSPLIT 24-Hour Backward Trajectories Overlaid on AOD Imagery from MODIS Aqua Satellite, August 25, 2011

4-39 Figure 4-27: AOD Imagery from MODIS Aqua Satellite, August 26, 2011 shows MODIS Aqua AOD satellite imagery on August 26, 2011. The thickest concentrations of aerosols were detected east of Houston in Louisiana and over Terrell, Pecos, and Brewster Counties in southwest Texas.

Figure 4-27: AOD Imagery from MODIS Aqua Satellite, August 26, 2011

4-40 NOAA’s Hazard Mapping System (HMS) combines data from nine satellites, computer algorithms, and expert analysis to identify and map locations of fires in North America year- round. Automated fire detection algorithms are applied to satellite measurements to detect surface heat anomalies. Expert evaluations determine whether these anomalies were the result of fires or other sources of heat (e.g., solar reflectance from clouds or sandy soils) and also add known fires not detected by satellites due to interference or gaps in orbital coverage. Figure 4- 28: HMS Smoke and HYSPLIT 72-Hour Back Trajectories from AirNowTech.org on August 26, 2011 shows that the trajectories pass through the modeled smoke agreeing with the MODIS AOD with HYSPLIT trajectory maps. There is heavy smoke modeled on August 26, 2011 agreeing with the AOD MODIS satellite data from August 26, 2011. The red trajectory represents 1 km starting height, blue represents 1.5 km starting height, and green represents 2 km starting height. The red triangles represent a detected fire and the shaded gray areas are smoke modeled by HMS.

Figure 4-28: HMS Smoke and HYSPLIT 72-Hour Back Trajectories from AirNowTech.org on August 26, 2011

Aerosols from wildfires in the northwest were prevalent in the images from MODIS Aqua from August 23, 2011 through August 26, 2011. There is evidence of the aerosols originating in the northwest moving into the HGB area on August 26, 2011. The HYSPLIT backward trajectories pass through areas of high aerosol concentrations on August 25, 2011. The satellite images with AOD from MODIS Aqua support that aerosol concentrations were elevated on August 26, 2011 in the HGB area. There is support from HMS modeled smoke agreeing with AOD MODIS Aqua data exhibiting elevated levels of smoke in the HGB area. This information all supports the

4-41 conclusion that aerosols from wildfires in the northwest U.S. affected the air quality in the HGB area.

4.7 PATHFINDER SATELLITE OBSERVATIONS The NASA maintains a fleet of satellites that use remote sensing technology to measure and report components of the atmosphere for analyses of weather, climate, and air quality. One of the satellites, the Cloud-Aerosol Lidar and Infrared Pathfinder Satellite Observation (CALIPSO) launched in 2006, is a polar-orbiting satellite that circles the globe multiple times each day. CALIPSO carries the Cloud-Aerosol Lidar with Orthogonal Polarization (CALIOP) instrument, which measures reflectance from clouds and aerosols.

Because it is a LIDAR (Light Detection and Ranging) instrument, CALIOP produces high- resolution vertical profiles of aerosols and clouds. That is, components of the atmosphere can be isolated and identified by their altitudes. Most other instruments that measure aerosols can only provide a value for an entire atmospheric column from the surface of the earth to the instrument. Further, advanced algorithms are used to classify these components into various sub-types of aerosols or water vapor, such as dust, smoke, or ice crystals. However, the design of CALIOP limits its field of view, or width of its band of detection, to several km, compared to other satellite-borne instruments that cover very wide swaths, some as wide as several thousand km. Therefore, CALIOP only very rarely takes measurements of any particular part of the globe.

On August 26, 2011, CALIPSO passed along a path just east of Houston, very near to the Houston East (CAMS 1) monitoring site, at around mid-day between 1:41 CST and 1:54 CST. This orbit path is shown in Figure 4-29: Close-up of Partial CALIPSO Orbital Path on August 26, 2011. The satellite passed directly over Galveston and Mont Belvieu at roughly the time of the exceedance event on August 26, 2011. CALIPSO made roughly 14 complete orbits of the earth on that day.

Figure 4-29: Close-up of Partial CALIPSO Orbital Path on August 26, 2011

All of the following CALIPSO/CALIOP images are courtesy of NASA. The Images are provided on the NASA website with accompanying guides to interpretation. Figure 4-30: Attenuated

4-42 Backscatter of Partial CALIPSO Orbital Path on August 26, 2011 plots total attenuated backscatter, which is a measure of reflectance from particles in the atmosphere between the CALIOP instrument and the surface. For ease of use, NASA divides each partial orbital into four zones indicated by different colors on the horizontal axis. The green zone includes the pass over the HGB area. NASA also provides a summary interpretation of this image: “signal strength has been color coded such that blues correspond to molecular scattering and weak aerosol scattering, aerosols generally show up as yellow/red/orange. Stronger cloud signals are plotted in gray scales, while weaker cloud returns are similar in strength to strong aerosol returns and coded in yellows and reds.”

Figure 4-30: Attenuated Backscatter of Partial CALIPSO Orbital Path on August 26, 2011

Figure 4-31: Total Attenuated Backscatter for the Partial CALIPSO Orbital Path on August 26, 2011 plots the vertical profile of the atmosphere for the portion of the orbit path indicated in green in Figure 4-35. Note this is a vertical profile so the vertical axis is altitude. Markers have been added to the horizontal axis to denote locations of features such as state boundaries to aid in locating areas of interest. All markers are approximate. The location of the Houston East (CAMS 1) monitoring site is highlighted in red. The yellow, red, and orange pixels over Texas and the Houston East (CAMS 1) monitoring site between the surface and about 4 km altitude indicate the presence of aerosols. North of Houston, CALIOP detected clouds (grey), as well as aerosols, at about 2 to 4 km altitude.

4-43

Figure 4-31: Total Attenuated Backscatter for the Partial CALIPSO Orbital Path on August 26, 2011

4-44 Figure 4-32: Detail of Total Attenuated Backscatter for the Partial CALIPSO Orbital Path on August 26, 2011 shows detail of the previous figure to highlight the plume of aerosols stretching from the coast of the Gulf of Mexico at about 29.3o north latitude all the way to the Texas- Oklahoma border at about 33.14o north latitude along the satellite orbital path. Aerosols are noted in yellow, orange, and red from about 2 to 4 km altitude.

Figure 4-32: Detail of Total Attenuated Backscatter for the Partial CALIPSO Orbital Path on August 26, 2011

4-45 Using principles of light scattering and complex algorithms, NASA bins raw backscatter measurements into feature groupings such as clouds, aerosols, clear air, or unknown. These are shown in Figure 4-33: Vertical Feature Mask for the Partial CALIPSO Orbital Path on August 26, 2011. For example, orange areas in the figure indicate areas with backscatter that indicate aerosols, while light blue indicates clouds. Black areas in the figure indicate areas where there was insufficient backscatter for the instrument to “see” what was in the atmosphere. Usually, this occurs where cloud cover is too thick for light to penetrate.

Figure 4-33: Vertical Feature Mask for the Partial CALIPSO Orbital Path on August 26, 2011

The Houston East (CAMS 1) monitoring site is indicated with a red vertical line. Figure 4-33 shows there was a large area north and south of the monitor that was impacted by aerosols on August 26, 2011. North of the Houston East (CAMS 1) monitoring site (to the right of the red vertical line) the aerosol plume extended from the ground up to about 4 km altitude and extended north well past the northern border of Texas. For reference, although CALIPSO did not pass over the panhandle of Texas on this orbit, the very northern border of the state in the panhandle is 36.5o north latitude.

4-46 The vertical feature mask and information on polarization of the particles also measured by CALIOP can be used to determine more precisely particle shape and therefore type of aerosol (e.g., smoke, dust). Figure 4-34: CALIPSO Aerosol Subtype Plot for the Partial CALIPSO Orbital Path on August 26, 2011 displays the results of the subtyping of detected aerosols. Note that the Houston East (CAMS 1) monitoring site lies at latitude 29.76o north. Just to the south of that location on the horizontal axis, there is a large parcel of “clean marine” air (indicated in blue) and likely from the Gulf of Mexico extending from the surface to about 3 km altitude. Adjacent to that to the north is a large parcel of “smoke” (indicated in black) which also extends from the surface to about 3 km altitude. This large parcel of smoke extends from roughly the Gulf of Mexico coast near Houston to about 31.5o north latitude, which is well north of Houston somewhere near the Davy Crockett National Forest in Trinity and Houston Counties. This large smoke plume covered the region at almost the exact same time, between 19:41 UTC and 19:54 UTC, as the one-hour ozone exceedance at the Houston East (CAMS 1) monitoring site. These times correspond to 2:41 p.m. to 2:54 p.m. local daylight time (LDT). Recall that the one-hour ozone exceedance occurred at 1:00 p.m. LDT, which when converted to local daylight time (“spring forward”) is 2:00 p.m. LDT.

Figure 4-34: CALIPSO Aerosol Subtype Plot for the Partial CALIPSO Orbital Path on August 26, 2011

4-47 The CALIOP instrument detects backscatter from aerosol particles in two wavelengths: 532 nanometers (nm) and 1,032 nm. Because large and small particles have different light extinction properties, the ratio of backscatter from the two wavelengths can be used to determine whether detected aerosols are likely from biomass burning. A smaller ratio indicates the particles are likely larger, whereas a larger ratio indicates they are smaller, which suggests biomass burning. Figure 4-35: Attenuated Color Ratio from Two Wavelengths Detected by the CALIOP Instrument on August 26, 2011 shows the ratio of the two wavelengths for the orbital path over the HGB area on August 26, 2011. The patch of light blue and bluish-green near the Houston East (CAMS 1) monitoring site, at about 3 km altitude, corresponds to small particles and suggests the aerosols detected by CALIOP were from biomass burning. The next figure, Figure 4-36: Detail of Attenuated Color Ratio from Two Wavelengths Detected by the CALIOP Instrument on August 26, 2011 provides a more detailed view of the color ratio.

Figure 4-35: Attenuated Color Ratio from Two Wavelengths Detected by the CALIOP Instrument on August 26, 2011

Figure 4-36: Detail of Attenuated Color Ratio from Two Wavelengths Detected by the CALIOP Instrument on August 26, 2011

4-48

4.8 MONITOR VALUES IN LOUISIANA DISPLAY WESTERLY TREND

The TCEQ also analyzed ozone and PM2.5 monitor values from Louisiana. The TCEQ plotted geographic representations of daily maximum PM2.5 and ozone concentrations at monitors throughout Louisiana on August 24 through August 26, 2011. Figure 4 37: Monitored Daily Maximum Hourly PM2.5 Concentrations in Louisiana August 24 through 26, 2011 and Figure 4 38: Monitored Hourly Ozone Daily Maximums in Louisiana August 24 through 26, 2011 show daily maximum concentrations of PM2.5 and ozone throughout Louisiana. From August 24, 2011 to August 26, 2011, the highest values statewide clearly move from east to west. This movement is consistent with the movement of wildfire emissions plumes moving across Louisiana into southeast Texas on a path that carries those emissions into the HGB area. The charts provide evidence of a causal relationship between wildfire emissions and an ozone exceedance at the Houston East (CAMS 1) monitoring site on August 26, 2011.

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Figure 4-37: Monitored Daily Maximum Hourly PM2.5 Concentrations in Louisiana August 24 through 26, 2011

4-50

Figure 4-38: Monitored Hourly Ozone Daily Maximums in Louisiana August 24 through 26, 2011

4-51 CHAPTER 5: NO EXCEEDANCE BUT FOR THE EXCEPTIONAL EVENT

5.1 HOUSTON AREA BACKGROUND OZONE LEVELS To evaluate the likelihood of the Houston East (CAMS 1) site having experienced an exceptional event, the TCEQ estimated regional background ozone for the Houston-Galveson-Brazoria (HGB) area on August 26, 2011. This regional background is essentially the ozone "concentration that would be present if no O3 were produced from NOX and VOC precursors emitted locally, or emitted on preceding days and recirculated locally by mesoscale circulations such as the land-sea breeze." (Berlin et. al., 2013) Because high levels of transported ozone (created by wildfire emissions) caused the August 26, 2011 exceptional event, estimation of the regional background ozone is critical to the success of this demonstration.

The TCEQ method for estimating regional background ozone here is very similar to the method recently published in Environmental Science and Technology (Berlin et. al., 2013) and used successfully in several previous exceptional event demonstrations related to fine Particulate Matter (PM2.5). Briefly, the TCEQ selects a set of regulatory and non-regulatory ozone monitoring sites based on their location near the periphery of the HGB area and the reasonable expectation that they will receive regional background ozone when upwind of the urban core (Berlin et. al., 2013). The sites used in this demonstration are a subset of those used by Berlin (et. al.) and are listed in Table 5-1: HBG Background Ozone Monitoring Sites. The regional background ozone concentration for each day was estimated by the smallest one-hour ozone maximum measured in this set of monitoring sites. Using this method, regional background for the HGB area on August 26, 2011 was estimated to be 70 ppb (occurring at Seabrook Friendship Park (CAMS 45). For this demonstration, the TCEQ used monitoring data from January 1, 2008, through December 31, 2013 to estimate regional ozone background for six full years. The TCEQ also used the same data for August 1 through August 31 for the years 2008-2013 to analyze estimated regional background ozone on a seasonal basis.

5-1 Table 5-1: HBG Background Ozone Monitoring Sites Site Name Latitude ⁰North / Longitude ⁰West Dates

CAMS 26 Northwest Harris County 30.039 / 95.674 2008-2013

CAMS 45 Seabrook Friendship Park 29.583 / 95.015 2008-2013

CAMS 78 Conroe Relocated 30.350 / 95.425 2008-2013

CAMS 84 Manvel Croix Park 29.520 / 95.393 2008-2013

CAMS 410 Houston Westhollow 29.723 / 95.636 2008-2013

CAMS 553 Crosby Library 29.921 / 95.068 2008-2013

CAMS 554 West Houston 29.833 / 95.657 2008-201

CAMS 555 Kingwood Library 30.055 / 95.185 2008-2010

CAMS 556 La Porte Sylvan Beach 29.655 / 95.010 2008-2013

CAMS 557 Mercer Arboretum 30.038 / 95.381 2008-2013

CAMS 558 Tom Bass 29.589 / 95.354 2008-2013

CAMS 559 Katy Park 29.811 / 95.806 2008-2013

CAMS 560 Atascocita 29.962 / 95.235 2008-2013

CAMS 561 Meyer Park 30.012 / 95.522 2008-2013

CAMS 617 Wallisville Road 29.821 / 94.990 2008-2013

CAMS 618 Danciger 29.149 / 95.765 2008-2013

CAMS 619 Mustang Bayou 29.314 / 95.201 2008-2013

CAMS 1016 Lake Jackson 29.044 / 95.473 2008-2013 CAMS 1034 Galveston 99th St. 29.254 / 94.861 2008-2013

Figure 5-1: HGB Regional Background August 1-31, 2008-2013, shows one version of the seasonal analysis. The regional background ozone time series for August of each year is plotted separately. Regional background ozone on August 26, 2011 is 70 ppb and the next highest measurement for August 26 is 57 ppb, which occurs in 2010. It is immediately clear that the ozone regional background ozone on August 26-31, 2011 is significantly higher than the same days in other years. In fact, this period is significantly higher than almost any other period of August 2008-2013.

5-2 The analysis shown in Figure 5-2: Distribution of Annual and Seasonal Regional Background Estimates, is even more significant. The TCEQ uses a chart known as a Box and Whiskers plot to show the statistical distribution of estimated regional background ozone values on both an annual and seasonal basis over the period of 2008 through 2013. On an annual basis, there are 2,192 observations and the estimated background for August 26, 2011 lies above the 99th percentile (99.3%). On a seasonal basis, there are only 186 observations but the estimated regional background still manages to rank just below the 99th percentile (98.9%). Just like the daily maximum of 128 ppb at the Houston East (CAMS 1) site, regional background ozone for the HGB area of 70 ppb on August 26, 2011 lies substantially outside of normal historical fluctuations for regional background ozone. Clearly, without this unusually high regional background ozone, there would not have been an exceedance at the Houston East (CAMS 1) site.

Figure 5-1: HGB Regional Background August 1-31, 2008-2013

5-3 80

(99.3%) (98.9%) 70 August 26, 2011 70 70

60 95th %

50

75th %

40 Mean Median

30

25th % Estimated Ozone Regional Background (ppb)

20 5th %

10

0 Annual 2008-2013 (n = 2,192) August 2008-2013 (n = 186) Annual and August Background Distributions

Figure 5-2: Distribution of Annual and Seasonal Regional Background Estimates

5.2 ANALYSIS OF A SURROGATE DAY 5.2.1 Introduction The Texas Commission on Environmental Quality (TCEQ) chose to develop an analysis of a surrogate day comparing a high ozone day as similar to August 26, 2011 as possible that does not contain smoke from significant numbers of wildfires. To select this day the TCEQ relied on comparisons of large-scale wind patterns, visual inspections and quantitative comparisons of local-scale complex wind patterns (acute flow reversal days), and quantitative comparisons of important meteorological metrics. This section documents the steps taken to identify a suitable surrogate day for August 26, 2011.

Selection of potential surrogate days first used the Hybrid Single Particle Lagrangian Integrated Trajectory (HYSPLIT) model (Draxler and Rolph, 2013) to identify days with similar large-scale wind patterns similar to August 26, 2011 that could have transported wildfire emissions to the Houston East (CAMS 1) monitoring site. The TCEQ then used surface level backward trajectories to match the small-scale wind currents at the Houston East (CAMS 1) monitor. Lastly, the TCEQ compared other important meteorological parameters.

The TCEQ initially started with 124 candidate surrogate days from the years 2009 through 2011. Five-day (120-hour) back trajectories were computed for each candidate day. The TCEQ also generated 120-hour back trajectories for August 15 through September 15, of the years 2009 through 2011 to capture large-scale meteorological patterns. To capture larger scale meteorological conditions, the TCEQ analyzed back trajectories ending at the Houston East (CAMS 1) monitoring site well up in the mixing layer (800 meters above ground) above ground. These back trajectories terminated at the receptor site, the Houston East (CAMS 1) monitoring

5-4 site, at 13:00 Local Standard Time (LST). Eighty-four trajectories out of a possible 93 back trajectories were computed. The remaining days could not be computed due to missing data or a lack of complete 120 hour trajectory output.

The remaining 84 back trajectories were analyzed with the HYSPLIT model’s clustering tool. The clustering tool identified seven clusters of days with similar wind patterns for the August 15 to September 15 time period. Upon visual inspection, three of seven clusters were determined to be sufficiently similar to August 26, 2011. These clusters are displayed in Figure 5-1: Selected HYSPLIT Clusters (3, 4, and 5) Containing Candidate Surrogate Days. Cluster 4, in the middle panel, contains August 26, 2011, but Clusters 3 and 5 are sufficiently similar to August 26, 2011 to be considered for further analysis.

Of the 124 days identified as potential surrogate days, application of the HYSPLIT clustering tool and visual inspection yielded 29 candidate surrogate days for further analysis. Surface back trajectories using TCEQ surface level ambient monitoring were analyzed for these 29 days to determine which displayed sufficiently similar local-scale wind patterns to August 26, 2011.

Figure 5-3: Selected HYSPLIT Clusters (3, 4, and 5) Containing Candidate Surrogate Days 5.2.1 Surface Trajectories For each of the 29 candidate surrogate days selected in Section 5.1.1, a single surface back trajectory model was run. Each back trajectory ended (or terminated) at the Houston East (CAMS 1) monitoring site at the end of the hour in which the daily one-hour maximum ozone value was measured. These trajectories were then compared to the trajectory computed for August 26, 2011, to identify those most similar. Each surface level back trajectory uses the wind direction and wind speed data available from all TCEQ monitoring sites in the Houston Galveston Brazoria (HGB) area. The backward trajectory heights originate at 10 meters height, the height of the wind monitoring sensor and travels six hours back in time. The surface trajectory model uses a distance-weighted Shepard's modified algorithm, or “Shepard’s method” (Shepard, 1968), to compute trajectories. The model has no vertical motion so back trajectories are only tracked in two dimensions at a height of the wind monitoring sensor, 10 meters.

The TCEQ determined that five days had sufficiently similar large and local-scale wind patterns to August 26, 2011 to consider as final candidates for a surrogate day. Figure 5-2: Surface Backward Trajectories for Candidate Surrogate Days plots each of the computed surface trajectories for August 26, 2011 and the final candidate days. Inspection of back trajectories suggests that regional and local wind patterns on August 27, 2009 were most similar to August 26, 2011. August 27, 2009 has the feature that the surface level trajectory wind arrives from

5-5 northwest of the Houston East (CAMS 1) monitoring site and it contains a clear flow-reversal pattern or a pattern where the wind changes directions dramatically. In addition, the time of peak ozone differs by only two hours from August 26, 2011 15:00 LST versus 13:00 LST.

A second potential candidate is September 15, 2011. This day’s flow reversal is sharp and occurs on a Northwest to Southeast access like August 27, 2009 or August 26, 2011. However, it starts from the Northeast as opposed to the Northwest. Flow reversal on September 15, 2011 is very similar to August 27, 2009 in shape and wind speed, and its overall wind speed would appear to be lower than either August 27, 2009 or August 26, 2011. This difference in wind speeds could increase this day’s potential for ozone production. In addition, the peak one-hour ozone measurement on September 15, 2011 occurred at 12: LST, a difference of only one hour from August 26, 2011.

Another potential surrogate day is September 3, 2009, which has a very acute flow reversal. September 3, 2009 exhibits similar wind speeds at peak ozone time but behaves differently before and after peak ozone hours. This trajectory meanders in a very small area for all of the six hours of the trajectory, unlike the August 26, 2011 trajectory. August 29, 2009 exhibits flow reversal, but the reversal is not as sharp as the flow-reversal as August 26, 2011.

The surface level back trajectory for August 17, 2010 exhibits a sharp flow reversal along an axis from Northeast to Southwest, which is very different from the Northwest to Southeast flow reversal axis observed on August 26, 2011. Wind speeds on August 17, 2010 were also faster overall than wind speeds on August 26, 2011. The difference in wind speed is a critical factor in distinguishing August 17, 2010 and August 26, 2011 because wind speed is critical in the

5-6 formation of ozone.

Figure 5-4: Surface Backward Trajectories for Candidate Surrogate Days 5.2.2 Surrogate Days As discussed above, five days were determined to be suitable as final candidates for surrogate comparison based on HYSPLIT trajectory clustering local-scale back trajectory comparison. Selection of a final surrogate day from these five candidate days entails further comparison of ozone concentrations and measures of sinuosity of measured wind speeds and directions. Table 5-1: Maximum One-Hour Ozone on Final Candidate Surrogate Days lists maximum ozone concentrations for each day and the hour when that maximum ozone was observed. The highest one-hour ozone concentration observed on any candidate day was 113 ppb on September 3,

5-7 2009 at 12:00 LST, which is below the one-hour ozone standard, as were all final candidate surrogate days. Two other candidate days measured one-hour ozone below 75 ppb: August 29, 2009 at 69 ppb and August 17, 2010 at 73 ppb.

Table 5-2: Maximum One-Hour Ozone on Final Candidate Surrogate Days Maximum Ozone Hour of Maximum Date Concentration (ppb) Concentration (CST)

Exceptional Event Day

August 26, 2011 128 13:00

Final Candidate Surrogate Days

August 27, 2009 111 15:00

August 29, 2009 69 19:00

September 3, 2009 113 12:00

August 17, 2010 73 16:00

September 15, 2011 107 12:00

5.2.3 Sinuosity A quantitative comparison of wind speeds from the candidate surrogate days can be performed using a measure that compares the net distance traveled by back trajectories versus the total distance traveled over their entire paths. This measure, known as sinuosity, is derived from the name of the sine curve in mathematics. Sinuosity is defined as the ratio of the distance from the start point of a trajectory to the ending point of the trajectory to the sum of all distances from one time step to the next from beginning to end of the trajectory. A trajectory traveling straight in one direction will have a ratio close to one. A trajectory that reverses flow will have a ratio closer to zero. Comparison of the lengths of trajectories can reveal the extent to which winds were straight or variable over the path of a trajectory. Straight winds are associated with lower ozone concentrations, while variable winds tend to be associated with higher ozone concentrations. Table 5-2: Sinuosity Results for Final Candidate Surrogate Days reports results of the sinuosity analysis. These results suggest that August 27, 2009 is most similar to the target day in terms of sinuosity than other days. The day with the greatest difference is September 3, 2009, which is evident from its circular trajectory.

5-8

Table 5-3: Sinuosity Results for Final Candidate Surrogate Days Difference Between Date Sinuosity August 26, 2011 and Candidate Day Exceptional Event Day August 26, 2011 0.56 ---- Final Candidate Surrogate Days August 27, 2009 0.42 0.14 August 29, 2009 0.81 -0.25 September 3, 2009 0.12 0.44 August 17, 2010 0.23 0.33 September 15, 2011 0.82 -0.26

5.3 METEOROLOGICAL SIMILARITIES OF THE EXCEPTIONAL EVENT DAY AND SURROGATE DAY August 26, 2011 and August 27, 2009 are not just similar in terms of wind flow patterns. The TCEQ also compared the two days on a number of other meteorological factors as well. Table 5-4: Meteorological Conditions on Event and Surrogate Days is a synopsis of general meteorological conditions on these two days and emphasizes the similarities between the exceptional event day and the surrogate day. Because the Houston East (CAMS 1) site has limited meteorological instrumentation, some measurements were taken at the Clinton (CAMS 403) monitoring site. Parameters measured at the Clinton (CAMS 403) location are noted in the table. Of all the parameters, the most outstanding difference is the daily one-hour maximum ozone measurement. All other parameters are similar, suggesting that the weather on both days is similar. The primary difference between the ozone formation potential on both days is the presence of a significant smoke plume on August 26, 2011.

5-9

Table 5-4: Meteorological Conditions on Event and Surrogate Days Exceptional Event Day Surrogate Day Parameter (August 26, 2011) (August 27, 2009)

Maximum 1-hour Ozone 128 ppb 111 ppb

Average Wind Speed† 3.08 mi/hr 2.04 mi/hr

Wind Direction prior to Northwest Northwest Flow Reversal

Average Temperature† 85.96°F 85.40°F

Average Atmospheric 1014.28 millibars 1015.62 millibars Pressure†‡

Average Solar Radiation†‡ 0.68 Langley/min 0.48 Langley/min

Average Relative Humidity†‡ 54.14% 59.84%

Total Precipitation† 0 in 0 in

Flow Reversal Present and acute Present and acute

Surface Pattern High pressure over Texas High pressure over Texas

Cloud Cover Clear Skies Partly Cloudy

†6:00 AM to 2:00 PM (LST)

‡Measurement taken at Clinton (CAMS 403) monitoring site

A comparison of national scale weather maps from the National Oceanic and Atmospheric Administration (NOAA) further shows the similarities between August 26, 2011 and August 27, 2009. To illustrate meteorological similarities, meteorological surface maps from the National Oceanic and Atmospheric Administration (NOAA) are compared. The maps, shown in Figure 5-5: NOAA Surface Level Weather Maps on August 26, 2011 and August 27, 2009, show large- scale synoptic meteorological conditions on August 26, 2011 and August 27, 2009. These maps are rich in meteorological information for larger scale meteorological events. This information includes features such as frontal boundaries, tropical cyclones, temperatures, wind directions, and surface pressures.

On August 26, 2011, a stationary front stretched from northeast Texas through central Mississippi and Alabama. A surface high pressure system was centered off the coast of southeast Texas. Skies over southeast Texas were clear with temperatures in the mid 90 degree Fahrenheit range. The clear skies extended over much of the southeast United States (U.S.). Winds over southeast Texas and the Houston area were light. Hurricane Irene was centered off the coast of

5-10 South Carolina causing winds over the southeast U.S. to flow cyclonically around the center. This resulted in winds generally out of the north over Arkansas and Mississippi.

Similarly, the surrogate day August 27, 2009, observed similar meteorological conditions as mentioned above. A weak front stretched from West Texas through Oklahoma. A surface high pressure system was also centered over southeast Texas. Skies were partly cloudy on this day with cloudier conditions extending further over the southeastern U.S. Temperatures were in the low 90 degree Fahrenheit range. Tropical Storm Danny was centered in the Atlantic off the coast of the southeastern U.S. Winds over southeast Texas and throughout Louisiana and Mississippi were generally light.

Both days were remarkably similar, right down to the tropical storm and hurricane off of the southeastern US Coast. They both observed high pressure in the Houston area, weak frontal boundaries, and generally sunny, clear, warm days with light winds.

Figure 5-5: NOAA Surface Level Weather Maps on August 26, 2011 and August 27, 2009

5-11

5.4 SIMILARITIES OF HRVOCS ON THE EXCEPTIONAL EVENT AND SURROGATE DAYS In order to establish the similarity of local Volatile Organic Compound (VOC) emissions on August 26, 2011 and August 27, 2009, the TCEQ reviewed two sources of data. The first data source was the commission’s Air Emission Event Report Database. This database contains reports of emissions events or upsets that can result in unexpected emissions of VOCs. The TCEQ found fewer reported air emission events on August 26, 2011 than on August 27, 2009.

The TCEQ also compared diurnal profiles of highly reactive volatile organic compounds (HRVOC) at two automated gas chromatograph (AutoGC) instruments near to the Houston East (CAMS 1) monitoring site. Those AutoGC sites are listed in Table 5-5: Neighboring AutoGC Monitoring Sites. These sites measure the concentration of more than 40 volatile organic compounds (VOC) on an hourly basis. The TCEQ chose to analyze the HRVOC species because they are commonly found in the Houston Ship Channel area and often associated with high ozone measurements. Both AutoGC sites are close to the Houston East (CAMS 1) monitoring site and are best positioned to measure the same air measured at Houston East (CAMS 1) on typical flow reversal days.

Table 5-5: Neighboring AutoGC Monitoring Sites Distance from Houston Relative Direction from AutoGC Site East (CAMS 1) (miles) Houston East (CAMS 1)

Clinton (CAMS 403) 3.25 Southwest

Houston Regional 2.57 East Monitoring (HRM) Site #3

To compare HRVOC measurements on August 26, 2011 and August 27, 2009, the TCEQ plotted hourly HRVOC measurements made on each day in the context of each hour’s statistical distribution for the month of August from 2008 through 2013. The distribution of measurements for each hour appears as the now familiar box-whisker plot showing the 5th, 25th, 50th, 75th, and 95th percentiles as well as the mean value. Hourly measurements for the Exceptional Event and Surrogate days were then plotted over the box-whisker series and compared. The results for the Clinton (CAMS 403) site are shown in Figure 5-6: Hourly HRVOC Measurements at Clinton on Event and Surrogate Days and the results for the HRM Site #3 are shown in Figure 5-7: Hourly HRVOC Measurements at HRM3 on Event and Surrogate Days.This approach provides a good picture of how HRVOC measurements on both days compare to typical HRVOC values.of the normal range of both HRVOCs and the ability to compare the diurnal profiles of both days against one another and the historical distribution of HRVOC measurement for that time of year. These figures both show that there were a very small number of hourly measurements that could be considered outside of the normal historical fluctuation of August HRVOC measurements at the Clinton (CAMS 403) or HRM Site #3 locations. Any measurements that could be considered as outside of normal historical fluctuations occurred after the daily one hour maximum had occurred at the Houston East (CAMS 1) site on either day. Because HRVOC levels surrounding the Houston East (CAMS 1) location on the exceptional event and surrogate days were not outside of normal historical fluctuations it would seem that local VOC emissions did not play a dominant role in one-hour

5-12 ozone maximums on these two days. Also, it appears reasonable to conclude that local HRVOC emissions on the Exceptional and Surrogate days were largely comparable.

Hourly HRVOC Measurements at Clinton on Event and Surrogate Days

Event Day (8/26/2011) Surrogate Day (8/27/2009)

70

60

50

40

30 HRVOC HRVOC Concentration(ppbC)

20

10

0 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00 Time of Day (LST)

Figure 5-6: Hourly HRVOC Measurements at Clinton on Event and Surrogate Days

Hourly HRVOC Measurements at HRM3 on Event and Surrogate Days

Event Day (8/26/2011) Surrogate Day (8/27/2009)

70

60

50

40

30 HRVOC HRVOC Concentration(ppbC)

20

10

0 0:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 19:00 20:00 21:00 22:00 23:00 Time of Day (LST)

Figure 5-7: Hourly HRVOC Measurements at HRM3 on Event and Surrogate Days

5-13 The TCEQ also compared HRVOC measurements for the exceptional event and surrogate days on a statistical basis. In this analysis, the TCEQ treated hourly measurements of HRVOCs on each day as a separate sample and compared the mean or central tendency of the exceptional event day to the mean or central tendency of the surrogate day. In order to be as thorough as possible, the TCEQ treated the two samples as both independent (unpaired) and related (paired). The TCEQ also used both parametric and nonparametric statistical tests. For the nonparametric case, the TCEQ chose the Mann-Whitney U Test (unpaired) and the Wilcoxon signed-rank test (paired). For the parametric, or normally distributed, case, the TCEQ chose the unpaired Student’s t-test for independent samples and the paired Student’s t-test. The two hypotheses used were as follows:

H0:

Ha:

The results of this analysis appear in Table 5-6: Comparison of Means Hypothesis Testing Results. In all cases, the probability, p, is high enough that the TCEQ cannot reject the null hypothesis that the central tendencies of HRVOC samples for the Event and Surrogate days are from the same population. In other words, the TCEQ cannot reject the possibility that the Event and Surrogate days are essentially similar or comparable in terms of their HRVOC measurements at the Clinton (CAMS 403) and HRM Site #3 locations.

Table 5-6: Comparison of Means Hypothesis Testing Results Clinton (CAMS 403)

Independent (unpaired) Related (paired)

( ) ( )

Nonparametric

Parametric

HRM Site #3

Independent (unpaired) Related (paired)

( ) ( )

Nonparametric

Parametric

5.5 CONCLUSIONS Through an analysis of background ozone levels in the HGB area the TCEQ showed evidence that background levels of ozone transported into the HGB on August 26, 2011 were well outside

5-14 the normal historical fluctuation for background ozone over the years 2008 through 2013. The estimated background ozone level for August 26, 2011, 70 ppb, was at least was well above it’s the next highest day and was above the 99th percentile for all of the years 2008 through 2013.

Candidate surrogate days were identified using HYSPLIT clustering of backward trajectories for all days between August 15 and September 15, 2009 through 2011. Comparison of local scale wind patterns and back trajectories to the exceptional event day, August 26, 2011, led to the identification of five candidate surrogate days with similar wind patterns. The computed “sinuosity” ratios of these five days were then compared to identify which were most similar to the smoke-affected day in terms of “straightness.” The candidate surrogate day found to be most similar to August 26, 2011 was August 27, 2009. August 27, 2009, the surrogate day, had a similar back trajectory, flow reversal, and sinuosity value. The surrogate day also observed similar non-wind meteorological conditions, such as relative humidity, precipitation, and other conditions to August 26, 2011. Furthermore, regionally meteorological conditions for August 26, 2011 and August 27, 2009 were similar. Both days observed high pressure in the HGB area, weak frontal boundaries, and generally sunny, clear, warm days with light winds. Finally, HRVOC levels at neighboring AutoGC monitoring sites for both August 26, 2011 and August 27, 2009 were within normal historical fluctuations and could not be distinguished from one another on a statistical basis.

Given the meteorological and photochemical similarities between August 26, 2011 and August 27, 2009, the primary difference between the two days are the widespread occurrences of high ozone measurements in the HGB area on August 26, 2011 and the presence of substantial smoke and wildfire-generated emissions on the same day. The surrogate day had a peak ozone one- hour value of 111 ppb while August 26, 2011 measured a maximum one-hour ozone value of 128 ppb. Fire emissions from outside Texas must be considered as an important cause of the one- hour ozone exceedance that occurred on August 26, 2011.

5-15 CHAPTER 6: DOCUMENTATION OF THE PUBLIC COMMENT PROCESS

In following the requirements listed in Title 40 of the Code of Federal Regulations (CFR) §50.14(c)(3)(i), Treatment of air quality monitoring data influenced by exceptional events, the Texas Commission on Environmental Quality (TCEQ) posted this Exceptional Events Demonstration Package on the Agency website for public comment from August 7 through September 7, 2014. In accordance with 40 CFR §50.14(c)(3)(v), the TCEQ is documenting the public comments received in this section. All comments received during the comment period will be included in Appendix B: Public Comments.

6-1 CHAPTER 7: CONCLUSIONS

On August 26, 2011, the Houston-Galveston-Brazoria (HGB) area experienced an exceptional event that affected air quality throughout the area but most especially at the Houston East (CAMS 1) monitoring site. On that day, 18 of 19 monitors reporting data in the HGB area reported maximum one-hour daily maximum ozone values greater than the 95th percentile for 2009 through 2011. During the early afternoon hours of August 26, 2011, the Houston East (CAMS 1) ozone monitor measured an exceedance of the one-hour ozone National Ambient Air Quality Standard (NAAQS). In the days leading up to August 26, 2011, there were several large areas in the northwestern and southern United States (U.S.) experiencing wildfires. Unfortunately, these wildfire areas lay underneath the path of air parcels on their way to the HGB area. Smoke, nitrogen oxides (NOX), and other pollutants from these fires mixed with the air overhead and were transported into the HGB area just in time to form significant plume of ozone. Without this wildfire-created ozone, there would have been no exceedance at the Houston East (CAMS 1) monitoring site that day.

The Texas Commission on Environmental Quality (TCEQ) has entered a preliminary/informational “flag” into the Air Quality System (AQS) monitoring data records for that day. Through the accumulated weight of evidence gathered in this document, the TCEQ has demonstrated satisfactorily that it has met the requirements set down in the federal clean air act and the Exceptional Event Rule (EER) and that the exclusion of monitoring data from this day at the Houston East (CAMS 1) monitoring site is warranted. The TCEQ now asks the U.S. Environmental Protection Agency (EPA) to concur with the TCEQ and enter an exceptional events “flag” into the appropriate AQS data records. The TCEQ also requests that after this flag is entered that the data from the Houston East (CAMS 1) monitoring site for August 26, 2011 not be used in regulatory activities associated with classification of metropolitan areas with respect to ozone.

The TCEQ has met the requirements set forth in the EER in the following manner:

1. The exceptional event affects air quality.

The Houston East (CAMS 1) monitoring site observed a daily maximum one-hour ozone concentration of 128 parts per billion (ppb) during the 1:00 p.m. to 2:00 p.m. LDT monitoring hour. The TCEQ has met the rule requirement by showing that fire-related emissions from outside the state caused high levels of ozone and ozone precursors to be transported into the HGB area and cause an exceedance of the one-hour ozone NAAQS. More specifically, the TCEQ has demonstrated the causal relationship between fire-related emissions and high ozone levels in the HGB area both theoretically and empirically, including August 26, 2011 (Chapter 4: A Clear Causal Relationship Between Fire Emissions and Higher Ozone). Further, the TCEQ has shown through analysis of a surrogate day similar to August 26, 2011, that a one-hour ozone NAAQS exceedance would not have occurred without the fire-related emissions.

2. The event is not reasonably controllable or preventable.

The fires causing the high levels of ozone and ozone precursors in the HGB area occurred outside the State of Texas in the Lower Mississippi River Valley. Consequently, Texas had no opportunity to prevent or control for those emissions.

7-1 3. The event is either caused by human activity that is unlikely to recur at a particular location or a natural event.

The large majority of wildfires burning around the U.S. on the days leading up to August 26, 2011 were believed to be natural in origin. Some, however, may have been caused by human activity. Wildfires, by their very nature, limit the probability of those events recurring at the same location in the near future. Even if the fires started again at the same locations, those locations are outside of Texas and beyond the authority of the State of Texas to control or prevent.

4. There is a clear causal relationship between the measurement under consideration and the event.

In Chapter 4: A Clear Causal Relationship Between Fire Emissions and Higher Ozone, the TCEQ provides strong evidence supporting the relationship between wildfires and enhanced levels of ozone – even after long transport distances. The literature review also cites three clear cases of previous ozone enhancement caused by fire-related emissions that transported into the HGB area. At least one of these events involved transport over even longer distances than are considered in this exceptional event. An exhaustive analysis of HYSPLIT trajectories demonstrated that the causal was clearly more than a plausible consideration. These analyses show that trajectories to the Houston East (CAMS 1) monitoring site passed over large wildfire areas while the fires were in progress and that emissions very likely entrained in those air parcels and transported to the HGB area. These analyses also show that air parcels from higher in the atmosphere subsided quickly when arriving in the HGB area bringing emissions and higher ozone levels from higher up in the atmosphere. The finding of Section 3.6: Southeast Texas Monitoring Sites, where 18 of 19 monitors in the HGB area measured daily one-hour maximum values greater than the 95th percentile on August 26, 2011 also points to the causal relationship between smoke, wildfire-related emissions and ozone in the HGB area. Finally, satellite imagery and computer modeling images provide strong support for the causal relationship that affected air quality on August 26, 2011. Cloud-Aerosol Lidar and Infrared Pathfinder Satellite Observation (CALIPSO) measurements clearly indicate that between the surface and about 4 km altitude a broad smoke plume was transported into the HGB area on August 26, 2011. Geostationary Operational Environmental Satellites (GOES) satellite imagery as well as National Oceanic and Atmospheric Administration interpretations document the smoke plumes in southeast Texas as well. The total weight of this evidence makes a strong case concluding that fire-related emissions caused the exceedance at the Houston East (CAMS 1) monitoring site.

5. The event is related to a measured concentration in excess of normal historical fluctuations.

In Chapter 3: Normal Historical Fluctuations at the Houston East (CAMS 1) Monitoring Site, the TCEQ demonstrates that the measured daily one-hour maximum ozone value at Houston East (CAMS 1) monitoring site, 128 parts per billion (ppb), was well outside the normal historical fluctuations at the site. When compared to nearly 700 seasonal ozone observations collected over three years (2009 through 2011) August 26, 2011 was shown to lie in the top 1 % of daily seasonal maximums. When compared to over 1,000 observations on an annual basis for the same time, August 26, 2011 also lay in the top 1 %. Analysis of diurnal ozone profiles for Houston East (CAMS 1) monitoring site involving 3,500 data points for the month of August in 2008 through 2012 also showed that August 26, 2011 was an outlier. A review of ozone monitoring data for August 26, 2011 revealed that a large majority of the ozone monitoring sites throughout southeast Texas had unusually high one-hour daily maximum ozone measurements.

7-2 Even more compelling is the fact that 18 of 19 ozone monitoring sites in the HGB area reported one-hour daily maximum ozone values that were greater than each site’s 95th percentile on August 26, 2011.

6. There would have been no exceedance but for the exceptional event.

Chapter 5: No Exceedance but for the Exceptional Event, analyzes background ozone for the HGB area and compares August 26, 2011, to a very meteorologically similar day (August 27, 2009) where the only significant differences between the two days are the widespread numbers reporting maximum daily ozone measurement outside of the range of normal historical fluctuation and the presence of fire-related emissions over the HGB area on August 26, 2011. Local Volatile Organic Compound measurements near the Houston East (CAMS 1) monitoring site were found to be well within the range of normal historical fluctuation and HRVOC measurements on the exceptional event and surrogate days were not statistically different. Without the extra ozone and precursors contributed by wildfires outside of Texas, the one-hour ozone NAAQS exceedance of 128 ppb would not have occurred. The similar day in 2009 only had a maximum one-hour measurement of 111 ppb – a difference of 17 ppb that is, at the very least, partially attributable to the fire-related emissions.

7. The TCEQ followed the required public comment process.

Since submittal of this document was not a SIP revision or a rule action, the TCEQ was not required to hold public hearings or go before its commission prior to submittal to the U.S. EPA. This document was posted on the TCEQ website for 30 days, and copies of all comments received from the public are included in the final submission.

8. The state complies with 40 Code of Federal Regulations (CFR) §51.930, which requires the state to take appropriate and reasonable actions to warn, educate, and protect the public from exceedances of the one-hour ozone NAAQS.

It is demonstrated through implementation plan revisions that the HGB area, one of the country’s largest and fastest growing metropolitan areas, has put into place one of the most innovative and effective set of control strategies in the U.S (Chapter 1: Introduction). The HGB Attainment Demonstration and Rate of Further Progress State Implementation Plan have gone through a very rigorous evaluation process photochemical modeling, peer review, public review, and the thorough review of the U.S. EPA. TCEQ control strategies for the HGB area have consistently passed the rigorous U.S. EPA review applied to SIP revisions. In addition to its effective control strategies, the TCEQ leverages contemporary media tools to provide up-to-the- minute air quality updates to people in the HGB area with electronic mail, its website, local media outlets that notify the public, and Internet links to other air quality resources like the U.S. EPA, AirNow, AirNowTech, and many other sites. On its own website, the TCEQ makes air quality data available to the public within one to two hours of its collection in the HGB area. The TCEQ also actively supports public awareness campaigns such as the “Take Care of Texas Program.” Through the Texas Emissions Reduction Plan (TERP) program, Rider 8 program, and air quality research funds, the TCEQ has spent hundreds of millions of dollars annually to help citizens reduce ozone causing pollution and better understand the complexities of ozone reductions so that the TCEQ and stakeholders in the HGB area and other areas throughout the state can continue working together to reduce ozone levels even more.

This, is the TCEQ case for the EPA’s concurrence on the exceptional event flag with respect to the events of August 26, 2011, at the Houston East (CAMS 1) monitoring site. The TCEQ believes

7-3 that it is submitting a strong, persuasive, and clear case for excluding the exceptional event occurring on August 26, 2011.

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8-10 APPENDIX A: PRESS RELEASES/MEDIA REPORTS

U.S. EPA guidance suggests the inclusion of news reports to support Exceptional Events evidence:

Air agencies can provide the following information to help establish the occurrence and geographic extent of the event: special weather statements, advisories, news reports;

This appendix provides various web related news reports (links) that support that the wildfires did happen, that some were not reasonably controllable or preventable as in the case of lightening.

These links provide include documents of fires and smoke on or around August 26, 2011 Additionally, reports from the climate and wildfire reports were collected from the National Oceanic and Atmospheric Administration (NOAA) and the United States Forest Service (USFS). Web links to documents are provided below http://wildfiretoday.com/2011/08/25/lightning-starts-fires-in-the-northwestern-united-states/ http://www.noaawatch.gov/headlines/fire_wx.php

http://www.blm.gov/or/districts/burns/files/BU_FireUpdate_August252011_6pm.pdf

http://www.blm.gov/or/districts/burns/files/BU_FireUpdate_August262011_7am.pdf http://www.thewildlifenews.com/2011/08/23/idaho-montana-forest-fires-heating-up/ http://articles.cnn.com/2011-08-26/us/california.fire_1_propane-tank-yosemite-national- park-wildfire?_s=PM:US

http://alg.umbc.edu/usaq/archives/004293.html

Plains states experienced elevated ozone levels today (August 26, 2011) with Kansas, Oklahoma, Texas, Georgia, and Florida reporting Code Orange (Unhealthy for Sensitive Groups) ozone levels. NOAA's Hazard Mapping System (HMS, bottom left) shows smoke from various fires continuing to cover a large part of the country.

http://alg.umbc.edu/usaq/archives/2011_08.html

A-1 http://www.ssd.noaa.gov/PS/FIRE/DATA/SMOKE/2011/2011H280420.html

A-2 Additional Media Articles Concerning Fires in the Northwestern United States

Missoulian August 22, 2011

New wildfire starts near Wyoming-Montana border http://missoulian.com/news/state-and-regional/new-wildfire-starts-near-wyoming-montana- border/article_bf848c16-cd3c-11e0-b9d4-001cc4c03286.html

Fires on Flathead forest grow slightly, expected to burn for weeks http://missoulian.com/news/state-and-regional/fires-on-flathead-forest-grow-slightly-expected- to-burn-for/article_1d2856d4-cd3f-11e0-b5ac-001cc4c03286.html

Wildfire races up West Riverside mountain, burns 1,000 to 2,000 acres http://missoulian.com/news/local/wildfire-races-up-west-riverside-mountain-burns-to- acres/article_3e1c91e8-cd21-11e0-917e-001cc4c03286.html

Fire in Idaho wilderness moves onto Bitterroot National Forest http://missoulian.com/news/state-and-regional/fire-in-idaho-wilderness-moves-onto-bitterroot- national-forest/article_0583d180-cd3e-11e0-b7a8-001cc4c03286.html

Missoulian August 20, 2011

3 western Montana wildfires remain 'relatively' calm http://missoulian.com/news/state-and-regional/western-montana-wildfires-remain-relatively- calm/article_ec877d12-cb8f-11e0-b71a-001cc4c03286.html

Missoulian August 23, 2011

West Riverside fire: Slurry bombers, helicopters, ground crews fight back http://missoulian.com/news/local/west-riverside-fire-slurry-bombers-helicopters-ground-crews- fight-back/article_201c12e4-cdef-11e0-aec2-001cc4c002e0.html

Bitterroot wildfire grows by almost 10,000 acres in single day http://missoulian.com/news/state-and-regional/bitterroot-wildfire-grows-by-almost-acres-in- single-day/article_36063026-ce08-11e0-ab8f-001cc4c002e0.html

5,000-acre wildfire prompts evacuations northwest of Lame Deer http://missoulian.com/news/state-and-regional/acre-wildfire-prompts-evacuations-northwest- of-lame-deer/article_ee5fb5f8-ce07-11e0-8c19-001cc4c002e0.html Lightning sparks dozen new wildfires on Crow Reservation http://missoulian.com/news/state-and-regional/lightning-sparks-dozen-new-wildfires-on-crow- reservation/article_ba16c206-cd84-11e0-ba78-001cc4c03286.html

West Riverside fire: Slurry bombers, helicopters, ground crews fight back http://missoulian.com/news/local/article_201c12e4-cdef-11e0-aec2-001cc4c002e0.html

Missoulian August 24, 2011

Fire crews corral flank of West Riverside blaze before thunderstorms http://missoulian.com/news/local/fire-crews-corral-flank-of-west-riverside-blaze-before- thunderstorms/article_1137d94a-cec9-11e0-a184-001cc4c002e0.html

Spread of 19,000-acre Bitterroot blaze slows http://missoulian.com/news/state-and-regional/spread-of--acre-bitterroot-blaze- slows/article_7f51a060-ced2-11e0-9105-001cc4c002e0.html

Fire near Lame Deer grows to more than 16,000 acres http://missoulian.com/news/state-and-regional/fire-near-lame-deer-grows-to-more-than- acres/article_f6be9dca-ced1-11e0-a310-001cc4c002e0.html

Smoke plumes from Idaho prescribed fires visible from Missoula, Bitterroot valleys http://missoulian.com/news/state-and-regional/smoke-plumes-from-idaho-prescribed-fires- visible-from-missoula-bitterroot/article_e525936a-cec8-11e0-99d4-001cc4c002e0.html

Smoke plumes visible from Missoula are from Idaho burns http://missoulian.com/news/local/smoke-plumes-visible-from-missoula-are-from-idaho- burns/article_fa829860-cebf-11e0-9f42-001cc4c002e0.html

Wind, lightning push wildfires across Montana http://missoulian.com/news/state-and-regional/wind-lightning-push-wildfires-across- montana/article_587fad12-ce53-11e0-8439-001cc4c03286.html

The Oregonian August 17, 2011

Threat of wildfires to rise along with the thermometer early next week | OregonLive.com http://www.oregonlive.com/pacific-northwest- news/index.ssf/2011/08/threat_of_wildfires_to_rise_along_with_the_thermometer_early_next _week.html

The Oregonian August 18, 2011

Grass fire near Rogue River threatens homes, closes part of I-5 | OregonLive.com http://www.oregonlive.com/pacific-northwest- news/index.ssf/2011/08/grass_fire_near_rogue_river_threatens_homes_closes_part_of_i- 5.html

The Oregonian August 23, 2011

Firefighters contain 1,000-acre wildfire that threatened homes near Madras http://www.oregonlive.com/pacific-northwest- news/index.ssf/2011/08/firefighters_contain_1000- acre_wildfire_that_threatened_homes_near_madras.html

The Oregonian August 25, 2011

Lightning sparks 180 fires across Oregon, with more expected this weekend http://www.oregonlive.com/pacific-northwest- news/index.ssf/2011/08/lightning_sparks_180_fires_across_oregon_with_more_expected_this _weekend.html

The Oregonian August 26, 2011

100 new fires erupt around Oregon after lightning strikes http://www.oregonlive.com/pacific-northwest- news/index.ssf/2011/08/100_new_fires_erupt_around_oregon_after_lightning_strikes.html

The Oregonian August 27, 2011

Idaho National Lab wildfire mostly contained http://www.oregonlive.com/pacific-northwest- news/index.ssf/2011/08/80_percent_idaho_national_lab_wildfire_reported_contained.html 100 new fires erupt around Oregon after lightning strikes http://impact.oregonlive.com/pacific-northwest-news/print.html?entry=/...

100 new fires erupt around Oregon after lightning strikes Lynne Terry | [email protected] By Lynne Terry | [email protected] Email the author | Follow on Twitter on August 26, 2011 at 9:55 PM, updated August 26, 2011 at 9:57 PM

More than 100 new fires flared up around O regon late Thursday and early Friday, with the biggest blazes sweeping through grasslands in Wheeler C ounty and on the Warm Springs reservation.

O regon was hit with about 1,200 lightning strikes, mainly in the northwest. The night before, 9,400 strikes zapped areas elsewhere.

"Last night, it hit the spot that was missed the night before," said Jeree Mills, spokeswoman for the Northwest Interagency Coordination Center in Portland. "It was pretty efficient."

Nearly 140 firefighters are battling the Hancock complex of fires just northeast of the unincorporated settlement of C larno in Wheeler C ounty, charring more than 13,000 acres. Five fires, ignited by lightning, are burning through rangelands straddling the John Day River and O regon 218.

"With the warm weather and unstable air, they grow pretty quickly," Mills said.

The 55 young science campers who evacuated the Hancock Field Station outside Fossil were scheduled to return to Portland for their regularly scheduled pickup by parents after two nights camping out in tents, said A ndrea Middleton, a spokeswoman for the O regon Museum of Science and Industry.

Firefighters are battling several blazes on and near the Warm Springs reservation. No structures were threatened, said Jeri C hase, an Oregon Department of Forestry spokeswoman.

The Webster fire, about 50 percent contained, has charred 1,500 acres northeast of Warm Springs, but crews hope to contain it fairly quickly. They're also fighting three dozen mostly smaller fires, but the High Cascades complex included three fires covering 3,000, 1,700 and 1,000 acres, said Bob Sjolund, a Warm management spokesman.

T he U.S. Bureau of Land Management is leading efforts against several grass and brush fires in southeastern O regon:

The West Little fire swept about 2,500 acres in remote territory 40 miles southeast of Burns Junction. The DSL complex of four fires torched about 1,000 acres along O regon 78 about 60 miles southeast of Burns. Smoke briefly closed the highway Thursday. The Smyth charred about 1,500 acres about 15 miles south of Diamond. The Desert Meadows fire covered about 600 acres about 15 miles south of Frenchglen. The V ines Hill fire extended over about 500 acres about 15 miles west of V ale.

The range fires tend to calm into the evening with higher humidity and lower temperatures.

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But another round of thunderstorms is forecast to strike the state through today, with temperatures in the upper 80s west of the C ascades and in the low 90s on the east side. The thunderstorms will move into Idaho and Montana on Sunday, bringing cooler temperatures.

Normally, that would bode well for firefighting efforts, but there's a catch: The cooler temperatures are expected to bring strong winds, some up to 45 mph.

"A ny fires out there will get whipped up in a hurry," said C linton Rockey, a meteorologist with the National Weather Service in Portland.

-- Lynne Terry

© 2014 O regonLive.com. A ll rights reserved.

2 of 2 9/15/2014 2:36 PM 3 western Montana wildfires remain 'relatively' calm 1 of 1

3 western Montana wildfires remain 'relatively' calm

AUGUST 20, 2011 8:00 PM • BY GWEN FLORIO OF THE MISSOULIAN Firefighters spent a relatively calm night Friday on three wildfires burning in western Montana - the key word being "relative," according to Flathead National Forest District Ranger Deb Mucklow.

"We still have an active fire, but not active growth," she said Saturday of the 1,250-acre Hammer Creek fire burning on the Spotted Bear Ranger District in the .

The Big Salmon , also burning in the Bob, had grown to 2,600 acres by Saturday, up from 2,000 acres Thursday, she said.

"It was more active, but active within the existing burn area," she said. Flames "would make a run up to the top of a ridge, roll down, and re-burn with more intensity."

Some 63 firefighters are monitoring both fires, she said.

No direct action was taken on either one Saturday and they remained at zero percent contained.

The South Fork Lost Creek fire burning in "extreme terrain" on the Swan Lake Ranger District was put at 10 percent contained Saturday, with 910 acres burned, said Tina Lawrence, a Flathead National Forest public information office.

Firefighters staged a successful 400-acre burnout Friday around Lost Creek Road and Lost Creek Trail to keep the flames from spreading south and west, she said.

About 188 firefighters are on the South Fork Lost Creek fire, with two engines, a water tender and five helicopters, she said.

Reporter Gwen Florio can be reached at 523-5268, [email protected] or CopsAndCourts.com.

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Home / News / Montana & Regional 5,000-acre wildfire prompts evacuations northwest of Lame Deer

August 23, 2011 8:00 pm • By ZACH BENOIT and CHELSEA KROTZER Billings Gazette (0) Comments

BILLINGS - The Waterhole fire has exploded to more than 5,000 acres, prompting evacuations northw est of Lame Deer on Tuesday.

The fire is about a half-mile north of Lame Deer on the Northern Cheyenne Indian Reservation, fire officials said.

Marilyn Krause, fire information officer for the Northern Rockies Type II incident management team that w ill take command Wednesday morning, said the fire is not contained.

She said it is one of five fires burning in the area. They have been dubbed the Black Springs Complex.

"Temperatures have been in the high 90s, and I think they had sustained w inds in the 30s to go w ith low humidity, so it's grow n quite a bit," Krause said.

Krause said mandatory evacuations w ere ordered for homes in the Lynch Coulee Road and Jimtow n cutacross road areas. She did not know how many homes w ere evacuated or how many people w ere affected.

Mark Hepler, dispatch manager of the Billings Interagency Dispatch center, said evacuees w ere asked to go to Lame Deer High School.

Christie Foote w orks at the dispatch center in Lame Deer and w as manning the emergency shelter at the high school Tuesday night. She said that, as of 9 p.m., nobody w as staying at the shelter.

How ever, some people did come by to register w ith the shelter, provide information about w here they w ould be staying and pick up supplies such as first-aid kits, toiletries and blankets.

"We just put together this shelter for them, a place they can come if they need," Foot said. "But right now there's no one here."

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Krause estimated that the five fires had burned as much as 5,800 acres by Tuesday evening.

As many as 15 engines and numerous helicopters and heavy tankers w ere assisting fire crew s from the Crow and Northern Cheyenne reservations.

"We've got more resources ordered," Krause said. "Obviously the fire w as real active today, and w e expect that to continue for the next few days."

Also in Rosebud County, three lightening-caused fires about 30 miles south of Ashland in the combined into one fire, know n as the Diamond Complex. By Tuesday evening, it had burned about 13,500 acres of ponderosa pine and sagebrush, said Kimberly Frasier, fire information officer from the Ashland Ranger District.

"There are a few structures w ithin the (complex), but at this time I don't have an update to w hether they are in danger or anything like that," Frasier said.

No evacuations had been ordered as of Tuesday evening.

Ground and air crew s w ere fighting tw o other fires near Ashland, the Mullins fire at 2,000 acres and the Mill fire, w hich grew from 200 acres to 2,000 by Tuesday evening.

The Diamond Complex and Mill fire grew significantly throughout the day, thanks in large part to hot, dry w eather.

"We have been more ordering resources and they're steadily coming in," Fraiser said. She added that Forest Service, Rosebud County and Bureau of Land Management crew s have been fighting the fire, along w ith local landow ners and w ith the help of helicopters and air tankers.

Frasier said a ground team from the Northern Rockies Incident Management team w ill assume command of the Diamond Complex on Tuesday night.

Betw een Sunday evening and Tuesday morning, firefighters on the Crow Indian Reservation contained nearly a dozen new w ildfires w hile they continue to deal w ith the 800-acre Hoss fire burning in the Bighorn Mountains.

Most, if not all, of the 11 new fires w ere caused by a lightning storm that rolled through the area Sunday.

The largest of the new fires, called the Beauvais Creek fire, burned about 775 acres northw est of St. Xavier. A Bureau of Indian Affairs press release said that it w as no longer "show ing open flame" by late Tuesday morning but that there w ere still areas giving off heat.

A pair of engines continued to patrol the area Tuesday evening.

The fires range in size from tw o acres to 775. The release said engine and hotshot crew s remain on most of the fires, many of w hich w ere contained or controlled by Tuesday.

Officials said one of the fires, in the Reno Creek valley, w as threatening homes. That prompted tribal and federal agencies to bring in a heavy air tanker to drop retardant on the blaze.

Tw o helicopters, a hotshot fire crew and firefighters from Big Horn County also assisted in the effort to contain that fire, know n as the Blankenship fire.

The 800-acre Hoss fire burning in Black Canyon is about 75 percent contained and officials are considering reduce efforts to monitoring by engines and a single helicopter if it doesn't grow by Wednesday.

About 35 firefighters remain on scene there.

Because of expected high temperatures and low humidity Tuesday, Big Horn County put Stage 1 fire restrictions in place, w hich prohibit most fires and campfires and doesn't allow for smoking except in enclosed vehicles, buildings or developed recreation sites or in an area at least three feet in diameter that's been cleared of possible fuel.

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To the w est, the Bull Fire, w hich has been burning in the Absaroka-Beartooth Wilderness 12 miles w est of Gardiner since July 29, grew to 248 acres because of the w eather.

That prompted fire officials to send out a pair of additional firefighters to protect structures and monitor the fire, but the plan remains to let the fire burn naturally.

Copyright 2014 missoulian.com. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.

Tags Wildfire, Disaster_accident, Environment, Northern Cheyenne Indian Reservation, Custer National Forest, Northern Rockies Incident Management, Black Springs Complex

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Home / News / Montana & Regional

August 23, 2011 10:45 pm • By PERRY BACKUS Ravalli Republic (0) Comments

HAMILTON - Pushed by heavy winds late Monday, the Saddle fire in the Frank Church-River of No Return Wilderness grew by almost 10,000 acres in a day.

On Tuesday, the fire slowed as firefighters on the Montana side began looking for opportunities to attack the blaze.

Late Monday, the wildfire created a plume that could be seen from space.

In a few hours, it made a five-mile run to the east along the Continental Divide and a three-mile run to the south as it burned through heavy stands of bug-killed lodgepole pine.

"It was a great day for fires," said Bitterroot National Forest fire management officer Rick Floch. "There were really low relative humidity levels and high winds created by the passage of a cold front."

"All across the state, we saw the same impacts on fires," he said.

In many places, the fire was pushed across ridges mid-slope by the high winds. At that point, Floch said the fire didn't really want to burn back up the hill.

In some places, firefighters clocked winds at 30 mph.

The sudden growth in the fire caught officials a bit by surprise Monday.

Floch said officials from the Salmon-Challis and Bitterroot national forests were in the middle of a four-hour meeting when the high winds hit.

Their initial plan called for a Salmon-Challis team to take on responsibility for monitoring the wilderness fire when it stood at about 700 acres. When it jumped to 17,000 acres and crossed over the divide into Montana, those plans changed.

Bitterroot National Forest officials took over responsibility for the fire on the Montana side. And an

http://missoulian.com/news/state-and-regional/bitterroot-wildfire-grows-... 7/14/2014 4:18 PM Bitterroot wildfire grows by almost 10,000 acres in single day 2 of 2

incident command team was ordered.

"They don't have nearly as many values on their side of the divide," Floch said. "We decided it would be difficult logistically for their team to have responsibility for the whole fire."

As of Monday morning, three initial attack crews were ordered and a helicopter on the Montana side.

Spot fires were about a half-mile from the nearest private structure, which Floch thought included a cabin and trailer house. The next nearest structures were about three miles away down the West Fork.

Floch said it may take some time before officials know how they will address the blaze.

"It got so big so fast that people are still trying to get information about where the fire actually is," he said. "It spotted quite a ways out in front of it."

Bitterroot National Forest officials manned an information trailer at Painted Rocks Lake boat ramp Monday.

While no evacuations have been ordered yet, Floch said officials will urge people potentially in the line of the fire to start thinking about getting prepared just in case.

Copyright 2014 missoulian.com. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.

Tags Frank Church-river Of No Return Wilderness , Ravalli County Montana , Bitterroot National Forest , Wildfires

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Home / News / Local Fire crews corral flank of West Riverside blaze before thunderstorms

MICHAEL GALLACHER/Missoulian

One of two heav y -lif t helicopters dumps water on the West Riv erside f ire across f rom Buy Now the old Stimson mill on Wednesday af ternoon. Calmer weather Wednesday allowed f iref ighters to catch their breath on the blaze, which started Monday af ternoon.

August 24, 2011 11:00 pm • By ROB CHANEY of the Missoulian (0) Comments

BONNER - Firefighters took advantage of Wednesday's Related Galleries calm w eather to corral the West Riverside fire's northw est flank, in preparation for possible thunderstorms later in the w eek.

And state Department of Natural Resources and Conservation investigators hope someone w ill provide information about the suspicious cause of the fire, w hich West Riverside fire photos: has burned at least 2,000 acres and threatened more August 2011 than 40 homes in West Riverside and the Blackfoot River canyon. Smoke plumes from Idaho

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A Crimestoppers alert seeks information from anyone prescribed fires visible from w ho saw the fire start at 6:07 p.m. Monday in the rocky Missoula, Bitterroot valleys hills above West Riverside, betw een East Missoula and Smoke plumes v isible f rom the Missoula and northern Bitterroot Bonner. Anyone w ith a tip may call anonymously at (406) v alley s Wednesday night were 721-4444. f rom prescribed f ires ignited recently - and being… Read more On Wednesday afternoon, Montana Fish, Wildlife and Parks officials closed the Blackfoot River to recreation Fire near Lame Deer grows to from Wisherd Bridge seven miles dow nstream to Bonner. more than 16,000 acres That included the Marco Flat and Weigh Station fishing LAME DEER - Smoke and ash made it dif f icult to see the hillside access sites. that Gloria Zerber and her 7-y ear-old grandson watched Authorities w ere allow ing floaters to take out at Wisherd Tuesday ev ening as f lam… Read Bridge, although most floaters w ould be better off to use more the Angevine Fishing Access Site one mile upstream. Spread of 19,000-acre Bitterroot The closure remains in effect until that reach of river is blaze slows no longer needed for helicopter bucket dips, according to HAMILTON - The spread of the FWP spokesw oman Vivaca Crow ser. Saddle f ire southwest of Painted Rocks State Park on the Ground crew s spent the day digging and burning out a Montana/Idaho border slowed considerably on Wednesday, a… strong line along the eastern ridge of Mittow er Gulch and Read more around Woody Mountain to protect a major pow er and communications line north of the main fire perimeter. They THURSDAY'S WEATHER: Red also completely surrounded a large 300-acre spot fire flag warning issued for dry that had scorched the basin east of Johnson Creek in the thunderstorms Blackfoot Canyon, about half a mile from the main blaze.

At nightfall, the West Riverside fire w as reported 20 percent contained.

"We don't have the staff to w ork along the southern face (above West Riverside and Bonner)," fire operations chief Craig Glazier told about 40 people at a community

meeting in Bonner Wednesday evening. "So w e have The National Weather Serv ice has structure protection crew s patrolling there, and the same issued a red f lag warning, in for the Blackfoot. Our main concerns now are the east ef f ect f rom noon until midnight Thursday. Read more face and the south face along the river. There's a lot of heavy fuel, a lot of snags and steep rocky slopes. It's not a place you w ant to put people."

As he spoke, his voice w as occasionally overw helmed by Type 1 helicopters ferrying w ater to those areas. Although several other major blazes have broken out in the past tw o days, the West Riverside fire should retain its air support, he said.

***

Earlier in the day, Gov. Brian Schw eitzer came to Missoula Rural Fire Station No. 4 in Piltzville for an update on West Riverside, w hich is now one of several major fires burning in Montana. State Forester Bob Harrington w elcomed him to the site of the No. 1 priority fire in the nation.

"We're not real thrilled w ith that distinction," Harrington said. "But it w ill help us get w hat w e need."

That included tw o heavy-lift helicopters w ith a third expected on Thursday, along w ith 250 personnel and numerous fire engines and earth-movers.

A stable air mass pushed thick smoke into the Missoula Valley Wednesday morning, but the air cleared by mid-afternoon. That w as a mixed blessing for the ground crew s, w ho endured w inds of 25 mph on the ridgetops. They w ere also bracing for possible dry thunderstorms on Wednesday evening and through the rest of the w eek.

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Those storms may bring rain as the w eekend nears, although they could also pack w ind and lightning.

"If w e get through this evening, w e're looking pretty good," Glazier said. "But w e don't know w hich w ay the w inds w ill blow."

"I just flew over that," Schw eitzer said. "If this moves north, there's a lot of fuel ahead of it."

That includes a lot of former Plum Creek Timber Co. land that now belongs to the U.S. Forest Service through the Montana Legacy Project.

Lolo National Forest Supervisor Debbie Austin said foresters w ere actually planning some controlled burns in the area for habitat improvement.

"Nature's taken care of that for us," Austin said.

One audience member at the Bonner meeting w ondered if many apparently unburned trees w ould survive the fire. Fire behavior specialist Matt Butler said they might.

"You are going to lose some trees, but I'm surprised w e haven't seen more burned to skeletons," he said. "Much of this fire looks like the nice prescribed burns w e do in other areas."

Another thing that w ill stick around is the smoke, even after the fire comes under control. DNRC area manager Tony Liane w arned the area w ould continue to smolder for a w hile. While some forecast thunderstorms are supposed to bring rain by the w eekend, it probably w on't be enough to affect the fire's progress.

"We w on't pull out until w e get a significant change in w eather - either rain or snow ," Liane said. "But this fire's going to be w ith us for a long time."

Copyright 2014 missoulian.com. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.

Tags West Riverside Fire, Wildfires, East Missoula, Disaster_accident, Missoula Montana, Blackfoot River, Montana Legacy Project, Department Of Natural Resources And Conservation, Brian Schweitzer, United States Forest Service

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Fire in Idaho wilderness moves onto Bitterroot National Forest

AUGUST 22, 2011 7:30 PM • BY DAVID ERICKSON RAVALLI REPUBLIC HAMILTON - The Saddle Complex fire burning in a remote portion of Idaho's Frank Church-River of No Return Wilderness moved onto the Bitterroot National Forest on Sunday afternoon and grew to 1,018 acres during the day Monday.

The complex is comprised of two wildfires burning near the Montana-Idaho border about 20 miles southwest of Painted Rocks State Park - the Saddle fire on the Idaho side and the 27-acre Stud fire on the Montana side of the border.

According to Salmon-Challis National Forests public information officer Jesse Bender, both fires are burning in an area that has not been impacted by fire in more than 100 years. The Saddle fire is being managed for resource benefits, meaning it is not actively being suppressed.

Officials chose not to staff the Stud fire due to the high safety risk to firefighters in the steep terrain and dense fuels and the limited values threatened.

The fires are being managed as a complex by a Salmon-Challis National Forest Type 3 team in a joint effort with the Bitterroot National Forest. Bender said the only threatened structures are on a wilderness inholding with seven cabins near Horse Creek Hot Springs called Gattin Ranch.

Fire officials were forced to close the Horse Creek Hot Springs on Monday because of the fire's proximity to the campground.

"We have a point protection strategy right now," she said. "Crews are going out ahead and preparing these areas to withstand fire, to be protected. We have firefighters on a hose out there. We are getting a little bit more wind on the fire than expected, so there have been a few uphill runs, but not any significant growth in the size of the fire."

On the Bitterroot side, firefighters are beginning to scout and prep areas of the West Fork Ranger District that require protection. The Stud fire is moving to the northeast toward Painted Rocks State Park.

At this time, there are no trail closures in effect but hikers are cautioned to be aware of the potential for such closures as well as the closure of roads accessing trailheads.

The fires burning in the Saddle Complex were ignited by lightning and flared up during high winds on Aug. 18 in the upper Horse Creek drainage, 23 miles northwest of North Fork, Idaho.

For updates on the fire, go to www.inciweb.org/incident/2496.

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Home / News / Montana & Regional Fire near Lame Deer grows to more than 16,000 acres

August 24, 2011 10:19 pm • By CHELSEA KROTZER Billings Gazette (0) Comments

LAME DEER - Smoke and ash made it difficult to see the Fire crews corral flank of West hillside that Gloria Zerber and her 7-year-old grandson Riverside blaze before w atched Tuesday evening as flames from the thunderstorms 16,000-acre Waterhole fire engulfed the dry brush, trees Authorities are and even pow er lines. seeking

They knew the flames w ere getting close after hundreds inf ormation about the suspicious of grasshoppers and birds started moving south ahead cause of the f ire, which has of the flames. burned at least 2,000 acres and threatened more than 40 … Read "It w as pretty cool to w atch that hill burn," Zerber said more from her front porch Wednesday morning. "It w as just consumed."

Zerber w as looking through the haze at the blackened hillside less than tw o miles aw ay from her home w est of Lame Deer. She lives w ith her daughter and grandson in the Muddy Cluster subdivision. While she has not received any evacuation notices, she has no plans to leave.

"If they told us to evacuate, I'd stay and try to protect the house," Zerber said. "I'd make sure my family gets out of here, but I'm going to stay."

The Waterhole fire grew from just around 5,000 acres Tuesday to more than 16,000 acres overnight as w ind gusts up to 35 mph carried flames and embers across the dried grasses, sagebrush and ponderosa pines. Highw ay 212 w as closed to through traffic Tuesday, and tw o residential areas - the Lynch Coulee Road and Jimtow n cutacross areas - w ere evacuated.

***

It's just one of five fires burning about 20,000 acres in an area dubbed the Black Springs Complex. All five w ere caused by lightning after a storm blew through Sunday night.

Crew s from the Northern Rockies Incident Command team arrived around noon Tuesday, setting up camp in Busby. Incident Commander Stan Beres said he expects 300 to 400 personnel to help fight the fires by Wednesday night. A mobile retardant unit is expected to be brought to the

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incident command center in Busby by Thursday.

The unit is able to put out 75,000 to 100,000 gallons of retardant a day, if there are enough aircraft available.

Before this w eek, the fire season had been slow for the management crew .

"It's kind of like the fire season came to the Northern Rockies overnight," Beres said. "We've got 15 crew s headed our w ay, w ith a couple on site."

He is expecting five 20-person hotshot crew s, betw een 20 and 25 engines and four types of air support by nightfall.

"It's a good high priority, mostly because it's threatening communities here," Beres said.

Three hotshot crew s w ere moving through the burned fields and hillsides in search of hot spots, carefully craw ling through soot-covered barbed w ire fences and past charred remains of hay bales.

It w as a very different job from the w ork Tuesday night, w hen the fire tripled in size.

"Last night w as structure protection," said Scott Bradley, crew boss of a hotshot team out of Fort Belknap. "We w ere carrying brush aw ay from homes, making sure no materials w ere against them."

The crew s spent most of Tuesday w alking in a single-file line, loosening up the dirt near smoldering sagebrush and grasses to help release the heat and avoid future flare-ups.

Overhead, tw o helicopter crew s w ere doing bucket drops on the flames that had kicked up again by Wednesday afternoon in the hills to the north of Highw ay 212.

It w as difficult to find w ater, and a steady supply of it.

"We just don't have the w ater here and ranchers w ho have reserves, they are pretty concerned w ith conserving their w ater," Beres said.

Bradley's crew is w ell versed in fires, having returned from fighting fires in Arizona and New Mexico in June.

A cold front is expected to move in Thursday, bringing thunderstorms and gusty w inds.

Jess Secrest, operations manager, said the plan for Wednesday night is to continue to protect homes.

"Tonight w e are going to try to secure the line across the highw ay," Secrest said of Highw ay 212. "It's to protect the structures. We w ill prioritize and find out w hat w ill need protection tonight."

***

Southeast of the Black Springs Complex is another group of fires that has burned more than 20,000 acres near Ashland. Another Northern Rockies Type II Incident Management team is scheduled to take over fire operations by Thursday morning, said Kimberly Frasier, fire information officer w ith the Ashland Ranger District.

Three of those fires, about 30 miles southeast of Ashland, w ere named the Diamond Complex and scorched 16,500 acres by Wednesday evening. Tw o of them merged into the Little Fork fire on Wednesday, w hich has burned 6,700 acres.

"High heat, low humidity w ith w inds helped these fires grow on Wednesday," Frasier said. "Sounds like it's going to be the same tomorrow ."

Several outbuildings have been destroyed w ithin the complex's burn area, officials said.

The Mill fire, 15 miles to the northeast of Ashland, has burned about 4,500 acres, although an

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update w asn't available on Wednesday evening.

Containment estimates w eren't immediately available.

Most of those fires are burning in the Custer National Forest, but if the w eather doesn't cooperate, one fire could burn onto private lands, threatening ranches, according to Pat McKelvey, incident commander of the Ashland area fires. He expected 12 more crew s to show up for the Ashland area fires, basing operations out of Fort How e.

***

On the Crow Indian Reservation, the 800-acre Hoss fire, burning in a rugged canyon in the Bighorn Mountains, grew only by a few acres on Wednesday.

Officials said that fire's grow th is actually strengthening fire lines because it is spreading tow ard natural barriers.

Some crew s and resources w ere released from the Hoss fire to assist w ith the fires in the Lame Deer area, but about 37 personnel remain on scene there.

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3 of 3 7/14/2014 4:35 PM Firefighters contain 1,000-acre wildfire that threatened homes near Madras http://impact.oregonlive.com/pacific-northwest-news/print.html?entry=/...

Firefighters contain 1,000-acre wildfire that threatened homes near Madras The Associated Press By The Associated Press Follow on Twitter on August 23, 2011 at 11:03 PM, updated September 04, 2011 at 1:46 PM

MA DRA S -- Firefighters have contained a 1,000-acre wildfire that had threatened more than 20 homes in central O regon, a state f ire marshal's spokesman said Tuesday evening.

No homes were lost and no one was injured in the fire although one outbuilding was reported burned.

"The fire, in a nutshell, has been contained, and the perimeter is expected to hold," spokesman Justin de Ruyter said.

A dditional fire crews mobilized from Clackamas and Marion counties under a C onflagration A ct declaration from Gov. John Kitzhaber have been taken off the fire line and will be sent home, he added.

Federal wildland firefighters and structural firefighters from Jefferson C ounty as well as the two Western O regon counties worked together to suppress the fire four miles west of Madras.

Wind gusts were a concern Tuesday afternoon, but those winds passed through the area "and the perimeter line is looking good," de Ruyter said.

The wind-driven fire started Monday afternoon, and its origin has been traced to an area resident's burn barrel, the spokesman said.

It spread through grass and brush on private land and U.S. Bureau of Land Management property.

Greg McCool estimated damage at $100,000 as flames ate through his fields and a pump house, according to KTVZ-TV. However, he said he's grateful for the response to the blaze.

A mong the homes saved was his mother's residence.

"My mom told me to just tell everyone I see, 'Thank you, thank you, thank you,' because this was her home, and they saved it for her," McC ool told the TV station Tuesday afternoon.

-- The Associated Press

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1 of 1 9/15/2014 2:40 PM Fires on Flathead forest grow slightly, expected to burn for weeks 1 of 2

Fires on Flathead forest grow slightly, expected to burn for weeks

AUGUST 22, 2011 8:30 PM • BY TRISTAN SCOTT OF THE MISSOULIAN Several fires burning in the Flathead National Forest grew slightly over the weekend and will continue burning for weeks, even as suppression efforts are pared back and crews demobilized.

The 2,750-acre Big Salmon Lake fire and the 1,350-acre Hammer Creek fire both are burning in the Spotted Bear Ranger District of the Bob Marshall Wilderness. The fires spread Sunday and Monday due to strong winds, warm temperatures and low humidity.

Melissa Wilson, public information officer for the Flathead National Forest, said incident commanders predicted both fires would continue to grow late Monday before Tuesday's moderate temperatures and increased humidity decelerate the flames.

"Over the weekend, both fires moderate-to-low growth in terms of expanding the perimeter, but there was active interior burning," Wilson said. "But they did not show the kind of dramatic jumps in size that we saw last week."

The South Fork Lost Creek Fire grew to 1,215 acres Sunday as the fire burned actively along the east flank, with isolated torching, short runs and spotting near the headwaters of the South Fork of Lost Creek.

The fire showed little activity Monday, however, and officials started downsizing the 140-member firefighting crew, which has worked the fire since it was reported Aug. 13.

Pat Cross, a spokesman for the Montana Department of Natural Resources and Conservation, said Monday's team shrank to 106 personnel, though the fire will likely continue burning into October. He estimated it is about 35 percent contained.

Crews will continue to monitor the human-caused blaze and mop up its southern flank, where a recent burnout occurred.

"Today has been real quiet," Cross said Monday evening. "The wind is kicking up, but I haven't seen any smoke come over the hill, so we're gearing up to demobilize most of the operation."

The fire has cost $1.7 million to fight and has forced road and trail closures in the area. They include: Alpine Trail No. 7, Trail No. 101, Trail No. 101A, Trail No. 86, Trail No. 108, Road No. 680 and Road No. 5206.

"One of the roads is so bad with rolling debris we call it the bowling alley," Cross said. "It's burning in very steep terrain."

The remaining crew will include one helicopter and one engine, Cross said. The main objective is to prevent the fire from spreading west or south.

http://missoulian.com/news/state-and-regional/fires-on-flathead-forest-g... 9/15/2014 1:35 PM Fires on Flathead forest grow slightly, expected to burn for weeks 2 of 2

"It's OK if it moves into that Spotted Bear country," he said.

Cross predicted the fire will continue to put up columns of smoke that are visible in the Flathead Valley until October.

Reporter Tristan Scott can be reached at (406) 730-1067 or at [email protected].

http://missoulian.com/news/state-and-regional/fires-on-flathead-forest-g... 9/15/2014 1:35 PM Grass fire near Rogue River threatens homes, closes part of I-5 http://impact.oregonlive.com/pacific-northwest-news/print.html?entry=/...

Grass fire near Rogue River threatens homes, closes part of I-5 The Associated Press By The Associated Press Follow on Twitter on A ugust 18, 2011 at 9:37 PM, updated September 04, 2011 at 1:47 PM

ROGUE RIVER -- An Oregon Department of Forestry spokesman says a fast-moving wildfire has raced across 300 acres of grassland near Rogue River in southern O regon, threatening at least 40 homes and briefly closing northbound lanes of Interstate 5.

Spokesman Brian Ballou said four helicopters dropped water on the flames before darkness fell Thursday night, helping to protect homes. A bout 200 firefighters and two air tankers fought the North River Road Fire as well.

Ballou said he wasn’t aware of any homes that burned although he believed some outbuildings did. No injuries have been reported.

Ballou said ground crews and bulldozers were working through the night to build fire lines.

A Jackson County sherif f’s spokeswoman said more than 50 deputies and search and rescue volunteers were helping with voluntary evacuations and roadblocks. Spokeswoman A ndrea C arlson said at least six families had left their homes.

Search and rescue crews also were helping evacuate animals.

O regon highway officials said a 10-mile stretch of northbound I-5 was closed for about an hour Thursday afternoon.

O fficials had no estimate when the fire might be contained. The fire's cause was under investigation.

-- The Associated Press

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1 of 1 9/15/2014 2:03 PM Idaho National Lab wildfire mostly contained http://impact.oregonlive.com/pacific-northwest-news/print.html?entry=/...

Idaho National Lab wildfire mostly contained The Associated Press By The Associated Press Follow on Twitter on August 27, 2011 at 9:49 AM, updated August 30, 2011 at 4:40 PM

IDA HO FA LLS, Idaho -- Fire crews say a 78-square-mile wildfire near the Idaho National Laboratory is mostly contained.

The INL said early Saturday the blaze had burned about 50,000 acres and was 90 percent contained. The wildfire was about three miles from the nearest INL facility and there is no known radiological hazard to the public .

More than 40 firefighters from the Bureau of Land Management and 31 from the INL were battling the blaze Saturday as crews worked to repair a number of power poles that had been damaged during the fire. INL facilities still have electricity, though, because of backup power supplies.

The INL said a BLM firefighter was treated for heat exhaustion on Friday.

The complex is about 28 miles west of Idaho Falls.

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1 of 1 9/15/2014 2:54 PM Lightning sparks 180 fires across Oregon, with more expected this weekend http://impact.oregonlive.com/pacific-northwest-news/print.html?entry=/...

Lightning sparks 180 fires across Oregon, with more expected this weekend Richard Cockle, The Oregonian By Richard Cockle, The Oregonian on August 25, 2011 at 10:25 PM, updated September 04, 2011 at 1:46 PM LA GRANDE – Crews are battling a 10,000-acre range fire in Wheeler County and a 1,000-acre blaze in timberland on the Warm Springs reservation Thursday after a lighting "bust" peppered O regon with more than 9,400 strikes in 24 hours.

With 90-plus-degree temperatures forecast over much of the region and more lightning expected, firefighters could be in for a busy weekend, said Mark Morrow, spokesman for the Northwest Interagency Fire Coordination Center in Portland. View full size Dania Maxwell/The Oregonian/File

"The Umpqua National Forest could get pretty active because of the number of strikes there," he said.

Lightning strikes ignited more than 17 fires on the Warm Springs reservation, the biggest being the 1,000-plus acre Webster Fire. The Warm Springs fires together are being called the High Cascades C omplex. They're not threatening any structures so far.

The Hancock Fire near the unincorporated settlement of C larno in Wheeler C ounty is burning across empty rangeland. A bout 55 children and a dozen staff members had to leave the Hancock Field Station outside Fossil on Wednesday night. O regon Museum of Science and Industry spokeswoman A ndrea Middleton said the camp staff is ready for this sort of thing, and took the kids to a campground outside Fossil, where they spent the night in tents.

In all, lightning triggered about 180 fires across the state, Morrow said. They included several small blazes in northeastern O regon's rugged Wenaha-Tucannon Wilderness that U.S. Forest Service smoke jumpers from McC all, Idaho, were fighting, said Rene C rippen, manager of the Blue Mountain Interagency Fire Dispatch Center near La Grande.

Firefighters also rappelled from helicopters onto fires near McGraw Lookout at 5,920 feet elevation overlooking Hells C anyon of the Snake River and into the Sled Springs area on the Wallowa-Whitman National Forest, she said.

More lightning is likely in eastern O regon over the next three or four days, followed by a cooling trend that could reduce the wildfire danger, she said. Lightning busts usually diminish in September, she said.

1 of 2 9/15/2014 2:08 PM Lightning sparks 180 fires across Oregon, with more expected this weekend http://impact.oregonlive.com/pacific-northwest-news/print.html?entry=/...

But with the current hot, dry weather, fire administrators are warning that so-called "sleeper" fires ignited by this week's storms might take off unexpectedly, Morrow said.

"We don't know what is going to come out of the Umpqua, and out of that whole area from Bend to Burns in central O regon," he said.

-- Richard Cockle

(The A ssociated Press contributed to this report.)

© 2014 O regonLive.com. A ll rights reserved.

2 of 2 9/15/2014 2:08 PM Lightning sparks dozen new wildfires on Crow Reservation http://missoulian.com/news/state-and-regional/lightning-sparks-dozen-n...

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Home / News / Montana & Regional Lightning sparks dozen new wildfires on Crow Reservation

August 23, 2011 9:00 am • By the Associated Press (0) Comments

BILLINGS - Crew s are fighting a dozen new w ildfires on southeastern Montana's Crow reservation after numerous lightning strikes from a w eekend thunderstorm.

The fires ranged in size from less than an acre to tw o fires estimated late Monday at 40 acres each.

Officials said one of the fires, in the Reno Creek valley, w as threating homes. That prompted tribal and federal agencies to bring in a heavy air tanker to drop retardant on the blaze.

Tw o helicopters, a hotshot fire crew and fire fighters from Big Horn County also assisted in the effort to contain that fire, know n as the Blankenship Fire.

Five of the smaller fires on the reservation have been extinguished. But tw o more w ere discovered late Monday high in the Bighorn Mountains w est of Windy Point.

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Tags Wildfires, Crow Reservation, Lightning, Reno Creek Valley, Air Tanker, Big Horn County, Southeastern Montana

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New wildfire starts near Wyoming-Montana border

AUGUST 22, 2011 7:30 PM • BY THE ASSOCIATED PRESS CRAIG, Colo. - Western wildfire officials worried Monday about low humidity and high winds expected this week as they battle several big fires and a number of smaller fires in Colorado and Wyoming, including one that grew so quickly it was detected by a satellite.

A new fire north of Cody, Wyo., near the Wyoming-Montana border dubbed the Hole in the began overnight and was visible by a weather satellite early Monday.

It was measured at 40 acres and was spreading rapidly, said Steve Segin, spokesman for the U.S. Forest Service.

Firefighters said allowing the fire to burn will help wildlife by keeping future fires at bay and allowing new vegetation to grow.

Also in Wyoming, the Red Rock fire was being allowed to burn on the Bridger-Teton National Forest about 25 miles northeast of Jackson and has blackened nearly 100 acres.

The fire danger in parts of Colorado and Wyoming was listed as high since dead fuels could ignite readily.

In northwest Colorado, about two dozen wildfires kept firefighters hopping over the weekend, including two minor fires that came close to a Shell oil and gas pumping and storage facility southeast of Rangely.

The Interagency Fire Management Unit allowed those fires to burn to remove vegetation from the area to help wildlife and protect the oil and gas facility from future fires, spokeswoman Lynn Barclay said.

"We started working on the hazardous fuel breaks around the Shell resources in 2009. This is a fire-prone area and our planning and work has helped in managing these fires," fire management officer Garner Harris said.

The largest of those fires was 50 acres.

Along the Front Range, storms Saturday night helped tamp down the Beaver Creek fire, which burned 100 acres since it began Friday in northern El Paso County.

Officials said 144 firefighters were working the fire and hoped to have it contained Monday.

The fire came within a quarter mile of some homes on Friday, but no damage or injuries were reported.

http://missoulian.com/news/state-and-regional/new-wildfire-starts-near-... 9/15/2014 2:10 PM Smoke plumes from Idaho prescribed fires visible from Missoula, Bitterr... http://missoulian.com/news/state-and-regional/smoke-plumes-from-idah...

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Home / News / Montana & Regional Smoke plumes from Idaho prescribed fires visible from Missoula, Bitterroot valleys

August 24, 2011 9:16 pm • Missoulian (0) Comments

Smoke plumes visible from the Missoula and northern Fire crews corral flank of West Bitterroot valleys Wednesday night w ere from prescribed Riverside blaze before fires ignited recently - and being allow ed to burn - thunderstorms directly to the w est in Idaho. Authorities are seeking Meteorologists at the National Weather Service in Missoula pinpointed the sources as the Pollock Ridge inf ormation about the suspicious prescribed fire on the Clearw ater National Forest, due cause of the f ire, which has w est of Missoula, and the O'Hara Creek prescribed fire burned at least 2,000 acres and on the Nez Perce National Forest, just southw est of threatened more than 40 … Read Pollock Ridge. more

The Pollock Ridge fire w as ignited on Aug. 12 and w ill be allow ed to burn until it is extinguished by rain and snow later in the year. It is expected to burn about 1,000 acres.

The fires are in areas that received 140 percent of average precipitation this year, and w here bugs have killed w ide sw aths of the forest - creating a w ildfire danger.

The O'Hara Creek burn is on the Creek Ranger District of the Nez Perce National Forest, and w as ignited on Aug. 15.

It, too, w ill be allow ed to burn until extinguished by rain and snow later in the year.

The O'Hara Creek fire is expected to burn about 1,000 acres of forest.

At the Weather Service office in Missoula, meteorologists w ere able to trace Wednesday night's smoke to those tw o fires. The upper-level air flow , they said, w as southw est-w est, blow ing the smoke directly into Missoula.

1 of 2 7/14/2014 4:36 PM Smoke plumes from Idaho prescribed fires visible from Missoula, Bitterr... http://missoulian.com/news/state-and-regional/smoke-plumes-from-idah...

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Tags Missoula County Montana, Ravalli County Montana, National Weather Service, Disaster_accident, Environment, Clearwater National Forest, Nez Perce National Forest, Wildfire, Controlled Burn

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Home / News / Local Smoke plumes visible from Missoula are from Idaho burns

August 24, 2011 8:12 pm • By the Missoulian (0) Comments

Smoke plumes visible from the Missoula and northern Bitterroot valleys Wednesday night w ere from prescribed fires ignited recently - and being allow ed to burn - directly to the w est in Idaho.

Meteorologists at the National Weather Service in Missoula pinpointed the sources as the Pollock Ridge prescribed fire on the Clearw ater National Forest, due w est of Missoula, and the O'Hara Creek prescribed fire on the Nez Perce National Forest, just southw est of Pollock Ridge.

The Pollock Ridge fire w as ignited on Aug. 12 and w ill be allow ed to burn until it is extinguished by rain and snow later in the year. It is expected to burn about 1,000 acres.

The fires are in areas that received 140 percent of average precipitation this year, and w here bugs have killed w ide sw aths of the forest - creating a w ildfire danger.

The O'Hara Creek burn is on the Moose Creek Ranger District of the Nez Perce National Forest, and w as ignited on Aug. 15. It, too, w ill be allow ed to burn until extinguished by rain and snow later in the year.

The O'Hara Creek fire is also expected to burn about 1,000 acres of forest.

At the Weather Service office in Missoula, meteorologists w ere able to trace Wednesday night's smoke to those tw o fires. The upper-level air flow , they said, w as southw est-w est, blow ing the smoke directly into Missoula.

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Tags Smoke, Missoula Valley, Idaho Prescribed Burns, Clearwater National Forest, Nez Perce National Forest, O'hara Creek, Missoula, Pollock Ridge

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Home / News / Montana & Regional Spread of 19,000-acre Bitterroot blaze slows

August 24, 2011 10:45 pm • By DAVID ERICKSON Ravalli Republic (0) Comments

HAMILTON - The spread of the Saddle fire southw est of Fire crews corral flank of West Painted Rocks State Park on the Montana/Idaho border Riverside blaze before slow ed considerably on Wednesday, although hot dry thunderstorms conditions and low visibility due to smoke continued to Authorities are hamper any efforts by firefighters to contain the blaze. seeking

On Monday, a w ind event caused the fire to make an inf ormation about the suspicious incredible 17,000-acre run and filled the southern cause of the f ire, which has Bitterroot Valley w ith a layer of smoke that has lingered burned at least 2,000 acres and through the w eek. threatened more than 40 … Read more On Wednesday, Bitterroot National Forest Fire Management Officer Rick Floch said the fire, w hich is still zero-percent contained, had grow n to about 19,275 acres, although lookouts w ere having a hard time gauging the fire because they couldn't see through the smoke.

"Basically, the fire grew by 1,000 acres today, and that w as from spot fires out in front of the fire from the w ind event, starting to burn around themselves and joining the main fire," he said. "Today w as a really good burn day in terms of temperature and humidity. It's really dry, w ith low relative humidity, and the fire is burning actively. It's really smoky, w hich means the w ind isn't picking up."

It w as confirmed during a helicopter reconnaissance flight on Tuesday morning that no structures w ere lost on Monday during the big run.

Floch said that the fire is beginning to burn upslope into areas w here the w ind pushed it on Monday.

"In a w ind-driven event, the fire just goes in one direction," he explained. "It doesn't matter if it's upslope or dow nslope - if the w ind is going east then the fire goes east. But w hen the w ind dies dow n, the fire goes upslope. So w here the smoke is coming from today is the fire burning upslope, going up and coming back from areas it w as pushed by the w ind."

Officials have begun setting up a large fire camp near Coal Creek Road, on private land past

1 of 2 7/14/2014 4:34 PM Spread of 19,000-acre Bitterroot blaze slows http://missoulian.com/news/state-and-regional/spread-of--acre-bitterroot-...

Painted Rocks State Park. He said that the low visibility w as forcing firefighters to remain extremely cautious about venturing into the mountains.

"The firefighters can only see a couple hundred yards at most," he said. "It's really smoky. The lookouts can't look into it any more, so it's impossible for them to judge the size of the fire accurately. We can't fly retardant planes or helicopters either."

The terrain that is burning, in both the Bitterroot National Forest in Montana and the Frank Church-River of No Return Wilderness in Idaho, hasn't been impacted by fire in more than 100 years. The Saddle fire w as sparked by lightning on Aug. 18.

Floch said the terrain is especially difficult for firefighters to access.

"It's steep country, tough to get to," he said. "There are a lot of snags because of beetle-killed trees, w hich also causes problems because the fire burns into crow ns quicker and throw s embers farther. We're not out of the w oods yet. It's not safe right now , so w e are focusing on protecting structures."

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Tags Saddle Fire, Disaster_accident, Firefighter, Montana, Wildland Fire Suppression, Environment, Hamilton, Bitterroot National Forest, Frank Church, River Of No Return Wilderness

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2 of 2 7/14/2014 4:34 PM Threat of wildfires to rise along with the thermometer early next week http://impact.oregonlive.com/pacific-northwest-news/print.html?entry=/...

Threat of wildfires to rise along with the thermometer early next week Stuart Tomlinson | [email protected] By Stuart Tomlinson | [email protected] Email the author | Follow on Twitter on A ugust 17, 2011 at 2:29 PM, updated September 04, 2011 at 1:47 PM The number of wildfires in O regon and Washington in 2011 is dramatically lower than last year at this time, but fire officials say that could all change this weekend and early next week.

Red f lag warnings are flying in both Eastern Washington and C entral and Eastern O regon in anticipation of much hotter temperatures, low humidity, breezy winds and the chance for sporadic lightning strikes.

"C onditions in the forests and rangelands of View full size Thomas Boyd/The Oregonian The Rooster Rock fire southeast of Sisters lights up the sky last central O regon are extremely dry," said August in the Deschutes National Forest. Last year's fire season George Ponte, the central O regon forester for was less intense than in previous years, but officials say dry forest conditions could spark this year's season to life early next week. the Oregon Dept. of Forestry. "A n errant cigarette, an unattended campfire or a lightning strike could easily ignite a large fire."

Ponte said long range forecasts show an increasing danger of forest fires in a season that has considerably calmer than last year.

The number of fires on state-protected land is dramatically below the ten year average, officials said. Since January 1,30 lightning caused fires have burned through just 81 acres, with 254 human-caused fires burning through 155 acres.

The ten year average by this time of the year is 255 lightning caused fires burning through 20,485 acres, and 469 human-caused fires burning through 2,713 acres, O DF officials said.

"We've been extremely fortunate so far this season in that we've not had any catastrophic fires and we'd like to keep it that way," Ponte said. "Large fires threaten public and firefighter safety, destroy property and natural resources, and are extremely expensive to suppress, and that hits everybody in the pocketbook.”

O n federally protected land there has been a total of 916 fires, compared to 1,387 this time last year. O f those 916 fires, 233 were sparked by lightning, and 683 were deemed human-caused blazes.

Jeree Mills, spokeswoman for the Northwest

1 of 3 9/15/2014 2:21 PM Threat of wildfires to rise along with the thermometer early next week http://impact.oregonlive.com/pacific-northwest-news/print.html?entry=/...

Interagency Coordination Center in Portland, which coordinates resources for O regon and Washington wildland fires on federal lands, said both this year and last year were relatively mild fire seasons compared to 2008.

By August 16, 2008, 1,071 lighting caused fires had burned through 110,577 acres, more than twice the 49,096 acres burned this year.

“We’ve had a good fire season, and that’s a good thing,’’ Mills said. “We’ve had little fires here and there but the timber has been too damp to support a large fire.”

State and federal officials are cautioning

Total fires and their causes on federal lands in O regon recreational users of the state and federal and Washington through A ug. 16 of 2010 and 2011. lands to be extra careful in the coming weeks

Northwest Coordination Center as fire danger increases.

"I would recommend that even if campfires are

allowed, keep it very small, and then put it out by drowning it with water, stirring the coals, and drowning it again,’’ said said Mary Ellen Holly, president and CEO of the Keep O regon Green A ssociation. “Keep doing that until you're absolutely sure that the campfire isn't O regon's next wildfire. Just a little bit of wind, which often comes up in the afternoons, can re-ignite small embers."”

The following restrictions are currently in effect on private and public lands protected by ODF:

- Smoking is prohibited while traveling in the fores t - O pen fires are prohibited except in Fire season through A ugust 16, 2008 was much more designated areas active than during the same period this year. - Mowing of dried grass with power equipment Northwest Coordination Center is prohibited between hours of 10 a.m. and 8 View full size p.m. - The use of timber harvesting or forest fuel-reduction equipment using high-speed rotary heads or flails is prohibited between 1 p.m. and 8 p.m.

2 of 3 9/15/2014 2:21 PM Threat of wildfires to rise along with the thermometer early next week http://impact.oregonlive.com/pacific-northwest-news/print.html?entry=/...

- The cutting, grinding, or welding of metal is prohibited between 1 p.m. and 8 p.m. When conducting these activities during permissible times, the area must be cleared of flammable vegetation.

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3 of 3 9/15/2014 2:21 PM West Riverside fire: Slurry bombers, helicopters, ground crews fight back 1 of 2

West Riverside fire: Slurry bombers, helicopters, ground crews fight back

AUGUST 23, 2011 11:00 PM • BY ROB CHANEY OF THE MISSOULIAN WEST RIVERSIDE - Black fingers of scorched rock showed where Monday night's forest fire nearly crept into people's backyards on Tuesday morning, while towers of smoke on the hillsides hinted at where the 2,000-acre West Riverside fire was headed next.

"We got lucky," said Bret Hitshew, who was visiting friend Willy Lovell on Bear Lane Monday night when they noticed fire in the trees and mountainside above West Riverside. "It didn't come into the treetops. The wind didn't pick up. But when I went up into the rockslides, the fire was already around the backside of the hill. When I called 9-1-1, nobody even knew it was burning there."

Firefighters concentrating on the west end of the small community discovered that flying embers had spread east across the steep slopes. Then around 3 a.m., downslope winds began pushing the flames toward homes at the base of the hill.

"I was the first one to pull up (Monday) and I thought, ‘We can put a stop to this,' " Missoula Rural Fire Capt. Blaine Cowan said Tuesday morning. "In 20 minutes - pow - it was going both directions. We worked hard on it all night. The winds shifted during the evening and it started creeping back down. It hits the sides of the canyon and bounces to the other sides."

The wildfire started about 6 p.m. Monday in the timber just above the Greenland trailer court in West Riverside, about five miles east of Missoula. Its cause is still undetermined.

By 9:30 p.m., it had reached the top of Woody Mountain. Observers on Missoula's Mount Jumbo saddle saw it race to the mountaintop in a fierce five-minute rush.

Cowan said Tuesday's firefighting plan was to keep the fire from going over the ridge above West Riverside, "and to keep it from coming back down again." Dozens of yellow-shirted firefighters were spraying and spading the dirt where West Riverside's homes abut the mountain, some within 10 feet of lawns and fences.

"Those afternoon winds are going to wreak havoc when they come," Cowen predicted. "The DNRC guys really did a good job. They worked their butts off keeping it out of the structures last night."

The Montana Department of Natural Resources and Conservation and Missoula Rural Fire are

http://missoulian.com/news/local/west-riverside-fire-slurry-bombers-hel... 9/15/2014 2:23 PM West Riverside fire: Slurry bombers, helicopters, ground crews fight back 2 of 2

sharing command of the fire, considered 10 percent contained as of Tuesday evening. The Missoula team is responsible for home protection and DNRC is working with the on the hillsides.

In addition to the roughly 40 homes threatened along the Clark Fork River, several more could be at risk in the Blackfoot River Canyon if fire intensity increases there.

The blaze was estimated at 2,000 acres Tuesday afternoon, and fire officials said it hadn't expanded much after its Monday night rush.

"The Lolo Hotshots made really good progress on the left flank of the fire," information officer Terina Mullen said on Tuesday evening. "It pushed the fire to top of the ridge and then spotted to Johnson Creek, but that's looking good, too. They've got dozer line around 70 percent of that spot."

Throughout the day, two Neptune Aviation P2-V air tankers took turns laying stripes of retardant along the ridge above West Riverside to block a possible move by the fire west toward Marshall Canyon. Helicopters were dipping buckets in the Clark Fork near Canyon River Golf Course and on the Blackfoot at Marco Flats Fishing Access to pour on flames.

"We have more aircraft on order that you should be seeing in the next day," Mullen said. She added that flight officers were concerned that many river floaters were passing through the pools where helicopters dipped their buckets, but no plans are in place to restrict the rivers yet.

Wednesday's forecast for fire weather is bad. The Missoula Valley should see high temperatures in the 90s with relative humidity around 4 percent. On top of that, there's a good chance the area will get some dry thunderstorms moving through. Those will bring lots of gusty wind and lightning, but little or no rain, Mullen said.

"When we get those conditions lined up with all those dry fuels out there," Mullen said, "people can guess what can happen."

Reporter Rob Chaney can be reached at 523-5382 or at [email protected].

http://missoulian.com/news/local/west-riverside-fire-slurry-bombers-hel... 9/15/2014 2:23 PM Wind, lightning push wildfires across Montana http://missoulian.com/news/state-and-regional/wind-lightning-push-wildf...

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Home / News / Montana & Regional Wind, lightning push wildfires across Montana

August 24, 2011 7:15 am • By the Associated Press (0) Comments

BILLINGS - High temperatures, low humidity and steady w inds helped a w ildfire in southeastern Montana spread to more than 5,000 acres Tuesday, prompting evacuations near Lame Deer.

Fire officials say the blaze is about half a mile north of the tow n on the Northern Cheyenne Indian Reservation. Marilyn Krause, a spokesw oman for the Northern Rockies Type II incident management team, said the fire is not contained and is among five burning in the area.

She said mandatory evacuations have been ordered northw est of Lame Deer, but she did not know how many homes or people w ere affected.

Also in Rosebud County, three lightning-caused fires about 30 miles south of Ashland in the Custer National Forest had scorched about 8,300 acres by about 10 p.m. Tuesday.

The latest string of w ildfires in the state comes after a relatively quiet fire season due to a w et, cool spring.

Firefighters on Tuesday w ere unable to contain a blaze that had burned 2,000 acres east of Missoula, but officials said they believe the threat to nearby homes had been reduced. Crew s w ere putting out hot spots and patrolling the area near the 40 threatened West Riverside homes about seven miles east of Missoula near the confluence of the Blackfoot and Clark Fork rivers.

No evacuations have been ordered and no structures have been damaged. Incident commander Ken Parks said in a statement the imminent threat to the homes has been greatly diminished.

Fire officials said Tuesday afternoon the blaze had not expanded much since its rapid spread Monday night, w hen it increased from 150 acres to 1,500 acres w ithin a matter of hours.

Meanw hile, tw o fires, at 2,800 and 1,350 acres, respectively, w ere burning in the Flathead National Forest, but both w ere in remote areas. Another w ildfire in northeastern Idaho spread to 18,275 acres and crossed the Montana line into Ravalli County, officials said.

That fire threatened seven homes, tw o commercial properties and several outbuildings.

In southeastern Montana, crew s w ere fighting a dozen new w ildfires on the Crow reservation after numerous lightning strikes from a w eekend thunderstorm. The largest burned 775 acres of

1 of 2 7/14/2014 4:41 PM Wind, lightning push wildfires across Montana http://missoulian.com/news/state-and-regional/wind-lightning-push-wildf...

grass and sage northw est of St. Xavier, w hile another in the Reno Creek valley w as threatening homes.

Copyright 2014 The Associated Press. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.

Tags Wind, Lightning, Wildfires, Fire Season, Montana Wildfires, Cheyenne Indian Reservation, Lame Deer, Marilyn Krause

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2 of 2 7/14/2014 4:41 PM APPENDIX B: PUBLIC COMMENTS

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Subject: August 26, 2011 One-Hour Ozone Exceptional Event Technical Support Document

From: Doug Boyer ([email protected])

To: [email protected];

Date: Thursday, August 7, 2014 4:16 PM

Hello everyone,

The public is invited to comment on a proposed data flag for one-hour ozone measured at a Houston- Galveston-Brazoria monitor on August 26, 2011.

In accordance with federal regulations, the demonstration document supporting the TCEQ's exceptional event flag for a one-hour ozone exceedance at the Houston East monitor on August 26, 2011 is provided through the link below for public review and comment. The proposed flag is for the exceedance caused by large wildfire plumes from the Northwestern and Southeastern United States, which are described in more detail in the demonstration document.

The TCEQ is accepting comments on the proposed flag and will forward the comments to the EPA for consideration. The EPA will review this demonstration document along with any comments and accept or reject the proposed flag. If EPA concurs, the flagged data will be removed from consideration for determination of compliance with the one-hour ozone NAAQS.

Comments should be submitted by e-mail to [email protected] with “Ozone Flag” as the subject. Comments will be taken until 5 p.m. on September 8, 2014.

• Houston East (CAMS1) Monitoring Site August 26, 2011 Exceptional Events Demonstration Package

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SIP Hot Topics

Hot topics related to Texas' State Implementation Plan (SIP) for air quality. (Last updated 8/11/14)

August 26, 2011 One-Hour Ozone Exceptional Event Technical Support Document The public is invited to comment on proposed data flags for one-hour ozone measured at Houston/Galveston/Brazoria monitors on August 26, 2011.

In accordance with federal regulations, the demonstration document supporting the TCEQ's exceptional event flags for a one-hour ozone exceedance at the Houston monitor on the date referenced above. The document is provided through the link below for public review and comment. The proposed flag is for the exceedance caused by large wildfire plumes from the Northwestern and Southeastern United States and descriptions are described in more detail in the demonstration document.

The TCEQ is accepting comments on the proposed flags and will forward these comments to the EPA for consideration. The EPA will review this demonstration document along with any comments received and decide whether to accept or reject the proposed flag. The data with flags where EPA concurs will be removed from consideration for determinations of compliance with the one-hour ozone NAAQS.

Comments should be submitted by e-mail to [email protected] with “Ozone Flag” as the subject. Comments will be taken until 5 p.m. September 8, 2014.

Houston East (CAMS1) Monitoring Site August 26, 2011 Exceptional Events Demonstration Package

Emissions Inventory (EI) SIP Revision for the 2008 Eight-Hour Ozone Standard for the Houston-Galveston-Brazoria (HGB) and Dallas-Fort Worth (DFW) Areas On July 2, 2014, the commission adopted the EI SIP revision for the 2008 Eight-Hour Ozone Standard (Non- Rule Project No. 2013-016-SIP-NR). This SIP revision satisfies the Federal Clean Air Act (FCAA), §172 and §182 requirements for the HGB and DFW nonattainment areas under the 2008 eight-hour ozone standard. The SIP revision includes 2011 emissions inventories for ozone precursors (volatile organic compounds and nitrogen oxides) from point, area, on-road mobile, non-road mobile, and biogenic emissions source categories as the base year emissions inventories for the HGB and DFW areas.

For additional information, please visit the Air Pollution from Ozone Web page.

2014 Five-Year Regional Haze SIP Revision On February 26, 2014, the commission adopted the 2014 Five-Year Regional Haze SIP Revision (Project No. 2013-013-SIP-NR). This SIP revision evaluates Texas' progress towards the reasonable progress goal for each Class I area located within the state and in each Class I area outside the state which may be affected by emissions from within the state. The TCEQ projects that Texas will meet the established reasonable progress goals set by the state for 2018 for all Class I areas it affects.

SIP Revision For additional information and the complete SIP package, including appendices, please visit the SIP Revision: Regional Haze Web page.

Inspection and Maintenance (I/M) Rulemaking and SIP Revision On February 12, 2014, the commission adopted amendments to Sections 114.1, 114.2, 114.21,114.50, 114.53, 114.82, 114.83, 114.84, and 114.87 of 30 TAC Chapter 114, Control of Air Pollution from Motor Vehicles (Rule Project No. 2013-035-114-AI) and the corresponding SIP revision (Non-rule Project No. 2013-041-SIP-NR). The rulemaking and corresponding SIP revision implement House Bill 2305 from the 83rd Texas Legislature, 2013, Regular Session, relating to replacing the dual windshield sticker system for vehicle inspection and registration with a single windshield sticker system and modifying the method used to collect the state portion of the vehicle safety and emissions inspection fee.

For additional information and the complete rule and SIP packages, please visit the Vehicle Inspection and Maintenance (I/M) Program Web page.

PM Data: El Paso 2010, 2011, and 2012 Exceptional Events Demonstrations In accordance with federal regulations, the demonstration documents supporting the TCEQ's exceptional event flags for El Paso PM10 and PM2.5 data for 2010, 2011, and 2012 were provided for public review and comment.

There are three PM10 and ten PM2.5 proposed exceptional event flags for data collected at various El Paso monitoring sites on ten separate days from 2010 through 2012. All thirteen of the proposed flags are for high wind regional blowing dust events that are described in more detail in the demonstration document.

The public comments received by the TCEQ were forwarded to the EPA for consideration. The EPA will consider information provided in these demonstration documents and public comments when deciding whether to accept or reject each proposed flag. The EPA concurrence on a flag will remove the data from consideration for determinations of compliance with the revised primary annual PM2.5 NAAQS for the period 2010 through 2012.

El Paso 2010-2012 Particulate Matter Exceptional Events Document

For more information, please visit the TCEQ's Air Monitoring Web page for PM flags: Particulate Matter (PM) Proposed Exceptional Event Flag Demonstrations.

Commission Approved Recommended Designations for the 2012 Primary Annual

PM2.5 NAAQS On October 23, 2013 the commission approved the executive director's designation recommendations for the

2012 primary annual fine particulate matter (PM2.5) National Ambient Air Quality Standard (NAAQS). The recommended designations will be provided to the governor for his consideration along with the basis for the recommendation. The governor will submit the state’s designation recommendation to the United States Environmental Protection Agency (EPA) by December 13, 2013.

PM2.5 State Area Designation Recommendation For additional information, please visit the Air Pollution from Particulate Matter Web page. PM2.5 Data: Houston 2010, 2011, and 2012 Exceptional Events Demonstrations In accordance with federal regulations, the demonstration documents supporting the TCEQ's exceptional event flags for Houston's Clinton Drive PM2.5 monitoring data for 2010, 2011, and 2012 were posted for the 30-day public review and comment periods. The exceptional event flags are for: June 9, 10, and July 13, 2010; May 20, 2011; and July 2, 27, and 28, 2012. All three of the 2010 flags are for African dust events. The 2011 flag is for a Mexican and Central American smoke event, and all three of the proposed flags in 2012 are for African dust events. These events are described in more detail in the demonstration documents.

The public comments received by the TCEQ were forwarded to the EPA for consideration. The EPA will consider information provided in these demonstration documents and public comments when deciding whether to accept or reject each proposed flag. The EPA concurrence on a flag will remove the data from consideration for determinations of compliance with the revised primary annual PM2.5 NAAQS for the period 2010 through 2012.

Houston PM2.5 2010 Exceptional Events Demonstration

Houston PM2.5 2011 Exceptional Events Demonstration

Houston PM2.5 2012 Exceptional Events Demonstration For more information, please visit the TCEQ's Air Monitoring Web page for PM flags: Particulate Matter (PM) Proposed Exceptional Event Flag Demonstrations

Public Information Meetings in Houston and El Paso Regarding Area Designations under the 2012 Primary Annual PM2.5 NAAQS

The TCEQ held public information meetings regarding area designations under the 2012 primary annual PM2.5 NAAQS in Houston on July 22, 2013 and in El Paso on September 17, 2013. TCEQ staff presented an overview of the 2012 PM2.5 NAAQS, current monitoring data for the State of Texas, exceptional events, and the process for state designation recommendations to the EPA.

For more information, please visit the Air Pollution from Particulate Matter Web page.

Public Information Meeting: Eight-Hour Ozone Planning for the DFW Area The TCEQ held a public information meeting to provide information on the development of revisions to the SIP for the 2008 ozone NAAQS in the 10-county Dallas-Fort Worth (DFW) nonattainment area. NCTCOG and EPA representatives provided updates on local and federal initiatives.

For more information on ozone planning for the DFW area, please visit the TCEQ’s Dallas-Fort Worth and the State Implementation Plan Web page.

Stage I Stakeholder Meetings scheduled for April 29 – May 16, 2013 The TCEQ scheduled Chapter 115 Stakeholder Group meetings regarding potential revisions to Stage I testing requirements for gasoline dispensing facilities. Stakeholder meetings were held in Austin, Corpus Christi, El Paso, Houston, Plano, Arlington, and Longview. The purpose of these stakeholder meetings was to discuss potential revisions to testing requirements and methods to ensure there are no leaks in the Stage I petroleum storage tank’s vapor recovery system. For additional information, please visit the Chapter 115 Stakeholder Group Web page.

Infrastructure and Transport SIP Revision for the 2010 SO2 NAAQS

On April 23, 2013, the commission adopted the Federal Clean Air Act (FCAA), §110(a)(1) and (2) Infrastructure and Transport SIP Revision for the 2010 Sulfur Dioxide (SO2 ) NAAQS (Project No. 2012-022-SIP-NR).

SIP Revision

For additional information, please visit the Air Pollution from SO2 Web page.

HGB 1997 Eight-Hour Ozone Standard MVEB SIP Revision On April 23, 2013, the commission adopted the Houston-Galveston-Brazoria (HGB) 1997 Eight-Hour Ozone Standard Nonattainment Area Motor Vehicle Emissions Budgets (MVEB) Update SIP Revision (Project No. 2012- 002-SIP-NR).

SIP Revision For additional information and the complete SIP package, including appendices, please visit the HGB: Latest Ozone Planning Activities Web page.

Infrastructure and Transport SIP Revision for the 2008 Ozone NAAQS On December 5, 2012, the commission adopted the FCAA, §110(a)(1) and (2) Infrastructure and Transport SIP Revision for the 2008 Ozone NAAQS (Project No. 2012-004-SIP-NR).

SIP Revision For additional information, please visit the Air Pollution from Ozone Web page.

BPA Attainment Area On-Road Mobile Source Emissions Inventory and MVEB Update SIP Revision On November 14, 2012, the commission adopted the Beaumont-Port Arthur (BPA) Attainment Area On-Road Mobile Source Emissions Inventory and Motor Vehicle Emissions Budget (MVEB) Update SIP Revision (Project No. 2012-005-SIP-NR).

SIP Revision For additional information, please visit the Beaumont-Port Arthur: Ozone, Latest Planning Activities Web page.

DRAFT SIP Timeline - Estimated Dates and Activities 2014 through 2015 This draft timeline reflects the ongoing SIP revision activities that will continue through 2015.

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From: [email protected] Sent: Monday, September 08, 2014 4:51 PM To: amda Cc: [email protected]; [email protected] Subject: Ozone Flag

Dear Sir or Madam:

The 8-Hour Ozone SIP Coalition appreciates the opportunity to comment on the proposed data flags and exceptional event demonstration prepared by TCEQ regarding the 1-hour ozone exceedance at the Houston East monitoring site on August 26, 2011. The Coalition is a group of companies in the energy industry with the common goals of clean air and a strong economy for Texas. The Coalition’s members have invested over $2 billion in start of the art emissions controls since 2001.

The Coalition supports TCEQ’s proposed data flags and exceptional events demonstration document, which we believe meets all applicable legal requirements under the exceptional events rule. This demonstration is significant, as it shows that the Houston-Galveston-Brazoria area would have attained the 1-hour ozone standard as of the 2009-2011 and 2010-2012 averaging periods but for exceptional events. We also support continued analysis of potential exceptional events as ozone levels in the Houston-Galveston-Brazoria area continue to decline toward the lower 8-hour federal ozone standards.

Regards,

Zachary L. Craft Baker Botts L.L.P. One Shell Plaza 910 Louisiana Street Houston, Texas, 77002 713.229.1133 713.229.7933 (fax) [email protected] From: Texas Commission on Environmental Quality [ mailto:[email protected] ] Sent: Thursday, August 07, 2014 4:27 PM To: Craft, Zach Subject: August 26, 2011 One-Hour Ozone Exceptional Event Technical Support Document

The public is invited to comment on proposed data flags for one-hour ozone measured at Houston/Galveston/Brazoria monitors on August 26, 2011.

In accordance with federal regulations, the demonstration document supporting the TCEQ's exceptional event flags for a one-hour ozone exceedance at the Houston monitor on the date referenced above. The document is provided through the link below for public review and comment. The proposed flag is for the exceedance caused by large wildfire plumes from the Northwestern and Southeastern United States and descriptions are described in more detail in the demonstration document.

The TCEQ is accepting comments on the proposed flags and will forward these comments to the EPA for consideration. The EPA will review this demonstration document along with any comments received and decide whether to accept or reject the proposed flag. The data with flags where EPA concurs will be removed from

1 consideration for determinations of compliance with the one-hour ozone NAAQS. Comments should be submitted by e-mail to [email protected] with “Ozone Flag” as the subject. Comments will be taken until 5 p.m. September 8, 2014.

August 26, 2011 One-Hour Ozone Exceptional Event Technical Support Document

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2 Comments on the Houston East (CAMS 1) Monitoring Site August 26, 2011 Exceptional Events Demonstration Package, August 5, 2014

Albert Hendler, Austin Texas September 8, 2014

TCEQ’s August 5, 2014 Exceptional Event Demonstration shows that the exceedance of the 1-hour ozone NAAQS at the Houston East Monitoring Site (AQS # 48-201-1034) on August 26, would not have occurred but for the influence of wildland fires in upwind states. The package that TCEQ prepared is consistent with the requirements of a successful exceptional event technical demonstration as described in EPA guidance (http://www.epa.gov/ttn/analysis/docs/exceptevents_guidememo_130510.pdf) and at least as compelling as the exceptional events demonstration for four days in April 2011 that was submitted by Kansas in November 2012 (http://www.epa.gov/ttn/analysis/docs/KDHE_ExEvents_final_042011.pdf) and approved by EPA Region 7 in December 2012 (http://www.epa.gov/ttn/analysis/docs/Flint_Hills_Concurrence_Letter_dated_12-28-12.pdf).

The TCEQ demonstration is also an important addition to the conceptual model for high ozone in HGB as August 26, 2011 was one of the more obvious cases of wildland fire contributions to HGB nonattainment of several that have occurred in recent years. High background ozone levels (e.g., above 60 ppb) have frequently been observed in the air transported to HGB on high ozone days; however, no detailed source apportionment or analysis of the background ozone has ever been published. TCEQ should consider adding an analysis of background ozone on August 26, 2011 to the exceptional event demonstration as well as to the HGB conceptual model for high ozone. A statistical analysis of HRVOC levels might also help assess the relative contributions of transported and locally produced ozone on August 26, 2011.