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Smoke Management 2018 Rulemaking

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Christopher
Adlam
OR
See attached document.
https://data.oregon.gov/views/t483-y97v/files/cf1f1128-68f8-41a1-990b-a8dbefc030b9?filename=Smoke+Management+Letter.docx
Evelina
Yoder
Oregon
My property is land locked and surrounded by unmanaged land. My ½ mile driveway is my only evacuation route and is not fire safe because the residents nor counties manage it. Rough and Ready land, recently logged and now over grown, is adjacent to my yard space. The Siskiyou National Forest is also adjacent to my property and I was one evacuated this 2018 fire. (You can understand my concern and requests.) 1) require residents or counties to maintain shared driveways which would also provide a fire break. 2) require Rough and Ready to provide and maintain an evacuation route and maintain a defensible area and/or fire break where adjacent to residential properties. 3) require Siskiyou National Forest to provide and maintain an evacuation route and a defensible area and/or fire break where adjacent to residential properties.
Holly
Hansen
OR
just seeking cleaner air. i live downtown and want the diesel fumes gone and anything else you can do to limit the health stealing air pollution of my new Portland home.
Erik
Fernandez
Oregon Wild
OR
Please accept the attached letter from Oregon Wild regarding revisions to the Smoke Management Plan.
https://data.oregon.gov/views/t483-y97v/files/4c70ff24-4eb7-421c-9a19-401fee12abb6?filename=Prescribed+Fire+Letter+of+Support+to+ODF-DEQ_DRAFT_8-15-18.pdf
Adrian
Levick
Oregon
The prolonged periods of smokiness in Portland and Eugene are exposing millions of residents to extremely poor air quality and smoke related health hazards annually, due to poor forest management and a public fear of controlled burning. Studies show these controlled burns do not lower air quality like a wildfire. Residents who live in secluded parts of the woods without adequate escape routes should know the risk that they are taking and have no right to affect policy that would improve quality of life and life expectancy for millions of residents in urban zones. Protecting the rights of relatively wealthy landowning people at the expense of diverse and lower income populations in urban zones is at best problematic and at worst emblematic of this region's history of systemic racism. My complaints are that the majority of people who this will affect will never see this announcement or have the opportunity to express their support. My complaint is that too often policy is built on comment instead of prevailing scientific evidence. This has taken at least 30 years too long. Make the changes, make them now, and please tell the wealthy owners of homes in vulnerable areas that they are fully capable of paying to add exit routes, etc, and we the people of urban zones will no longer choke on pollution they are complicit in creating.
Rachel
Winters
Or
I definitely in support of prescribed burning to prevent the buildup of fuels that cause such a huge amount of smoke along with wildfires. I do have asthma but would much prefer this better management alternative despite that.
Jonathan
Willing
Oregon
I support this rule change. I live in Ashland Oregon and the smoke this year is unbearable. We need more fire to get the wildfire under control. We must change tactics, the status quo is not working.
Gary
Holeman
N/A
Oregon
I support revising the rules to a allow more burning under proscribed conditions.
Donald
Cochran
14095 E Evans Creek Road, Rogue River, Oregon
Citizen
Oregon
Bring back logging with proper forest management and grazing to reduce fuels so the fires don't burn so hot and fast
Oregon
Sounds like a good idea to me! Better a little smoke in winter than what we have now!
shirley
nickell
1955
Oregon
We deal with private timber companies burning whenever they want during the fall and spring and I see no reason to federal or state to burn when possible. We need to take care of our over-stocked forests so i'm all for this!
Geraldine
Ventura
Oregon
I support the rewriting of the rules governing prescribed fires to provide increased forest management and strategically reducing the over-forested lands in Oregon.
https://data.oregon.gov/views/t483-y97v/files/b913e644-ee7b-41c1-a56c-3b9eb8fe5cf2?filename=OregonForestManagment.docx
https://data.oregon.gov/views/t483-y97v/files/2134b7a1-90e1-4893-95e0-66d24fa9c723?filename=support.docx
Kathryn A
Bulinski
citizen
Oregon
I support prescribed burning to reduce hazardous fire risk to our communities and public lands and resources.
Gabi
Ford
OR
Yes to more controlled burns during the rainy season.
Ted
Reiss
Self
Oregon
I am supportive of these changes to the ODF Smoke Management Plan. As a professional forester in Oregon experienced in forest management and fire fighting I see the need for increased flexibility to conduct prescribed burning in Oregon to help subdue the opportunity for wildland fire. Not all fire will be eliminated by proactive wildfire fuel reduction efforts. But many fires will burn less intense sending out less smoke during the summer and allowing wildland fire professionals better opportunity to control them. A smoke management system as described here will allow for more opportunity while keeping our air healthy. This is a positive change in ODF rules that should be lauded as an example for others to follow.
Anne
Clarke
OR
Controlled burns during optimal weather is infinitely superior to the unknowns wildfire risks both in terms of healthy/ safety and of the costs incurred.
Adam
Stinnett
Seneca Jones Timber
OR
I believe it’s time to make a change to the Oregon Smoke Management Plan. This proposed rulemaking is an excellent plan for moving forward. By providing flexibility for forest land owners to do prescribed burning while protecting public health is a win-win for everybody. Removing excess fuels protects our forests from catastrophic fires that release millions of tons of pollution. This common sense approach accomplishes this goal.
Geoff
Weaver
n/a
Oregon
Let's use common sense here rather than antiquated notions of fire suppression and unwillingness to see smoke in our skies. To limit smoke beyond state and federal clean air guidelines (e.g. visible smoke) and thus prevent or limit controlled burns that we so desperately need is incredibly short sighted and counterproductive. Those who want to limit the smoke and thus the implementation of controlled burns will suffer far worse smoke from the higher intensity wildfires that result from decades of fire suppression. And their short sightedness will inflict this impact on others who will suffer because of this lack of common sense. Look at the science - without controlled burns and in the face of climate change driven hotter, drier weather patterns we are doomed to larger and more frequent wildfires and the resultant plumes of smoke. It will take decades or even generations to right the past mistakes of fire suppression. We need to be tackling this problem today in a substantial and urgent manner so that our children or at least our grandchildren don't suffer the consequences of our short sightedness today.
Lisa
Foster
OR
I am concerned about future large wildfires and so, I support prescribed burning prevention measures. Please allow wildfires to burn when possible, and increase restoration and prevention measures to prevent future catastrophic wildfires. While a little smoke is inconvenient now, it is much preferred to destructive wildfires in the future.
Doug
Viner
OR
Regarding wildfire smoke, I strongly support *long term* approaches to this increasingly important issue. If we must suffer more smoke in the short term in exchange for a brighter tomorrow, so be it. We cannot continue to treat fires as single, short-term events. The trajectory of such short-sighted action is not good.
malcolm
drake
oregon
I am commenting on Smoke Management 2018 Rulemaking These proposed new rules (weakening air quality standards) would make a bad situation even worse. There are better ways to deal with overgrown forests. PROBLEMS WITH PROPOSAL The following statement, supposedly a "solution", appears to be short-sided: “(State Forester) Daugherty said in some cases, the new standards could be breached for one-hour periods in communities particularly vulnerable to wildfire if they develop programs to protect vulnerable populations. This includes such steps as providing community warnings of prescribed fires and indoor locations providing filtered air." First off, "one-hour"? Since when can smoke levels be predicted with that kind of accuracy? Secondly, "Vulnerable populations”? Cities throughout Oregon already regulate woodsmoke, since it’s unhealthy to ALL populations". We have had smoke warnings of "unhealthy", or worse, in areas all over the state, especially in SW areas of the state. Smoke is HAZARDOUS. When smoke is present, it WILL affect our fellow citizens. Thirdly, this statement does not address people who HAVE TO BE outside all day, or parts of days, in order to earn a living. Examples-and I'm sure we can think of others, if we put our minds to it-are farm workers; carpenters, roofers, masons, and others in the building trades; landscape workers; surveyors, road construction workers; house painters; park rangers; life guards; hydrologists/hydrologic technicians; UPS drivers; US Postal Service workers. These people cannot simply stop working, and race over to a building with filtered air. As a former carpenter/framer/general contractor, I can tell you how hard it would be to do so, even for one hour. We could le never simply leave a building site unattended, even for one hour. Tools and materials tend to grow legs! And does the mail carrier simply stop delivering mail on smoky days? ALTERNATIVE SOLUTIONS Alternative 1. A)Fight fires as we’ve done for over 100 years; readopt the USFS mantra “Every Fire Out By 10:00(a.m.)”. B) Increase readiness, increase standby fire fighting forces and equipment. Reinstate Smoke Jumpers bases. Hit fires hard and fast! C)Allow commercial trees to naturally overtake brush species; the forest will eventually recover from excess brush, if we allow commercial trees to grow, and not be killed by fires. When forests become overstocked with timber species, do some commercial thinning. D)Outlaw clear cutting, at least in dry areas, e.g. SW Oregon forests, where clearcuts almost always result in highly flammable brushfields. E) Harvest only percent of forest canopy which can be harvested without resulting in brushfields. Alternative 2. A) Everything in Alternative 1. B) Also, utilize wood chippers, slash-busters, etc. to turn undesirable understory species into mulch. Mulch -unlike fires-adds nutrients to soil, keeps soil cooler, and retains soil moisture, all of which increase rate of tree growth. C) Utilize lop-and-scatter in areas inaccessible to slash-busters, wood chippers, etc. Alternative 3 A) Everything in Alternative 1. B) Utilize Slash-Busters, Bulldozers, and/or firefighters to cut strategic firelines, for use in future wildfires. (NOT like the excessively wide fire lines used on the Biscuit Fire, the Taylor Creek Fire, the Klondike Fire, etc.) Alternative 4) A) Utilize/pay suitable prisoners who volunteer to clear brush using various hand tools. B) Require suitable recipients of unemployment insurance to work at clearing brush, in order to continue receiving benefits, while paying them a "living wage".
Mike
Supkis
La Pine Rural Fire Protection District
OR
Letter Attached
https://data.oregon.gov/views/t483-y97v/files/198a1a14-ebdc-41ca-8780-bc854e6389ec?filename=Comment+for+the+record+-+smoke+rule+making+-+La+Pine+Fire.pdf
Glen
Ardt
Oregon
https://data.oregon.gov/views/t483-y97v/files/2db41683-ebb8-41d9-865d-04583d225dd8?filename=GlenArdt.pdf
Jennifer
Porn
Oregon
I'm in favor of reevaluating the smoke management plan. I think it makes sense to use controlled fires to decrease the magnitude of wild fires.
Tim
Jensen
Oregon
I have bad asthma. I would rather have a few days of light smoke from prescribed fires than miss the entire summer because the whole state is on fire. It didn't use to be this bad in the early 90s when logging and pre-burns kept things in better check.
Angelina
McClean
Oregon
Thank you for considering the need for more prescribed burns in our forests. As a resident of the Rogue Valley, I can say communities are suffering from the extreme wildfires and unhealthy air quality. We need more prescribed burns in our forests to help them be more resilient during fire season. Decades of fuel build up after initial intense logging has left our forests lacking in large, fire resistant trees, and choked with very small trees and fuels. Allowing more prescribed burns is a much needed step in our desire for healthy, resilient forests.In Ashland, prescribed burns and the small amount of smoke they produce is a small trade off for the increased forest health and peace of mind of the citizens. Thank you.
Leslie
Edwards
n/a
OR
I'm unable to attend my local meeting, but I want to convey my strong support for modifying the existing rules to allow for more prescribed burning.
David
Powell
Citizen
Oregon
I support the proposed rule revisions, and I support additional use of prescribed fire as a forest management tool. As a member of Eastern Oregon Climate Change Coalition, a 501c3 nonprofit group, I know that eastern Oregon's fire seasons have experienced a significant trend of increasing temperatures during the summer months, and this trend is projected to worsen in coming decades as the climate continues to change. As fire seasons lengthen with warming temperatures, then periods during the year when prescribed fire would be suitable may become fewer. This means that it is even more important to have smoke management rules supporting use of prescribed fire because weather windows in which to use it will be smaller.
Rick
Sohn
Self
Oregon
Any and all rule changes which lengthen the burning season in both the spring and the fall and allow more fuel to be consumed in prescribed fire. Especially in fires associated with eco- silvicultural harvest or industrial harvest are welcome by me. The more we can reduce fuels especially in dry forest areas the better and the minor smoke intrusions from prescribed fire are far far overshadowed by the heavy intrusions in the summer. Public acceptance of smoke is going to have to happen one way or another but there will be much fewer repercussions from prescribed fire than wildfire. Thanks for the opportunity to comment.
John
Chapman
253 1/2 Ashland
Oregon
I am for relaxing smoke rules in order to remove fuel that can lead to major fires. I have asthma, and am more that willing to be inconvenienced by prescribe burns. I am also a cyclist, and hace spend a total or 4 hours on my bike in the last 4 weeks. Prior to the Carr fire, I was driving 2 hours to get to clear air.
Charles
Whitaker
Oregon
See attached document
https://data.oregon.gov/views/t483-y97v/files/b62fe182-676e-4823-ae64-ef62a252921a?filename=burns.txt
George
Myers
OR
increase mowing and thinning. decrease burning.
Marie
Reeder
OR
Thank you for this opportunity to comment. Increasing prescribed burning into Oregon's forest is our best opportunity to reduce the hazardous air quality that results from large wildland fires. As a resident of southern Oregon, I believe that smoke from wildland fires is the most oprressive effect of climate change that we are now experiencing. For the past 3 summers, August has become a new season to restrict outdoor activity. I teach a summer field biology class for the local high school, and have had problems with student exposure to smoke (and this year, evacuations due to wildfires). July and August should be the prime months for outdoor activities, so this seems particularly offensive. Besides educational events, tourism and even farmstands are negatively impacted by many weeks of unsafe air. My husband is exposed to unhealthy particulates every working day during smoke season, and suffers from coughing, inflamed eyes, and an increased susceptibility to bronchitis. As a result,we're both very concerned and believe that the best solution is increased opportunities for sontrolled burns during the winter and spring. We live less than a quarter mile from the Garner Fire complex lines and know first hand how brushy and overly dense our watershed has become.. Although we applaud the work done along roadsides and close to residential areas for fuel reduction, we have also seen how quickly brush such as poison oak grows back in after that expensive treatment is completed. So as taxpayers as well as citizens who have health concerns with smoke, we feel that increased fire prescriptions are necessary. I do think that language addressing watershed health should be added to balance the emphasis on maximizing burning for commercial timber management. I'm not convinced that huge slash piles that result from clearcuts are beneficial either for the soil, air quality, or reducing the wildfire risks for large plantations of young trees.
Charlie
Burr
Restoration Seeds
Oregon
Robert
Fossek II
OR
It has been a practice for thousands of years to burn areas when the humidity was high and the temperature low. This is a necessary component of healthy ecosystems in the Western U.S. backed by thousands of years of traditional indigenous ecological knowledge as well as modern science. The suppression of these ways in part is responsible for many of the predicaments we are in, including mega fires and our new, normal smoke season. We need to implement prescribed burns and ecological diversity in a big way.
William
Aney
Retired, USFS
OR
https://data.oregon.gov/views/t483-y97v/files/509e98d9-38b2-4057-afd8-57630a42a9ac?filename=WilliamAney.pdf
Deschutes
County
Deschutes County
OR
see attached letter.
https://data.oregon.gov/views/t483-y97v/files/1ec596a5-f3ff-4dc4-9ae2-c8b44a727068?filename=Deschutes_County_SMP_comment_letter_201808.docx.pdf
Deschutes Rural Fire Protection District #2
OR
see attached letter.
Deschutes Rural Fire Protection District #2
OR
see attached letter.
https://data.oregon.gov/views/t483-y97v/files/10385b4b-0dc8-4234-bd93-c0832b110ca2?filename=DRFPD2_SMP_comment_letter_201808.pdf
Bryce
Leppek
Oregon
I am firmly against any changes to the smoke management regulations in Souther Oregon. The rogue valley is now getting a reputation of a place to avoid in summer because of smoke. Lets not extend that beyond summer. We all need to get a break from the smoke and fires . My health has been affected the last few summers. And I am a lucky one who can hunker down with a filtered air HVAC house. I recommend more strategic use of existing forest roads made into wider and shoulder thinned logging.
richard
clayton
citizen
oregon
i fully support relaxing smoke rules in order to increase the use of prescribed fires, in particular in the fall and winter
Leigh
Ahlgren
Private Citizen
OR
I wholeheartedly (and lung-edly) support these changes. They adequately address community concerns regarding air quality by providing a clarified definition of “smoke intrusion” based on the amount of measurable pollutants over time (rather than a simple presence/absence test over the course of an hour). The community notification provisions and involvement of health authorities convince me that these changes will lead to a net decrease in the amount of smoke Oregonians have to breathe over the long term. I am curious as to why the removal of this section is proposed: “In addition, the rules apply to forestland outside any forest protection district in Oregon as described by ORS 527.620(7) at the discretion of the Oregon Department of Forestry and Department of Environmental Quality defined in a joint agreement.”
Elizabeth
Stanley
self
OR
I am horrified by the idea that controlled burns will send more smoke into our cities. Already, I suffer any time there is a controlled burn which sends smoke into Bend. WIth news reports talking about increased health problems and deaths from smoke, surely we don't need more.
Skyler
Conner-Coash
OR
Please allow these changes to the program. This can be one step in the right direction to help manage our forests and allow more control when wildfires to arise.
Alan
Mitchell
Washington
I support prescribed burning prevention measures. Let's burn out the underbrush during the Spring or Winter. Better a little smoke then, to decrease the intensity and duration of Summer wildfires.
Michelle
Clark
OR
Please do not lessen the restrictions regarding burning and smoke in our area. We have immune impaired individual living in our home and live right against logging land. We already deal with herbicides spread by helicopter, we don't need to add smoke on top of that.In general, our air quality is going down thanks to climate change. It's time to be more rigorous in protecting air quality, not less.
Stuart
Smith
-- Select --
OR
utilize fire crews and the tool of prescribed fire in the wet season to reduce fuels for next summer's fire season.
Nicolle
Aleman
Mrs.
OR
The situation with wildfire smoke has become simply untenable for Oregonians, particularly in Southern Oregon. The impact on our physical and mental health is very hard, not to mention the hit our economy takes when we are so reliant on tourism dollars during the summer months. Many residents "save" during this time to get through the dead months in winter. It's time for ODF to take some meaningful, progressive steps in thinning out the dead trees in our forests and ALSO putting out these fires when they start in the first place.
Central Oregon Fire Chief's Association
Oregon
Please see the attached letter from the Central Oregon Fire Chief's Association
https://data.oregon.gov/views/t483-y97v/files/33c42aa1-44ae-4111-b564-fe61ca49f91e?filename=COFCA+letter.pdf

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