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National Park Service U. S. Forest Service Bureau of Land Management U. S. Fish & Wildlife Service

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National Park Service U. S. Forest Service Bureau of Land Management U. S. Fish & Wildlife Service. Problem Statement. Problem Statement.

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National Park Service

U. S. Forest Service

Bureau of Land Management

U. S. Fish & Wildlife Service


Problem Statement

Problem Statement

Decades of research and monitoring results confirm natural resources on federally managed lands in California are being adversely impacted by ozone air pollution.


Problem Statement

Problem Statement

  • Ozone injury to ponderosa and Jeffrey pines has been extensively documented in national parks and forests in California, including:
    • 100% of pines sampled in the San Bernadino Mts.
    • 93% of pines in some areas of Sequoia National Park
    • 88% of pines in some areas of Yosemite National Park
Chlorosis- bleaching or yellowing of pigment

Stipple - accumulations of pigment; often small dots; visible on upper leaf surface

Fleck - cell death in palisade layer; visible only on upper surface

Bi-facial necrosis - cell death in palisade and spongy mesophyll; visible on both surfaces

Visible Ozone Injury Symptoms


Red Alder

Quaking Aspen

Blue Elderberry


Healthy ponderosa

pine (right)


Ozone damaged ponderosa pine (left)


PhysiologicalEffects of Ozone

  • Reductions in photosynthetic rate
  • Early needle loss
  • Diminished annual ring growth
  • Decreases in radial growth
  • Changes in stand composition
  • More vulnerable to mortality from insects and diseases

Plants are more sensitive than humans to ozone.

Air quality standards are not protective of vegetation.


Sierra and Sequoia NF FPM Plots

None Slight Moderate Severe Very Severe


Primary Causes of Tree DeathSierra and Sequoia National Forests (1977 – 2000)

FPM Ozone Trend Plots

Primary Cause of Death

Percent of Dead Trees

Ozone 36.5

Bark beetles, wood borers 27.9

Fire damage 15.4

Broken top 9.6

Dwarf mistletoe 5.8


Problem Statement

Problem Statement

The extent and severity of ozone damage to federal natural resources in California is in conflict with Congressional direction to FLMs to sustain healthy ecosystems.


FLM Responsibilities

  • Clean Air Act
    • FLM has “an affirmative responsibility” to protect resources that may be adversely affected by a change in air quality
  • Wilderness Act
    • Directs FLMs to administer wilderness areas “in such a manner as will leave them unimpaired for future use and enjoyment as wilderness”

FLM Responsibilities

  • Organic Acts
    • NPS Organic Act: ... manage parks to “leave them unimpairedfor…future generations”
    • National Wildlife Refuge System Improvement Act: ... maintain “the biological integrity, diversity, and environmental health of the [Refuge] System… for the benefit of present and future generations of Americans.”

FLM Responsibilities

  • National Forest Management Act:

“National Forests are ecosystems and their management for goods and services requires an awareness and consideration of the interrelationships among plants, animals, soil, water, air, and other environmental factors within such ecosystems.”


State Responsibilities

  • SIPs for Nonattainment Areas
    • New non-attainment area State Implementation Plans are being developed for:
      • Ozone
      • PM2.5
      • Regional Haze
  • Control measures will result in lower Ozone concentrations and hopefully a sigh of relief for vegetaton

FLMs Responsibilities

Conformity Determination

NEPA Documentation process

PSD Permit Review

New Tools

Collaboration with Research and Regulatory Agencies


FIA Ozone Bio-

monitoring sites

in California –


(Red dots are

positive for ozone)


Interagency Participation

The FLM agencies have been working to develop nationally consistent criteria and guidance to evaluate air pollution impacts to natural resources on all Federal lands. Initial criteria and guidance is published in the FLAG Phase I Report:

We hope to build off of the FLAG effort by working together to inform regulators and the public of the serious threat of ozone pollution to our Federal natural resources in California.


Current 1 hr ozone standard

non-attainment areas in CA

Proposed new 8 hr ozone non-attainment areas in CA

(State and EPA)