FeatherRiverAirQualityManagementDistrictPUBLICHEARINGONTHESTATEIMPLEMENTATIONPLANSUBMITIAL:DistrictRules2.0-OpenBurningand3.17-WoodHeatingDevicesPublicHearingDate:February3,2014PublicCommentsTherehavebeennopubliccommentsreceivedtodate.Attachment
D: Comments and ResponsesProposed Rule 3.17 Wood Stove Heating/Wood Burning Appliances Public Workshop- August 26, 2009 @ 3:00p.m. Public Comments and Questions Q. How much credit incentive does the District provide and how much do appliances typically cost? A. Sondra Andersson (Andersson),
Air Quality Planner, stated the last round provided up to $500.00 toward the purchase of a new stove. There

is a tax credit of 35% also. Costs range depending
on the type and style of stove desired. They typically start at around $1500 and can go up to very high. A member of the public commented that the tax credit was only for biomass stoves and did not apply to natural gas stoves. He stated the costs are around $2000- $3500 for a stove. Q. Why are we not offering different requirements
for the different elevations within the county? A. Andersson explained the requirement

to meet the federal standard applies to the entire county and therefore the measure should be effective for all elevations within the District. Q . Why is the focus on the use of wood and not the sale of wood? Wouldn't

it be easier to enforce a sale provision? Are we planning on enforcing the regulation? Will we have
a meter for moisture content? Do we have opacity rules? A. Andersson stated the focus
is the emission minimization. There are instances where wood
is sold and seasoned
at the residence
or seasoned wood
is purchased and then is left in the rain and absorbs moisture. Our focus
is the reduction
of emissions when the wood
is burned so we are looking at the use instead of sale. Karla Sanders (Sanders), Air Quality Compliance Supervisor, stated the District will enforce the regulation
by continuing enforcement policies
in practice. The District

is a complaintdriven agency and will conduct complaint investigations,

if needed. The District will use approved methods to determine the moisture content. Andersson stated we do have an opacity standard for the District of 40% under Rule 3.0. Sanders stated she thought Rule 3.1 was more applicable. (Rule 3.1 exempts residential fireplaces from the opacity standard unless they are burning prohibited materials) Q. Why is F.2 only exempting masonry fireplaces since there are only two types of fireplaces, masonry and factory, and they are pretty much the same; why not exempt all fireplaces? Page
1 of 3A. Andersson stated that this part of the rule camefrom the original rule and EPA regulation

.The lineout strikeout changes arefor formatting purposes.She thanked him for the comment and will look into the exemption and recommend changes

if needed. Q
.What about the voluntary certification from EPA? A. Andersson requested
he submit written comments for moreinformation
onthis topic and the District will review this possibility

. Q. Why don't weset anamount

in the rule for when the advisory recommends

no burning? Why don't wehave two stages of allowable burning like other districts? A. Andersson said that weare hoping to hire aconsultant
to assist uswith the forecasting. David Valier (Valier), Air Pollution Control Officer, discussed the PM forecasting and other issues. The man clarified the issue of bifurcation
of education

.If wewant people to upgrade to anewer stove, then we have to give them reasonsand educate them onthe importance
of acleaner stove

.If there weretwo stages related to the type of device, then people would question the difference and want the onethat is allowed to burn overthe onethat is not allowed to burn. He recommended ouradvisories saythat certain approved devices can light but not the older, unapproved devices. Andersson thanked him for the comment and said she will discuss this with staff. Q. Could weenumerate the prohibited materials

in the rule rather than referencing another rule? A. Andersson made sureSanders was taking notes and requested the manto submit this comment with his others for ourconsideration. Q. The projections
of the emissions

is highly sensitive, do wehave speciation data? A. Andersson stated that the projections could be off and that it was only anestimate. We do have speciation data from other studies. Q. After adoption, would wework with the building departments

to assist them in implementing the changes? A. Andersson said that wewould need
a significant effort with all county and city departments including the sellers to help them implement the rule

.

Page 2 of 3Q. Would weconsider

a training or workshop for all departments? A. Andersson stated that it makes senseto have
a workshop for all departments and vendors so everyone

is onthe same pageand that this is a good idea. Q.Will wecontinue the change out voucher program? A. Andersson stated weare planning to continue the programand are going to the board
in October for approval of the next round of vouchers. Q. Could wefocus the change out vouchers for the people located nearthe monitor because that is where the problem is? A .Andersson thanked him for this comment. Q. What percent of newhomes arenot putting
in gas heating? A. Andersson stated that removing the exemption for fireplaces would not influence the new construction

of homes. When they review projects, the installation
of the gasstove
is usually part of the mitigation. We work with the planning agencies. Q. Are we planning to revise the rule soon,when should they submit comments? A. Andersson requested that wereceive the comments
by Friday sowecanhave the proposed rule ready for the board meeting to give a 30-day comment period. The public and staff discussed the public hearing and workshop process. There werenoother questions from the public workshop and Andersson closed the public meeting

. Page
3 of 3Sondra Andersson From: Sent: To: Subject: From: Griffin, Marty Palmeri, Edwin [EPalmeri@co

.yuba

.ca

.us] Wednesday, September 02, 2009 2:05 PM sandersson@fraqmd.org FW

:FRAQMD

:Wood Burning Applicances Sent: Friday, August 28, 2009 8:02AM To: Palmeri, Edwin; andersson, sondra Subject: RE: FRAQMD: Wood Burning Applicances Sondra, Just to let youknow the Section 3707(n) of the Uniform Building Code no longer exist. The ICBO merged and became the International Code Counsel, the State of California has adopted the California Code of Regulation, Title 24 Part 2, volume

1 and 2 which

is based onthe 2006 International Building Code

.Masonry Fireplaces fall under Section 2111A of the California Code of Regu

l at

i on,Title 24 Part 2, Volume

2 . Marty From: Palmeri, Edwin Sent: Thursday, August 27, 2009 9:03 AM To: Griffin, Marty; Mclean, Brent Cc: Hartman, Wendy; Mallen, Kevin Subject: FRAQMD: Wood Burning Applicances Attending

aFRAQMD workshop yesterday

.As youareawareFRAQMD

is amending Rule 3.17 pertaining
to Wood Burning Appliances. They are looking for comments
ontheir proposed draft Rule 3.17 (attached above) by the end of next week. They will then post the draft Rule for 30 day comment with
a public hearing onOctober

5, 2009. Any comments that you mayhave should be sent to Sondra at FRAQMD 1 Sondra Anderson Ft:atht:r

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r gSondra Andersson From: Sent: To: Cc: Subject: AndrewSondra Andersson [sandersson@fraqmd

.org] Monday

,August 24, 2009 11

:08 AM 'Steckei

.Andrew@epamail

.epa

.gov' ' apco@fraqmd

.org' RE

:EPA comment
onFeather River
3

.17 Thank youfor reviewing and commenting

onthe draft rule. In response

to yourcomments

: E.2

:CFR references are generally not dated to minimize confusion

if the CFR is subsequently revised

. E.4

:Same asabove

. The District shall removethe date references

in sections E.2 and E.4. E.8

:The referenced ASTM test method 04442-92

is the appropriate method to measuremoisture content. Please delete, "or other method approved
by the Air Pollution Control Officer

." The District shall determine moisture content using ASTM test method D4442-92, however would like to keep "or other method approved
by the Air Pollution Control Officer"

in this section. The District does not intend to submit this rule to the SIP. Future revisions maybe submitted

to the SIP

,at wh

i ch time the District shall consider removing the provision for other methods approved
by APCO. While we support the improvements proposed
by this rule revision, werecommend that Feather River AQMD also consider adopting other more stringent requirements, such asthose contained

in San Joaquin Valley APCD Rule 4901. The district reviewed other AQMD's rules and regulations during the development processof this rule revision

.At this time, additional residential wood burning restrictions, such asin the SJVUAPCD's Rule 4901, have not been considered
as part of this revision. The district

is pursuing

aseveral pronged approach

to reduce PM emissions

in our jurisdiction. These include enhanced public outreach, incentive programs,and control measures,such as amending Rule 3.17 to prevent the installation

of anynewwood burning, uncontrolled fireplaces. Thank you again for yourreview

.
I shall forward

afinal "proposed" rule to youafter the public workshop. Please let meknow
if youhave any questions. Regards, Sondra Andersson Air Quality Planner

II F.R.A.Q.M.D. 1007 Live Oak Blvd. Suite B-3 Yuba City, CA 95991 (530) 634-7659 ext210

1-----·--·-

,._

.

.... ·-·-----·- From: Steckei.Andrew@epamail.epa.gov [mailto:Steckei

. Andrew@epamail.epa.gov] Sent: Thursday, August 20, 2009 3:20 PM To: sandersson@fraqmd.org; mguzzett@arb.ca.gov Cc: Vineyard.Christine@epamail.epa.gov; Drake.Kerry@epamail.epa.gov Subject: EPA comment on Feather River 3.17 .ftEA•A United States Environmental Protection Agency 0

, )1-1\ Region IX 75 Hawthorne Street San Francisco, CA 94105-3901 August 20, 2009 Transmittal

of EPA Rule Review Comments To: Sandra Andersson, Feather River Air Quality Management District sandersson@fraqmd

.org Mike Guzzetta, California Air Resources Board mguzzett@arb

. ca.gov From: Andrew Steckel, Rulemaking Office Chief steckel

. andrew@epa.gov Re: Rule 3.17, Wood Burning Appliances, draft dated July 16, 2009 We are providing comments based on our preliminary review of the draft rule identified above

.Please direct any questions

in this regard to me at (415) 947-4115
or to Christine Vineyard
at (415) 947-4125

. E.2

: CFR references are generally not dated to minimize confusion

if the CFR is subsequently revised. E.4

: Same as above

. E.8

: The referenced ASTM test method 04442-92

is the appropriate method
to measure moisture content. Please delete

, " or other method approved
by the Air Pollution Control Officer." While we support the improvements proposed
by this rule revision, we recommend that Feather River AQMD also consider adopting other more stringent requirements

,such as those contained

in San Joaqu

i n Valley APCD Rule 4901

. 2Sondra Andersson From: Sent: To: Sondra Andersson [sandersson@fraqmd

.org] Monday

,August 24

,2009 11

:12 AM 'Krichevsky, Alex@ARB' Subject:

RE

:ARB Review of FRAQMD Rule
3

.17 Thank youfor reviewing the draft rule.

I shall send youa copyof the final proposed rule after the public workshop. Regards, Sondra Andersson Air Quality Planner

II F.R.A.Q.M.D. 1007 Live Oak Blvd. Suite B-3 Yuba City, CA 95991 (530) 634-7659 ext210 From: Krichevsky, Alex@ARB [mailto:akrichev@arb.ca

.gov] Sent: Monday, August 24, 2009 10:30 AM To: sandersson@fraqmd.org Subject: ARB Review of FRAQMD Rule 3.17 Attached areresults of ARB's review of the following rules

: Rule
3

.17 -Wood Burning Appliances Please contact meat (916) 324-6222
orakrichev@arb

.ca.gov

if there are any problems with this e-mail transmittal. Alex

1STATE OF CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY AIR RESOURCES BOARD P. 0. Box 2815 Sacramento

,California 95812 August 24, 2009 Transmittal of ARB Staff Rule Review Comments To: Ms. Sondra Andersson Air Quality Specialist

II Feather River Air Quality Management District Telephone Number: (530) 634-7659 ext. 210 e-mail: sandersson@fraqmd

.org From: Alex Krichevsky, (916) 324-6222 e-mail: akrichev@arb.ca.gov The following draft rule, which
is scheduled for a workshop
to be held by yourDistrict staff on August 26, 2009, wasreceived by uson July 21, 2009, for ourreview: Rule 3.17 Wood Burning Appliances We have reviewed the rule, and based onthe information available
to usat this time

,we have nocomments. If youhave any questions, please contact meat the telephone number above.