Public Comments 

There have been no public comments received to date. 
Attachment D: 

Comments and Responses 
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 3 
A. Andersson requested he submit written comments for more information on this topic and the 

District will review this possibility. 

Q. Why don't we set an amount in the rule for when the advisory recommends no burning? Why 

don't we have two stages of allowable burning like other districts? 

A. Andersson said that we are hoping to hire a consultant to assist us with 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 we want people to upgrade to a newer stove, then we 

have to give them reasons and educate them on the importance of a cleaner stove. If there were two 

stages related to the type of device, then people would question the difference and want the one that is 

allowed to burn over the one that is not allowed to burn. He recommended our advisories say that 

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 we enumerate the prohibited materials in the rule rather than referencing another rule? 

A. Andersson made sure Sanders was taking notes and requested the man to submit this comment 

with his others for our consideration. 

Q. The projections of the emissions is highly sensitive, do we have speciation data? 

A. Andersson stated that the projections could be off and that it was only an estimate. We do have 

speciation data from other studies. 

Q. After adoption, would we work with the building departments to assist them in implementing 

the changes? 

A. Andersson said that we would need a significant effort with all county and city departments 

including the sellers to help them implement the rule. 

Page 2 of 3 
Q. Will we continue the change out voucher program? 

A. Andersson stated we are planning to continue the program and are going to the board in 

October for approval of the next round of vouchers. 

Q. Could we focus the change out vouchers for the people located near the monitor because that is 

where the problem is? 

A. Andersson thanked him for this comment. 

Q. What percent of new homes are not 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 gas stove 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 we receive the comments by Friday so we can have 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 were no other questions from the public workshop and Andersson closed the public meeting. 

Page 3 of 3 
Sent: Friday, August 28, 2009 8:02AM 

To: Palmeri, Edwin; andersson, sondra 

Subject: RE: FRAQMD: Wood Burning Applicances 

Sondra, Just to let you know 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 on the 2006 International Building Code. Masonry Fireplaces fall under Section 

2111A 

of the California Code of Regulation, 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 a FRAQMD workshop yesterday. As you are aware FRAQMD is amending Rule 3.17 pertaining to Wood 

Burning Appliances. They are looking for comments on their 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 on October 5, 2009. 

Any comments that you may have should be sent to Sondra at FRAQMD 

1 

Sondra Anderson 

Ft:atht:r Rivt:r Air Quality fVlanagt:mt:nt ... 

Air Quality Planner 

{530) 3+7~59 Ex.T- 210 \• ork 

sandersson @fi·aqf!1d. org 

100 7 Livt: Oak Blvd, Suitt: B-3 

Yuba City, c A:95991 . 

http://"Jww. fi·aqnid.org 
Thank you for reviewing and commenting on the draft rule. In response to your comments: 

E.2: CFR references are generally not dated to minimize confusion if the CFR is subsequently revised. 

E.4: Same as above. 

The District shall remove the date references in sections E.2 and E.4. 

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." 

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 may be submitted to the SIP, at which 

time the District shall consider removing the provision for other methods approved by APCO. 

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 Joaquin Valley APCD Rule 4901. 

The district reviewed other AQMD's rules and regulations during the development process of this rule 

revision. At this time, additional residential wood burning restrictions, such as in the SJVUAPCD's 

Rule 4901, have not been considered as part of this revision. 

The district is pursuing a several 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 any new wood burning, uncontrolled fireplaces. 

Thank you again for your review. I shall forward a final "proposed" rule to you after the public 

workshop. Please let me know if you have 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 ext 210 

1 
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 Joaquin Valley APCD Rule 4901 . 

2 
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 ext 210 

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 are results of ARB's review of the following rules: 

Rule 3.17 -Wood Burning Appliances 

Please contact me at (916) 324-6222 or akrichev@arb.ca.gov if there are any problems with this e-mail transmittal. 

Alex 

1 
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 your District 

staff on August 26, 2009, was received by us on July 21, 2009, for our review: 

Rule 3.17 Wood Burning Appliances 

We have reviewed the rule, and based on the information available to us at this time, we 

have no comments. 

If you have any questions, please contact me at the telephone number above.