GOVERNING BOARD

Hub Walsh, Chair Supervisor, Merced County

Tom Wheeler, Vice Chair Supervisor, Madera County

Oliver L. Baines III Councilmember, City of Fresno

Tony Barba Supervisor, Kings County

Skip Barwick Councilmember, City of Tulare

Sally J. Bomprezzi Councilmember, City of Madera

Dennis Brazil Mayor, City of

John Capitman, Ph.D. Appointed by Governor

Judith G. Case McNairy Supervisor, Fresno County

David Couch Supervisor, Kern County

Bob Elliott Supervisor, San Joaquin County

Harold Hanson Councilmember, City of Bakersfield

William O’Brien Supervisor, Stanislaus County

Alexander C. Sherriffs, M.D. Appointed by Governor

J. Steven Worthley Supervisor, Tulare County

Seyed Sadredin Executive Director Air Pollution Control Officer

Northern Region Office 4800 Enterprise Way Modesto, CA 95356

- 8718 (209) 557

- 6400 • FAX (209) 557

- 6475

Central Region Office 1990 East Gettysburg Avenue Fresno, CA 93726

- 0244 (559) 230

- 6000 • FAX (559) 230

- 6061

Southern Region Office 34946 Flyover Court Bakersfield, CA 93308

- 9725 (661) 392

- 5500 • FAX (661) 392

- 5585

www.valleyair.org 

## DATE: September 18, 2014

TO: SJV UAP CD G overning B oard

FROM: Seyed Sadredin, Executive Director/APCO Project Coordinator: Sheraz Gill

RE: ITEM NUMBER 7 : ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM

RECOMMENDATION :

1. Adopt proposed amendments to Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters).

2. Adopt proposed amendments to the District Burn Cleaner Program to offer additional financial incentives to Valley residents for the purchase of cleaner devices, including:

a. Increase per

- unit incentive amounts from current amounts ($100

- $500) to a maximum of $1,500 with an additional $500 for installation of gas

- fired units; b. Increase per

- unit incentive amounts for low

- income qualified applicants from up to $1,500 to up to $2,500 with an additional up to $500 for installation of gas

- fired units;

c. Expand low

- i ncome provisions to include property owners who rent to low

- income qualified tenants; and d. Work with retailers to allow qualified low

- income applicants to purchase devices through the Burn Cleaner program without requiring up

- front payment.

3. Adopt propos ed new Rule 3901 (Fees for Registration of Wood Burning Heaters).

4. Authorize the Chair to sign the attached Resolution.

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014


## BACKGROUND :

On December 20, 2012, your Board adopted the District’s 2012 PM2.5 Plan which laid out a host of strategies aimed at attaining the 2006 federal ambient air quality standard for PM2.5. One of the measures contained in the plan was amendments to District Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters). Your Board directed the staff to develop the necessary amendments for implementation in the winter of 2014

- 15

. The Governing Board directed the staff to craft amendments that lower the threshold for daily residential wood burning prohibitions during winter seasons while increasing the number of permissible burn days for Valley residents that have invested in cleaner wood burning devices. The District staff was also directed to investigate the feasibility of enhanced financial incentives to encourage Valley resident s to upgrade to cleaner devices. Today’s recommendations were developed through an extensive public process including multiple workshops, public meetings, and consultations with various stakeholders including representatives from the hearth industry.

DISCUSSION :

Due to the Valley’s geography, topography, and meteorology, the challenges that we face in meeting the federal health

- based ambient air quality standards are unmatched by any other region in the nation. In response to these federal mandates a nd to improve quality of life for Valley residents, the District has developed and implemented multiple generations of rules on various sources of air pollution. Since 1992, the District has adopted over 500 rules, requiring the installation and operation of the most effective air pollution control technologies and processes. Valley businesses are currently subject to the most stringent air quality regulations in the nation. Despite significant progress in improving the Valley’s air quality, more reducti ons in emissions are needed to attain the ever toughening federal standards. The District’s attainment plans contain a comprehensive set of local and state measures to reduce air pollution from stationary and mobile sources throughout the Valley. However , attaining the 2006 federal PM2.5 standard is impossible without significant further reductions in wood smoke emissions.

Further reducing residential wood smoke emissions is also a high priority under the District’s Health Risk Reduction Strategy given the significant localized health impacts associated with residential wood smoke. Scientific studies show that prolonged inhalation of wood smoke contributes to lung disease, pulmonary arterial hypertension, and pulmonary heart disease, which can eventual ly lead to heart failure. The proposed rule is designed to improve public health by reducing toxic wood smoke emissions in Valley neighborhoods during the peak PM2.5 winter season (November through February).

2

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE D ISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014 

## Summary of the Proposed Wood Burning Curtai lment Strategy

The proposed amendments to the residential wood burning program will enable Valley residents to play a major role in reducing emissions at almost no cost, and, in many cases, with savings in heating

- related energy costs. The District will encourage the
tr ansition to less polluting wood burning heaters by decreasing the number of allowable burn days for high polluting wood burning heaters and fireplaces while at the same time increasing the number of burn days allowed for registered clean wood burning heate rs through a tiered episodic wood burning curtailment program. The proposed amendments to Rule 4901 will lower the No Burn threshold for high polluting wood burning heaters and fireplaces from the current limit of 30 μg/m 3 

## to 20 μg/m 3 

## . The proposed amend ments will significantly increase the number of permissible burn days for cleaner certified wood burning devices by raising the No Burn threshold to 65 μg/m 3



## . If approved, the proposed amendments will double the number of No Burn days for high polluting u nits that are the source of over 95% of the wintertime residential wood smoke emissions. By contrast, under the proposed rule, clean certified units will be subject to minimal number of No Burn days ranging from zero to six days depending on the location in the Valley during the winter season.

Figure 1 Current and Proposed Curtailment Thresholds

3

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014 

## Additionally, the proposed enhancements to the District’s Burn Cleaner Program will provide additional financial incentives to Valley residents for the purchase of cleaner devices. The proposed regulatory and financial incentives which encourage the purchase of cleaner units will result in significant additional emission reductions throughout th e season even on permissive burn days. Overall, the proposed wood burning strategy is expected to reduce over 5.1 tons per day of PM2.5 valley

- wide during the winter season.

Table 1 below provides the potential number of wood burning prohibitions that will occur in each county at the proposed curtailment thresholds. These estimates are based on the District’s wood burning forecasts as averaged over the last five wood burning

seasons.

Table 1 Potential Change in No Burn Days Based on Proposed Amendments

County Current Average No

Burn Days (≥30 μg/m3) Proposed Level 1 (20

– 65

μg/m 3 

## ) Proposed Level 2 (above 65 μg/m 3 

## ) TOTAL No Burn Days for Non

- Registered units (L1 + L2) San Joaquin 24 53 0 53
Stanislaus 36 70 2 72
Merced 19 55 0 55
Madera 29 66 1 67
Fresno 49 79 6 85 Kings 39 64 6 70
Tulare 36 65 4 69
Kern 44 73 6 79

Registration Program for Wood Burning Heaters The approach under the proposed rule that will allow clean units to burn on days when burning is prohibited for conventional units will be nearly impossible to enforce without a mechanism to readily identify and verify qualifying devices. To provide the District with an enforceable mechanism for allo wing certified devices to burn during a level one curtailment (greater than 20 μg/m 3 

## but less than 65 μg/m 3 

## ), the District proposes a registration program for these cleaner burning devices. Without preregistering qualifying devices the District would be f orced to resort to more intrusive enforcement techniques which would involve routine access to private property. The preregistration will also enhance enforcement capabilities by allowing the District to better focus resources. Registration will also ens ure that the equipment is maintained in proper working condition and provides the expected reduction in emissions.

Registration would be voluntary and will only be necessary if the owner of a certified unit wishes to take advantage of the additional bu rn days provided under the proposed rule. Under the proposed approach, registrations would be valid for three wood burning seasons and registered devices would be required to operate with no visible smoke

4

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING P ROGRAM September 18, 2014 

## under normal operating conditions, be maintained p roperly, and refrain from burning prohibited materials. Wood burning devices found to be in violation of Rule 4901 requirements by the District may be disqualified.

Registration Program for Wood Burning Heater Professionals Proposed rule requirements w ill require a registered wood burning heater to be inspected by a Wood Burning Heater Professional to verify that the wood burning heater is in good operating condition, including ensuring that the device has been cleaned, maintained, and operated in accor dance with manufacturer specifications. To ensure qualified individuals are performing these inspections and verifications, the District proposes a registration program for Wood Burning Heater Professionals. The District will maintain a list of these reg istered individuals on the District’s website for the public
to access.

Free I nterim Registration during 2014

- 15 Winter Season If adopted in September the rule will take effect in November leaving a short amount of time for the public to accommodate sig nificant changes to the rule. To provide for a smooth transition, the District proposes a simplified registration process at no charge to the public for the first year. The interim registration process will rely on self

- certification by interested appli cants and interim registrations will expire at the end of this first wood burning season on February 28, 2015. The District is committed to educating the public on how the tiered episodic wood burning curtailment program works and how to comply with it, a s well as how to register clean wood burning heaters in order to encourage upgrading to cleaner devices through the additional burn days afforded them through the tiered program.

Clarifications to Existing Rule Requirements Proposed amendments will simplify rule language and clarify existing requirements through the removal of redundant and expired language in the rule. Additionally, in response to EPA’s proposed amendments to the Code of Federal Regulations Part 60, Subpart AAA, the District is updating all references of “EPA Phase II Certified” to clarify as “Phase II certified or the most stringent EPA certification as enforced by the NSPS”.

New definitions will be added to rule language to clarify existing standards or in support of proposed standards. Proposed new definitions include: Normal Operating Conditions, NSPS, and Wood Burning Season.

The exemptions section of the rule will be amended to add new exemption 4.3 to clarify that open burning is regulated by Di strict’s Rule 4103, and as such are not subject to Rule 4901 rule requirements.

Proposed amendments to Section 5.1 (Sale or Transfer of Wood Burning Heaters) will clarify that the section is applicable to the sale and the transfer of new wood burning he aters, and is not strictly limited to the sale of such heaters. Proposed amendments also clarify that the certification of wood burning heaters is pursuant to the NSPS to

5

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014 

## ensure that the most recent and stringent requirements in the NSPS are being impleme nted for these new wood burning heaters.

Proposed amendments to Section 5.3 (Limitations on Wood Burning Fireplaces or Wood Burning Heaters in New Residential Developments) will clarify existing requirements in the rule. These amendments will be effect ive as of January 1, 2015, consistent with the time frame provided in the 2003 amendments to Rule 4901 which first introduced these requirements to the rule.

Proposed amendments will clarify that the prohibited fuels are not only not allowed in indoor woo d burning heaters but also in the outdoor wood burning devices (Section 5.5) and will add a clarification that butane is not considered natural gas (Section 5.6.3), and clarifications will be added to clarify that the most recent ASTM shall be used to test the moisture content of wood to verify it is seasoned wood (Section 7.1).

Residential Wood Burning Emissions in the Valley

Residential wood burning is a significant contributor to V alley PM2.5 emissions during the winter season. Based on data from the Metropolitan Planning Organizations, the U.S. Census, and survey results, the District estimates that there are over 240,000 residences in the Valley contributing 13% of total winter

- t ime PM2.5 emissions (see Figure 2 ).

Figure 2 Wintertime Valley Source Contributions to the PM2.5 Emission Inventory

AGRICULTURAL

WASTE BURNING
& FOREST MGMT
11%

FIREPLACES &

WOOD STOVES
13%

COOKING

INCLUDING

CHARBROILING
6% FARMING

OPERATIONS
17%

HEAVY DUTY

DIESEL TRUCKS
6% OTHER MOBILE

SOURCES

10% FUGITIVE

WINDBLOWN

DUST
7% ROAD DUST
13%

OTHER SOURCES
17%



### 6

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014 

## During peak winter days, organic carbon contributes up to 33% of the composition of PM2.5 emissions in the Valley, the vast majority of which is from residential wood burning, as can be seen in Figure 3 below.

Figure 3 Wintertime Peak Day PM2.5 Emission Speciation (Fresno)

According to EPA, of the wood stoves in use today, 75% are not EPA certified. Because these devices produce so much more pollution than EPA certified wood stoves, these older wood burning heat ers and fireplaces represent 95% of the overall emissions from residential wood burning. An EPA certified wood burning heater is at least 20 times cleaner than a wood burning fireplace, as demonstrated in the figure below. This tremendous difference in e missions between these units highlights the importance of replacing existing high polluting devices with cleaner burning alternatives. ELEMENTS
2% GEOLOGICAL
1% ELEMENTAL

CARBON
7%

ORGANIC

CARBON

33%

AMMONIUM

SULFATE
6% AMMONIUM

NITRATE

51%



### 7

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014 

## Figure 4 Average PM2.5 Emissions Based on Wood Burning Heater Type

Emission Reductions f r om Proposed Amendments

The total emission reductions achieved from the proposed amendments to Rule 4901 is calculated to be 5.1 tons per wood burning season day which includes :

• 3.33 tons of r eductions from simply lowering the threshold from 30 μg/m 3 

## to 20 μg/m 3



## ,

• 0.065 tons/day increase in emissions if all existing clean certified units registered and burned on days when P M2.5 concentrations are projected to be between 30 μg/m 3 

## to 65 μg/m 3



## ,

• 0. 22 tons/day increase in emissions if 24% of existing higher pol luting devices transition to clean certified units and all registered and burned on days when PM2.5 concentrations are projected to be between 20 μg/m 3 

## to 65 μg/m 3 

## , and

• 2.04 tons/day of r eductions from the transition of older dirtier wood burning heaters and wood burning fireplaces to cleaner certified devices

.
Wood Smoke Reductions Critical to Attaining the PM2.5 Standard

Based on the m odeling conducted for the 2012 PM2.5 Plan

, reaching attainment requires reductions of 68.6 tons per day of NOx, 4.3 tons per day of PM2.5, and 1.8 tons per day of SOx. These numbers reflect the average daily reductions needed based on a 180 day winter season (November through April). The bulk of these reductions will come from a multitude of measures targeted at mobile and stationary

sources of pollution throughout the Valley

. However, modeling indicates that attainment is not possible without the reductions in directly

- emitted PM2.5 emissions from

8

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014 

## residential wood burning. The projected 5.1 tons per day reductions from the proposed rule represents the average reductions during the 120

- day wood burning season (November through February).

H ealth Impacts of Wood Smoke Particulate Matter Emission s

Reducing emissions from residential wood burning is a priority under the District’s Health Risk Reduction Strategy because m ultiple scientific studies show that prolonged inhalation of wood smoke has adverse impacts on human health . Inhalation of wood smoke contributes to lung disease, pulmonary arterial hypertension, and pulmonary heart disease, which can eventually lead to heart failure. Wood smoke has also been linked to oxidative stress and blood coagulation and can ultimately lead to cancer. Children with the highest exposure to wood smoke show a significant decrease in lung function.

Health benefits from reducing emissions from residential wood burning are related to the high level of population exposure to urban resident ial wood burning emissions with relation to other stationary sources. People can be exposed to wood smoke when they use their wood burning devices. Additionally, people can be exposed to wood smoke when people in their neighborhoods use their wood burnin g devices because windows and doors cannot keep the particles in wood smoke out of people's homes. A Central Valley Health Policy Institute Study found that wood burning curtailments on high pollution days reduced annual exposure by 13.6% in Fresno, and a n estimated 12.9% in Bakersfield resulting in 30 to 70 avoided cases of annual premature deaths.

Proposed Rule Amendments Guided by Scientific Public Survey

In January 2014, the District hired a third party company to perform a telephone survey of Va lley residents . One of the primary goal s of this study was to learn more about residential wood burning habits and attitudes. S urvey results support the implementation of a tiered episodic wood burning curtailment program and increasing incentive amounts for the Burn Cleaner Program. Some of the results of the survey are summarized below an in Figure 5. R efer to Appendix E of the final draft staff report for the complete surve y :

• 32% of those surveyed reported having a wood burning device in their residence

• 80% of people surveyed are aware of the Check Before You Burn program

o 78% of whom have reduced wood burning activities as a direct result of this program

• 29% of survey respo ndents stated that they would upgrade their existing wood burning device to a clean alternative if doing so meant that they could use their device more days then they currently can

• 24% of respondents said they would upgrade their existing wood burning dev ice to a clean alternative if they were given up to a 50% discount on a new unit.

9

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014 

## Figure 5 Percentage of Wood Burning Devices in the Valley (Survey Results)

Summary of Proposed Amendments to Burn Cleaner Incentive Program

The District’s Burn Cleaner Wood Stove Change

- out Program (Burn Cleaner Program) plays a key role in the success of the transition from older more polluting wood burning heaters and firepla ces to cleaner wood burning heaters. Since 2006, the Burn Cleaner Program has been helping residents overcome some of the financial obstacles in purchasing cleaner alternatives. The District continues to take proactive steps to enhance the Burn Cleaner P rogram and as such proposes the following changes to the District’s current Burn Cleaner Program as a complementary strategy to the proposed regulatory amendments:

Increased Incentive Amounts The results of the scientific survey indicated that 24% of Val ley residents with wood burning heaters would transition to cleaner burning heaters if they were provided a discount of up to 50% off the total cost of the heater. 1 

## In light of this new information, the District is proposing to increase the current incentive amounts to about half of the total cost of entry level heaters. The dollar amounts are based on information gathered from local hearth retailers and the Distri ct’s database of funded Burn Cleaner Program projects.

The increase in incentive funding amounts will encourage more residential property owners to replace their existing heaters with cleaner burning heaters sooner in conjunction with the upcoming propos ed Rule 4901 amendments by making the

1 

### Gomez Research. Residential Wood Burning, Lawn Care, and Commuting Survey Final Report. February 2014. Retrieved from http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2014/march/final/09.pdf

. 

### WOOD

BURNING

FIREPLACE
25%

WOOD STOVE
4%

PELLET STOVE
3% NO WOOD

BURNING

DEVICE

68%

10

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014 

## replacement costs more feasible. More importantly, the proposed funding amount for low

- income qualified applicants will help them pay for a majority of the costs of a replacement, as many are unable to afford these ex pensive new heaters. The proposed funding amounts are summarized in Table 2 below.

Table 2 Proposed Amendments to Burn Cleaner Program Incentive Amounts

New Heater Current Funding Proposed Funding Gas Insert/Stove/Fireplace* $500 $1,500

- Additional Incentive for Installation of Gas

Infrastructure* Not Available $500**

EPA Certified Pellet Insert/Stove $250 $1,500
EPA Certified Wood Insert/Stove $100 $1,500
Low

- Income Qualified Applicants $1,500 $2,500

- Additional Incentive for Installation of Gas

Infrastructure* Not Available $500**

*Gas fireplaces must be certified as heater

- rated (ANSI Z21.88/CSA 2.33) **Applies only to eligible installation costs beyond the proposed funding amount for the new gas heater.

Addit ional Assistance for Low

- Income Residents As a part of the District’s ongoing efforts to encourage more low

- income qualified applicants to participate in the Burn Cleaner Program, the District sought feedback and suggestions from the Environmental Justice Advisory Group (EJAG), the Citizen’s Advisory Committee (CAC), the public at public workshops, and the Ad Hoc Technical Workgroup Committee on how to make the program more accessible. The District is proposing to make several enhancements to the existing Burn Cleaner Program, including:

• Increased per

- unit incentive amounts for low

- income qualified applicants from $1,500 to $2,500 with an additional $500 for the installation of natural gas infrastructure

,

• Reducing the upfront cost of purchasing and installing a new unit for low

- income applicants. The District has partnered with contracted hearth retailers to allow low

- income qualified applicants to make the purchase at a reduced price by deducting the incentive amount from the invoice at the time of purchase. Allowing the incentive funding to be directly applied to the cost of the unit makes it more feasible for low

- income applicants to take advantage of the program

, and

• Expanding low

- income provisions to include property owners who rent to low

incom e qualified tenants;

**Check Before You Burn** Campaign Outreach and Education

The success of implementing the proposed amendments to the residential wood burning program will hinge on the expansion of the District’s comprehensive multi

lingual Check Befor e You Burn outreach and education program. The District has an

11

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNI NG PROGRAM September 18, 2014 

## extremely successful outreach and education program with regards to residential wood burning and educating Valley residents about air quality, the effects of air pollution on the populations’ health, and on options they can take to reduce emissions. The District’s Check Before You Burn program is the District’s public education program most recognized by Valley residents. In both the District’s 2010 and 2014 public opinion surveys, over 80 pe rcent of Valley residents indicated that they were familiar with the
program.

The PM2.5 air quality improvements that the Valley has experienced since adoption of Rule 4901 have been assisted by strong multimedia outreach by the District and the resultant increase in public awareness and participation in winter District programs. Since the inception of Check Before You Burn , the District’s complementary tools, such as the Real

- time Air Advisory Network (RAAN) and the “Valley Air” smart phone app, have con tinued to gain in popularity.

The District’s seasonal public outreach advertising campaign is retooled each year to include timely and relevant messaging. In the past few seasons, this messaging has been delivered by the District’s Governing Board membe rs, with billboards in English and Spanish strategically placed throughout the Valley in older neighborhoods where open hearth fireplaces and older devices are most likely to be, targeted radio and TV spots, and value

- added messaging delivered through medi a throughout the Valley.

The key message of this outreach is to ask residents to call the District’s 1

- 800 number, check the website, check their local news outlet, check their smart phone or visit social media to assess their county’s burn status. The District maintains partnerships with television, newspaper, radio, outdoor and print, as well as more non

- traditional media, such as on

- screen messaging in local movie theaters, internet advertising and video loops in medical offices.

Looking forward, the Check Before You Burn outreach messaging will expand to focus

on three areas:

• E ducat ing the public and the media about the new tiered episodic wood burning curtailment program,

• E ncourag ing residents to upgrade to cleaner certified device s and take advantage of the enhanced Burn Cleaner Program , and

• E ducating Valley residents regarding the severe health impacts associated with wood smoke.

Continued emphasis will be placed on reaching those communities that might be heavily impacted by ne ighborhood smoke from older devices and open hearth fireplaces. The District is prepared to work with retail partners, media partners and non

- profit stakeholders to launch these new outreach and education efforts immediately after the adoption of proposed amendments.

12

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014 

## Summary of Proposed New Rule 3901

Proposed new Rule 3901 (Fees for Registration of Wood Burning Heaters) will create the fee structure for the registration of wood burning heaters with the District pursuant to Rule 4901. The registration fee and registration renewal fee will be established at $12.50. In order to ensure a smooth transition for registered devices , there will be no fee for this coming season (2014

- 15 wood burning season) and the registration process will be truncated by eliminating third party verification.

Public Process for Developing Proposed Amendments

The District has conducted a robust pu blic process for developing the proposed amendments to Rule 4901 and the Check Before You Burn program. The public has been actively participating and providing feedback and comments on potential amendments to Rule 4901 since the beginning of the developm ent of the District’s 2012 PM2.5 Plan , through subsequent public workshops and meetings, and through a scientific public opinion survey of Valley residents.

2012 PM2.5 Plan Development The District hosted a series of public workshops and updates at pub lic meetings such as the Governing Board meetings, Citizen Advisory Committee meetings, and Environmental Justice Advisory Group meetings throughout the plan development process. Potential opportunities to reduce emissions were discussed at these meetings , including potential emission reductions opportunities from Rule 4901. Public comments specific to Rule 4901 were received throughout the plan development process and incorporated into the plan as appropriate.

Technical Workgroup Committee meetings
In preparation for amendments to the District’s Residential Wood Burning Program, the District formed an Ad Hoc Technical Workgroup Committee consisting of District staff, retailers of residential wood burning heaters, and representatives of the Hearth, Pati o & Barbeque Association. The technical workgroup committee met monthly for five months during the summer of 2013 to discuss concepts related to potential rule amendments, implementation issues, outreach considerations, and enhancements to the Burn Cleane r Program. The expertise and suggestions from the Ad Hoc Technical Workgroup Committee were invaluable in helping the District to craft the proposed innovative amendments to the District’s Residential Wood Burning Program.

Public Opinion Survey of Va lley Residents In September 2013 the District hired a third party company to develop and administer a bilingual user survey of residential wood combustion, lawn care and personal commuting activity in the Valley. In January 2014 the telephone survey of 1, 000 random Valley residents took place, the final draft report was drafted in February 2014 and presented to the District’s Governing Board in March 2014. Information gained from this survey has been incorporated into the proposed amendments to the Reside ntial Wood Burning Program.

13

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014 

## Public Workshops and Meetings The District held two public workshops in the evening hours at all three District offices. On the evening of March 27, 2014 the District presented conceptual information and plan commitments, new NSPS regulations, potential methods of public outreach, and potential incentive program enhancements. On the evening of July 31, 2014, the District presented draft amendments to Rule 4901 and draft new Rule 3901. Each workshop was followed by a two

- week public comment period. Comments received were evaluated and incorporated into the rules and staff report as appropria te. Refer to Appendix A (Comments and Responses) for a summary of significant comments and District responses. In addition to the workshops, the District provided regular updates on the development of Rule 4901 at public meetings of the District’s Citize n’s Advisory Committee and Environmental Justice Advisory Group.

Public Hearing for Rules 4901 and 3901 In accordance with CH&SC Section 40725, the proposed amendments to Rule 4901 and proposed new Rule 3901 and the Final Draft Staff Report were public ly noticed prior to the Governing Board public hearing to consider adoption of the proposed amendments and proposed new rule. The proposed amendments to Rule 4901, proposed new Rule 3901, the Final Draft Staff Report, and other supporting documents

were m ade available for public comment on August 19, 2014. Summaries of comments received prior to 5:00 PM on September 2, 2014 with District responses are in Appendix A of the final draft staff report. The public is also invited to provide comments during the public hearing for proposed adoption of this rule.

Public Comments and Responses

The comments and questions received during workshops and associated written comment periods have been integral to development of this rule. The key issues raised durin g development of this rule are summarized below:

Comment: T he District should focus on regulating businesses, the agricultural community, and mobile sources instead of Valley residents.

Response: Since 1992, the District has adopted over 500 rules, requiring the installation and operation of the most effective air pollution control technologies and processes. Valley businesses

, including agricultural sources are currently subject to the most stringent air qual ity regulations in the nation and have a lready achieved significant emissions reductions (over 80%) that the Valley is at the point of diminishing returns from new regulatory controls on businesses , and new opportunities for more stringent regulatory controls continue to become increasingly scar ce. Achieving additional emission reductions from businesses beyond those already achieved will require significant investments on the part of Valley businesses who have already spent billion s of dollar s in control technology. Despite significant progres s in improving the Valley’s air quality, more reductions in emissions are needed from all source categories to attain the ever toughening federal standards. Therefore, attaining the 2006 federal PM2.5 standard is impossible without significant further red uctions in wood smoke emissions.

14

### SJV U

APCD Governing Board
ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014 

## Further reducing residential wood smoke emissions is also a high priority under the District’s Health Risk Reduction Strategy given the significant localized health impacts associated with residential wood smoke. Scient ific studies show that prolonged inhalation of wood smoke contributes to lung disease, pulmonary arterial hypertension, and pulmonary heart disease, which can eventually lead to heart failure. The proposed rule is designed to improve public health by redu cing toxic wood smoke emissions in Valley neighborhoods during the peak PM2.5 winter season (November through February).

C omment: A mending the curtailment threshold for all wood burning devices in the Valley from 30 to 65 μg/m 3 

## is a relaxation of the rule and the draft curtailment threshold should be no higher than 30 μg/m 3



## .
Response: On the contrary, the proposed amendments will make this rule the most stringent wood burning curtailment rule in the nation

. T he District is proposing to lower the curtailment threshold to 20 μg/m 3 

## for o lder more polluting wood burning heaters and wood burning fireplaces, which comprise over 9 5 % of wood burning emissions . In addition, the operation of non

- registered clean devices will also be restricted at the 20 μg/m 3 

## threshold . This proposed curtailment level is significantly lower than the current curtailment threshold of 30 μg/m 3 

## . Amending the rule to allow the cleanest wood burning heaters to be used between 20 and 65 μg/m 3 

## would provide significant motivation to Valley residents for transitioning away from old er high er polluting devices to the cleanest wood burning heaters. A registered wood burning heater pollutes at least twenty times less than a wood burning fireplace ; therefore, encouraging this transition would reduce emissions beyond those that could be accomplished by only reducing the curtailment threshold to 20 μg/m 3



## . T he proposed amendments will achieve an estimated reduction of 5.1 tons per day of PM2.5 emission s.

Comment: The Duraflame Company provided a comment that t he proposed revision of lowering the concentration threshold to 20 μg/m 3 

## dramatically increases the number of No Burn days and tilts the burden of reducing PM2.5 emissions far beyond the contribu tion that occasional residential wood burning makes to PM2.5 emissions in the Valley. Additionally, they suggested that the high PM2.5 concentrations experienced in the winter of 2013

- 14 indicate the need for controlling other sources of air pollution tha t were allegedly responsible for such increases.

Response: Valley Businesses are already subject to toughest air regulations in the nation

. The District’s attainment plans call for significant reductions in emissions from mobile and stationary sources throughout the Valley. With regards to directly emitted PM2.5 emissions, residential wood burning is the largest source in the Valley during the winter months, as supported by Appendix B (Emissions Inventory) of the District’ s 2012 PM2.5 Plan. 2 

## During the 2013

- 14 winter season, the Valley experienced unprecedented stagnation and extreme weather conditions with century old drought records being broken in many of the cities in California

. These unique conditions

2 

### SJVUAPCD. 2012 PM2.5 Plan. Appendix B (Emissions Inventor y). December 2012. Retrieved on 8/15/14 from http://www.valleyair.org/Air_Quality_Plans/PM25Plans2012.htm

.



### 15

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014



## r esult ed in abnormally high PM2.5 concentrations during the 2013

- 14 winter season and
t he Valley’s PM2.5 concentrations would have been even higher absent the wood burning restrictions. The District and the California Air Resources Board also conducted extensive grid based and photochemical modeling during the development of the 2012 PM2.5 Plan and determined that significant PM2.5 reductions were achieved through the implementation of the Districts PM2.5 control strategy which includes the wood burning heater and wood burning fireplace rule

. Reducing directly emitted PM2.5 emissions will have a greater benefit on Valley air and public health than reducing precursor emissions to PM2.5 as supported by California Air Resources Board modeling summarized in Chapter 4 (Scie ntific Foundation and PM2.5 Modeling Results) of the 2012 PM2.5 Plan

. 3 

## Nonetheless, given the ever tightening federal health standards, the District is mandated to pursue all available measures to reduce direct and indirect sources of particulate emission s.

In addition, prolonged inhalation of wood smoke has adverse impacts on human health

. Inhalation of wood smoke contributes to lung disease, pulmonary arterial hypertension, and pulmonary heart disease, which can eventually lead to heart failure. Wood smoke has also been linked to oxidative stress and blood coagulation and can ultimately lead to cancer. Children with the highest exposure to wood smoke show a significant decrease in lung function.

Health benefits from reducing emissions from resident ial wood burning are related to the high level of population exposure to urban residential wood burning emissions with relation to other stationary sources. A Central Valley Health Policy Institute Study found that wood burning curtailments on high pollut ion days reduced annual exposure by 13.6% in Fresno, and an estimated 12.9% in Bakersfield resulting in 30 to 70 avoided cases of annual premature deaths.

Comment: Duraflame suggested that their logs should be given the same preferential
treatment as clean certified devices under the proposed rule, claiming that their manufactured logs emit 80% less air pollution.

Response: Duraflame claims a manufactured log “produces 80 percent fewer fine

particle emissions than a wood fire of a similar duration ”

. This is correct, however, Duraflame’s own information indicates that the heat generated by their product is only 25% of the heat generated from the same amount of Douglas Fir wood for a fire of the same duration. Therefore

, for the same amount of heat ge nerated, there will be no reductions in emissions.

The following table further demonstrates that the emissions are higher from a Duraflame log vs a Douglas Fir Cordwood log of the same weight :

3 

### SJVUAPCD. 2012 PM2.5 Plan. Chapter 4 (Scientific Foundation and P M2.5 Modeling Results), page 4

- 24. December 2012 Retrieved on 8/15/14 from http://www.valleyair.org/Worksho ps/postings/2012/12

- 20

- 12PM25/FinalVersion/04%20Chapter%204%20Sci%20Foundation%20and%20Modeling.pdf

.



### 16

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMEN TS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014



## Table 3 General Air Emission Factors 4



## In addition, t he comparison to certified wood stoves which produce even more useful heat than open hearth fireplaces is even more dramatic. Duraflame logs also contain other chemicals in the wax that lead to generation of other emissions including toxics.

Comment: Proposed rule is not as stringent as wood burning curtailment rules in other air d istricts.

Response: Proposed amendments to Rule 4901 as a whol e are far more stringent then analogous rules in other air districts in California

. No reductions in emissions will be achieved if the District adopted the curtailment thresholds in place in any of the other air districts in California. With the District being at the forefront of wood burning curtailment regulations since 2003, other air districts rules either copied the District’s existing rule or are less stringent. The proposed amendmen ts will result in 5.1 tons per day of reductions in PM2.5 emission s. M atching the curtailment threshold in other air districts ’ rules will not result in any reductions in emissions and in fact may result in an increase in emissions.

As discussed above, the District is going far above any of the other districts and is proposing to lower the No Burn curtailment to 20 μg/m 3 

## , which is 10 μg/m 3 

## lower than any of the other districts and by itself will result in s ignificant emission reductio ns since 95% of the PM2.5 emissions are associated with older high polluting devices. The following are the thresholds for other districts for comparison purposes:

• The South Coast Air Quality Management District (SCAQMD) Rule 445 (Wood

Burning Devices) wa s recently amended in 2013 and has a No Burn curtailment

4 

### Pitzman, L., Eagle, B. Smith, R., Houck, J. OMNI Environmental Services. Dioxin/Furan Air Emissions, General Emissions, and Fuel Composition of Duraf lame Firelogs, and Douglas Fir Cordwood . Prepared for Jim Nolan Puget Sound Clean Air Agency. May 23, 2006.



### 17

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM September 18, 2014 

## threshold of 30 μg/m 3



## – copies District’s current rule, no emissions reductions if adopted in the Valley,

• The Bay Area Air Quality Management District (BAAQMD) Regulation 6

– Rule 3 (Particulate Ma tter and Visible Emissions

– Wood

- Burning Devices) has a No Burn curtailment threshold of 35 μg/m 3



## – less stringent than the District’s current rule and will result in an increase in emissions if adopted in the Valley,

• Sacramento Metro Air Quality Manage ment District Rule 421 (Mandatory Episodic Curtailment of Wood and Other Solid Fuel Burning) implements a tiered curtailment program where the lowest No Burn curtailment threshold begins at 30 μg/m 3 

## while allowing certified devices to burn up to 35 μg/m 3



## – less stringent than the District’s current rule and will result in an increase in emissions if adopted in the Valley.

Supporting Regulatory Analyses

Economic Analysis The District has prepared a cost effectiveness analysis to analyze the economic feasibility of the proposed rule amendments. No significant socioeconomic impacts are expected from this rule project. Refer to Appendix C of the final draft staff report for these analyses.

Rule Consistency Analysis The District prepared a rule consistency analysis that compares the elements of the proposed amendments for Rule 4901 and proposed new Rule 3901 with the corresponding elements of other District rules and fede ral regulations and guidelines that apply to the same type of equipment or source category. The proposed amendments and proposed new rule will not conflict with other District rules, or federal rules, regulations, or policies covering analogous stationary sources. Refer to the final draft staff report for this analysis.

Environmental Impacts The District investigated the possible environmental impacts of the amendments to Rule
4901. Based on the lack of evidence to the contrary, the District has concluded that the rule amendments will not have any significant adverse effects on the environment. As such, the District finds that the rule amendment project is exempt per the general rule that CEQA applies only to projects which have the potential for causing a significant impact on the environment (CEQA Guidelines §15061 (b)(3)). Pursuant to Section 15062 of the CEQA Guidelines, the District will file a Notice of Exemption upon Governing Board approval of amendments to Rule 4901.

FISCAL IMPACT :

In addition to the reductions in emissions from lowering of the No Burn threshold in the rule, we hope to achieve additional reductions through transition to cleaner burning certified devices. Towards that end, today’s recommendations include added incentiv es

18

### SJV U

APCD Governing Board ITEM NUMBER 7: ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL W OOD BURNING PROGRAM September 18, 2014 

## to encourage purchase and installation of cleaner devices. An allocation of $2.1 million for the District’s Burn Cleaner Program is included in the District’s 2014

- 15 budget. Therefore, no budget amendments are needed at this time.

The increase in the number of No Burn days is expected to result in increased enforcement related workload. The proposed registration program is designed to facilitate effective enforcement without the need for intrusive inspection of residential wood burning devices. T he added administrative costs associated with the registration process will be defrayed with the proposed registration fee of $12.50 for every three

years. No fees will be charged for registrations for the first wood burning season in
2014

- 15. The Distri ct expects to have adequate resources in 2014

- 15 to handle the additional enforcement related workload without any increase in staffing. If additional resources are needed as the fiscal impacts of the amendments become more defined, staff will present rec ommendations for additional appropriations to your Board either through annual budget requests or mid

- year budget adjustments, as necessary.

Attachments: Attachment A: Resolution for Proposed Amendments to Rule 4901 and Proposed New Rule
3901 (5 pages) Attachment B: Proposed Amendments to Rule 4901 (14 pages) Attachment C: Proposed New Rule 3901 (2 pages) Attachment D: Final Draft Staff Report with Appendices for Propo sed Amendments to Residential Wood Burning Program ( 20 0 pages) Attachment E: Registration Form s ( 2 page s )

19

### San Joaquin Valley Unified Air Pollution Control District Meeting of the Governing Board September 18, 2014



## ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM

Attachment A :

Resolution for Proposed Amendments to Rule 4901 and Proposed New Rule 3901 ( 5 PAGES)

### SJVUAPCD Governing Board ADOPT PROPOSED AMENDMENTS TO RULE 4901 (WOOD BURNING FIREPLACES AND WOOD BURNING HEATERS) AND ADOP T PROPOSED NEW RULE 3901 (FEES FOR REGISTRATION OF WOOD BURNING HEATERS) September 18, 2014

-1- Resolution for Proposed Amendments to Rule 4901 And Proposed New Rule 3901 

## 1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

SJVUAPCD 1990 E. Gettysburg Ave.

Fresno, CA 93726

(559) 230-6000 

## BEFORE THE GOVERNING BOARD OF THE SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

IN THE MATTER OF: PROPOSED AMENDMENTS TO RULE 4901 (WOOD BURNING HEATERS AND WOOD BURNING FIREPLAC ES) AND PROPOSED NEW RULE 3901 (FEES FOR REGISTRATION OF WOOD BURNING HEATERS) ) ) ) ) ) ) ) RESOLUTION NO. ______________

WHEREAS , the San Joaquin Valley Unif ied Air Pollution Control District (District) is a

duly constituted unified air pollution control district, as pr ovided in Califor nia Health and

Safety Code (CH&SC) Sections (§) 40150 et seq. and 40600 et seq.; and

WHEREAS , said District is authorized by CH &SC §40702 to make and enforce all

necessary and proper orders, rules, and regul ations to accomplish the purpose of

Division 26 of the CH&SC; and

WHEREAS , pursuant to federal Clean Air Act (C AA) §107, the San Joaquin Valley Air

Basin (Valley) has been classified as a nona ttainment area for the national healthbased air quality standards for particulate matter 2.5 microns and smaller (PM2.5); and

WHEREAS, pursuant to CH&SC §39608, the Va lley has been classified as a

nonattainment area for the state health-based air quality standards for PM2.5; and

WHEREAS, for each federal nonattainment pollu tant, federal CAA §172 requires the

District to adopt a plan that provides for the implementation of all reasonably available

control measures as expeditious ly as possible, and that provides for attainment of the

applicable health-based air quality standard; and

WHEREAS , pursuant to the federal CAA and California CAA, the District’s 2012

PM2.5 Plan commits the District to amend Rule 4 901 to lower the episodic curtailment

threshold to reduce directly emitted PM2.5 emissions from this source category; and

WHEREAS , proposed amendments to Rule 4901 woul d incorporate a tiered episodic

wood burning curtailment program whereby a Level One Episodic Wood Burning

### SJVUAPCD Governing Board ADOPT PROPOSED AMENDMENTS TO RULE 4901 (WOOD BURNING FIREPLACES AND WOOD BURNING HEATERS) AND ADOP T PROPOSED NEW RULE 3901 (FEES FOR REGISTRATION OF WOOD BURNING HEATERS) September 18, 2014

-2- Resolution for Proposed Amendments to Rule 4901 And Proposed New Rule 3901 

## 1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

SJVUAPCD 1990 E. Gettysburg Ave.

Fresno, CA 93726

(559) 230-6000 

## Curtailment would be declared in a gi ven geographic area by the District when

pollutant levels are forecast to be equal to or exceed 20 μg/m 3 

## but not to exceed 65

μg/m 3 

## in that area and Level Two Episodic Wood Burning Curtailment would be

declared in said area by the District when pollutant levels are forecast to exceed 65

μg/m 3 

## in said area; and

WHEREAS , a Level One Episodic Wood Burning Curtailment would prohibit the use

of non-registered wood burning heaters and wo od burning fireplaces in a given

geographic area, while the cleanest wood burn ing heaters that are registered with the

District would be allowed to be used in said area; and

WHEREAS , a Level Two Episodic Wood Burning Curtailment would prohibit all wood

burning subject to Rule 4901 in a given geographic area; and

WHEREAS , a registration program would be creat ed for the registration of wood

burning heaters that m eet specific qualification requir ements identified within rule

language; and

WHEREAS , a registration program would be creat ed for the registration of qualified

Wood Burning Heater Professionals to ve rify said wood burning heaters qualify for

registration and are maintained per manufacturer specifications; and

WHEREAS , amendments to the Residential Wood Burning Program will result in a

reduction of directly emitted PM2.5 emi ssions when and where those reductions are

needed most, in urban residentia l areas during periods of atmospheric stagnation; and

WHEREAS , amendments to the Residential Wood Burning Program will result in a

reduction of 5.1 tons per day of directly emitted PM2.5 emissions during the wood

burning season of November through February; and

WHEREAS, clarifications would be added to the density requirements for the

installation of wood burning heaters; and

WHEREAS, an exemption would be added to Rule 4901 rule language to clarify that

open burning is subject to Rule 4103 rule requirements; and

### SJVUAPCD Governing Board ADOPT PROPOSED AMENDMENTS TO RULE 4901 (WOOD BURNING FIREPLACES AND WOOD BURNING HEATERS) AND ADOP T PROPOSED NEW RULE 3901 (FEES FOR REGISTRATION OF WOOD BURNING HEATERS) September 18, 2014

-3- Resolution for Proposed Amendments to Rule 4901 And Proposed New Rule 3901 

## 1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

SJVUAPCD 1990 E. Gettysburg Ave.

Fresno, CA 93726

(559) 230-6000 

## WHEREAS, the District is proposing adminis trative amendments to Rule 4901 to

clarify rule requirements by adding defin itions and removing outdated and redundant

language; and

WHEREAS , new Rule 3901 would complement Ru le 4901 by establishing a $12.50

fee associated with the voluntary registrati on and renewal of qua lifying wood burning

heaters for use during Level One Epis odic Wood Burning Curtailments; and

WHEREAS , new Rule 3901 would co mmit the District to notify individuals with

registered wood burning heaters of the upcoming expiration of said registration no

earlier than 60 days prior to the expiration date; and

WHEREAS , a public hearing for the adoption of proposed amendments to Rule 4901

and adoption of new Rule 3901 was duly noticed for September 18, 2014 in

accordance with CH& SC §40725.

NOW, THEREFORE, BE IT RESOLVED AS FOLLOWS:

1. The Governing Board hereby adopt s the proposed amendments to Rule 4901

(Wood Burning Fireplaces and Wood Burni ng Heaters) and proposed new Rule 3901

(Fees for Registration of Wood Burning Heater s). Said rules shall become effective on

September 18, 2014.

2. The Governing Board hereby finds, based on the evidence and information

presented at the hearing upon wh ich its decision is based, all notices required to be

given by law have been duly given in accordance with CH&SC §40725, and the

Governing Board has allowed public test imony in accordance with CH&SC §40726.

3. In connection with said rulemaking, the Governing Board makes the following

findings as required by CH&SC §40727:

a. NECESSITY. The Governing Board finds, based on the staff report, public

testimony, and the record for this rulemaki ng proceeding, that a need exists for said

rule amendments and said new rule. Adopti ng said rules is necessary to meet the

commitments of the SIP and r equirements of the federal C AA and the California CAA.

### SJVUAPCD Governing Board ADOPT PROPOSED AMENDMENTS TO RULE 4901 (WOOD BURNING FIREPLACES AND WOOD BURNING HEATERS) AND ADOP T PROPOSED NEW RULE 3901 (FEES FOR REGISTRATION OF WOOD BURNING HEATERS) September 18, 2014

-4- Resolution for Proposed Amendments to Rule 4901 And Proposed New Rule 3901 

## 1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

SJVUAPCD 1990 E. Gettysburg Ave.

Fresno, CA 93726

(559) 230-6000 

## Said rules satisfy the commitment in the District’s 2012 PM2.5 Plan

.

b. AUTHORITY. The Governing Board finds that it has the legal authority for

said rulemaking under CH&SC §40000 and 40001.

c. CLARITY. The Governing Board finds that said rules are written or

displayed so that the meani ng can be easily understood by thos e persons or industries

directly affected by said rule.

d. CONSISTENCY. The Governing Board finds t hat said rules are in harmony

with, and not in conflict with or contradictory to, existing statutes, court decisions, or

state or federal regulations.

e. NONDUPLICATION. The Governing Board finds that said rules do not

impose the same requirements as any ex isting state or f ederal regulation.

f. REFERENCE. The Governing Board finds that said rulemaking implements

federal CAA §172(c)(1 ) and CH&SC §40920.

4. The Governing Board hereby finds t hat the requirements of CH&SC §40728.5

and 40920.6 have been satisfied to the gr eatest extent possible, and that the

Governing Board has actively considered and made a good faith effort to minimize

any adverse socioeconomic impacts a ssociated with the proposed rulemaking.

5. The Governing Board finds that, becaus e said rulemaking will have no possible

significant adverse effect on the environm ent, the proposed actions are exempt from

the provisions of the Califo rnia Environmental Quality Act of 1970 (CEQA) under the

provisions of the State CEQA Guidelines §15061 (b)(3).

6. The Executive Director/Air Pollution Control Officer is di rected to file a Notice of

Exemption with the County Clerks of eac h of the counties in the District.

7. The Executive Director/Air Pollution Co ntrol Officer is directed to file with all

appropriate agencies certified co pies of this resolution and the rules adopted herein

and is directed to maintain a record of this rulemaking proceedi ng in accordance with

CH&SC §40728.

### SJVUAPCD Governing Board ADOPT PROPOSED AMENDMENTS TO RULE 4901 (WOOD BURNING FIREPLACES AND WOOD BURNING HEATERS) AND ADOP T PROPOSED NEW RULE 3901 (FEES FOR REGISTRATION OF WOOD BURNING HEATERS) September 18, 2014

-5- Resolution for Proposed Amendments to Rule 4901 And Proposed New Rule 3901 

## 1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

SJVUAPCD 1990 E. Gettysburg Ave.

Fresno, CA 93726

(559) 230-6000 

## 8. The Executive Director/Air Pollution Cont rol Officer is directed to transmit said

rules to the California Air Resources B oard for incorporation into the SIP.

9. The Governing Board authorizes the Ex ecutive Director/Air Pollution Control

Officer to include in the submittal or subsequent documentat ion any technical

corrections, clarifications, or additions that may be needed to secure EPA approval,

provided such changes do not alter the subs tantive requirements of the approved rule.

THE FOREGOING was passed and adopted by t he following vote of the

Governing Board of the San Joaquin Valley Unified Air Pollution Control District this

18th day of September 2014, to wit:

AYES:

NOES:

ABSENT:

SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

By ___________________

______________ Hub Walsh, Chair Governing Board

ATTEST: Deputy Clerk of t he Governing Board

By _____________________ Michelle Franco

### San Joaquin Valley Unified Air Pollution Control District Meeting of the Governing Board September 18, 2014



## ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM

Attachment B :

Proposed Amendments to Rule 4901 ( 14 PAGE S )

# PROPOSED September 18, 2014

4901-1 Proposed Amendments to Rule 4901 

## RULE 4901 WOOD BURNING FIREPLAC ES AND WOOD BURNING HEATERS (Adopted July 15, 1993; Amended July 17, 2003; Amended October 16, 2008; Amended [ rule adoption date ])

1.0 Purpose

The purposes of this rule is are to limit emissions of carbon monoxide and particulate matter from wood burning fire places, wood burning heaters, and outdoor wood burning devices., and to establish a public education program to re duce wood burni ng emissions.

2.0 Applicability

This rule applies to:

2.1 Any person who manu factures, sells, offers for sale , or operates a wood burning fireplace, or wood burning heater , or outdoor wood burning device.

2.2 Any person who sell s, offers for sale, or supplies wood intend ed for burning in a wood burning fireplace or w ood burning heater.

2.3 Any person who transfer s or receives a w ood burning stove or wood burning heater as part of a real pr operty sale or transfer.

2.4 Any person who in stalls a wood burning fireplace or wood burn ing heater in a new residential development.

3.0 Definitions

3.1 APCO: the Air Pollution Control Officer of the San Joaquin Valley Unified Air
Pollution Control District.

3.2 ASTM: the American Society for Testing and Materials.

3.3 Consumer: any person other than a di stributor or a retail er who buys a wood burning fireplace, wood bur ning heater, or outdoor wood burning device.

3.4 Distributor: any person other than a manufacturer or a retailer who sells, offers for sale, or supplies wood burning fireplaces, wood bur ning heaters, or outdoor wood burning devices to retail ers or others for resale.

3.5 EPA: the United States Environmental Protection Agency.

3.6 EPA Phase II Certified: meets the performa nce and emissions standards set forth in the NSPS. Code of Federal Regulati ons, Part 60, Title 40, Subpart AAA.

# PROPOSED September 18, 2014

4901-2 Proposed Amendments to Rule 4901 

## 3.7 Garbage: any solid, semisolid, and li quid wastes generated from residential, commercial, and industrial sources, including trash, refuse, ru bbish, industrial wastes, asphaltic products, ma nure, vegetable or animal solid or semisolid wastes,
and other discarded solid or semisolid wastes.

3.8 Low Mass Fireplace: any fireplace and attached chimney, as identified in ASTM E 2558-7, “Determining Particulate Matter Emission s from Fires in Low Mass Wood-burning Fireplaces,” that can be weighed (including the weight of the test fuel) on a plat form scale.

3.9 Manufacturer: a ny person who constructs or impor ts a wood burni ng fireplace or wood burning heater.

3.10 Masonry Heater: any site-built or s ite-assembled, wood bur ning solid-fueled heating device constructed mainly of ma sonry materials in wh ich the heat from
intermittent fires burned rapidly in its firebox is stored in its structural mass for
slow release to the site. Such wood burning solid-fueled h eating devices must meet the all federal requirements and be designed and constructed per construction specifications set fort h in ASTM E 1602-3, “Guide for Constructi on of Solid Fuel Burning Masonry Heaters.”

3.11 New Residential De velopment: any single or multi-family housing unit, for which construction began on or af ter January 1, 2004. Co nstruction began when the
foundation for the struct ure was constructed.

3.12 New Wood Burning Heat er: any wood burning heater that has not been sold, supplied, or exchanged for the first time by the manufacturer, the manufacturer's distributor or agency, or a retailer.

3.13 Normal Operating Conditions: th e operation of a wood burning heater as defined in this rule, excep t when a fire is started in the wood burning heater,
when fuel is added to the wood burnin g heater, and when the fire is being extinguished. Visible smoke produced during these three events shall not exceed fifteen minutes per event.

3.14 NSPS: New Source Perfor mance Standard. For purposes of this rule the NSPS
is the Code of Federal Regulations, Part 60, Titl e 40, Subpart AAA.

3.15 Outdoor Wood Burning Device: a ny wood burning firepl ace, wood burning stove, or other device designe d to burn wood, and that is located outside of a building or structure. This includes, but is not limited to, burn bowls, fire rings/pits, fire pits, and ch imineas. This does not incl ude fire pits at state parks, national parks, or national forests.

# PROPOSED September 18, 2014

4901-3 Proposed Amendments to Rule 4901 

## 3.164 Paints: any ex terior and interior house and trim paints, enamels, varnishes, lacquers, stains, primers, s ealers, undercoat ers, roof coatings, wood preservatives, shellacs, and other paints or paint-like products.

3.175 Paint Solvents: any orga nic solvents sold or used to thin paints or clean up painting equipment.

3.186 Pellet-Fueled Wood Burn ing Heater: any wood burning heater manufactured for the purpose of heatin g a space and is intend ed to operate on pe llet fuel. which operates on pellet-fuel and is either EPA-certified or is exempted under EPA requirements set forth in the Code of Federal Regulations, Part 60, Title 40, Subpart AAA.

3.197 Pellet Fuel: in cludes, but is not limi ted to, compressed sawdust, compressed paper products, and compre ssed forest residue, wood chip s and other waste biomass, ground nut-hulls and fruit p its, corn, and cotton seed.

3.2018 Permanently Inop erable: modified in such a way that a wood burning heater device can no longer operate as a wood burning heater.

3.2119 PM: particulate matter. PM2.5 has an aerodynamic diameter eq ual to or less than 2.5 microns. PM10 has an aerodynamic di ameter equal to or less than 10
microns.

3.220 Real Property: the la nd itself and anything that is permanently affixed to the land, such as buildings, and structures . Examples of real property include heating and air conditioning systems, wate r lines, or electrical systems that primarily are used to control the environment for people an d to benefit the land.

3.231 Retailer: a ny person engaged in the sale of wood burning fireplaces, wood burning heaters, or outdoor wood burni ng devices directly to the consumer.

3.242 Seasoned Wood: wood of any species that has been sufficie ntly dried so as to contain 20 percent or less moisture by weight.

3.23 Sole Source: the only source of h eat in a residence.

3.254 Treated Wood: wood of any species that has been chemically impregnated, painted, or similarly modified to improve resistance to insects or weathering.

3.265 Used Wood Burning Heater : any wood burning heater that has been used at least once, except wood burning heat ers that have been used by retailers for the purpose
of demonstration.

# PROPOSED September 18, 2014

4901-4 Proposed Amendments to Rule 4901 

## 3.276 Waste Petroleum Product: any petroleum product other than gaseous fuels that has been refined from crude oil, and has been used, and, as a result of use, has been contaminated with physical or chemical impurities.

3.287 Wood Burning Fireplace: any permanently installed masonry or factory built wood burning device designed to be used with an air-to -fuel ratio greater than or equal to 35-to-1.

3.298 Wood Burning Heater: an enclosed, wood burning applianc e capable of and intended for space heating (i .e. wood stove, pellet-fuel ed wood burning heater, or wood burning fire place insert).

3.30 Wood Burning Seas on: for purposes of this ru le, the months of November, December, January, and February.

4.0 Exemptions

The following devices are exempt from the provisions of this rule:

4.1 Devices that are exclusively ga seous-fueled.

4.2 Cookstoves, as described in Co de of Federal Re gulations 60.531.

4.3 Any burning occurring on the ground is open burning a nd is subject to requirements of District Rule 4103.

5.0 Requirements

5.1 Sale or Transfer of Wood Burning Heaters

5.1.1 New wood burning heaters

No person shall advertise, sell, offer fo r sale, supply, install, or transfer a new wood burning heater unless it is either:

5.1.1.1 EPA Phase II certified with a Phase II Certification or a more stringent certification as currently enforced in the NSPS at the time of sale or transfer, or is a

5.1.1.2 A pellet-fueled wood burning heater that is exempt from EPA certification pursuant to requirements in the NSPS, until such
time that amendments to the NSPS are finalized to remove exemptions for pellet-fueled wood burning heaters, then all new wood burning heaters must comply with Section 5.1.1.1.

# PROPOSED September 18, 2014

4901-5 Proposed Amendments to Rule 4901 

## 5.1.2 Used wood burning heaters

No person shall advertise, sell, offer fo r sale, supply, install, or transfer a used wood burning heater unless it has been rendered permanently inoperable, satisfies requirements purs uant to Section 5.1.1, or is EPA Phase II Certified, or is a pellet-fuel ed wood burning h eater, or is a low mass fireplace, maso nry heater, or other wood-b urning device of a make
and model that meets all federal re quirements EPA emission targets and has been approved in writing by the APCO.

5.1.3 Public Awareness Information

Retailers selling or offering for sa le new wood burni ng heaters shall supply public awar eness information with each sale of a wood burning
heater in the form of pamphlets, brochures, or fact sheets on the following topics listed in Sections 5.1.3.1 through 5.1.3.6. 5.1.3.5.
Public awareness information shall be subject to the review and approval
of the APCO.

5.1.3.1 Proper installation, operation, and maintenance of the wood burning heater,

5.1.3.2 Proper fuel selection and use,

5.1.3.3 Health effects from wood smoke,

5.1.3.4 Weatherization methods for the home, and

5.1.3.5 Proper si zing of wood burning heaters, and

5.1.3.6 Episod ic Wood Burning Curtailmen t levels as defined in
Section 5.6.

5.1.4 Sections 5.1.1 and 5. 1.2 do not apply to wood bu rning heaters subject to
Section 5.2.

5.2 Sale or Transfer of Real Property

5.2.1 No person shall sell or transfer any real property which contains a wood burning heater without first assuri ng that each wood burning heater
included in the real property is:
5.2.1.1 EPA Phase II Certified or has a more string ent certification under the NSPS at time of purc hase or installation, or

# PROPOSED September 18, 2014

4901-6 Proposed Amendments to Rule 4901 

## 5.2.1.2 Aa pellet-fueled wood burning heater that was exempt from EPA Certification pursuant to requ irements in the NSPS at the time of purchase or installation, or ,

5.2.1.3 permanently rendered Rendered permanently inoperable. or
removed and render ed inoperable.

5.2.2 Upon the sale or transfer of real property, the seller sh all provide to the recipient of the real property, and to the APCO, documentation of compliance with Section 5.2.1 of this rule. Documentation shall be in the form of a statement signed by the seller describing the type(s) of wood burning heater(s) incl uded in the real property transaction, and any action taken to comply with Section 5.2.1. The APCO shall make blank forms available to the public fo r the purpose of fulfilling this requirement.

5.2.3 Documents required by Section 5.2.2 shall be retained by the recipient of the real property and shall be made available to the AP CO upon request.

5.3 Limitations on Wood Burn ing Fireplaces or Wood Burning Heaters in New Residential Developments

5.3.1 Effective until December 31, 2014

5.3.1.1 No person shall install a wood burning fireplace in a new residential development with a density greater than two (2) dwelling units per acre.

5.3.1.2 No person sha ll install more than two (2) EPA Phase II Certified wood burning heaters per acre in any new residential development with a density equal to or greater than three (3) dwelling units per acre.

5.3.1.3 No person shall install more than one (1) wood burning fireplace or wood burn ing heater per dwe lling unit in any new residential development with a density equal to or less than two (2) dwelling units per acre.

5.3.2 Effective on and af ter January 1, 2015

5.3.2.1 No person shall insta ll a wood burning fireplace in a residential development with a density greater than two (2) dwelling units per acre.

# PROPOSED September 18, 2014

4901-7 Proposed Amendments to Rule 4901 

## 5.3.2.2 No person sha ll install more than two (2) EPA Phase II Certified or more stringent cert ification as curr ently enforced under the NSPS, w ood burning heaters per acre in any residential development with a density greater than two (2) dwelling units per acre.

5.3.2.3 No person shall install more than one (1) wood burning fireplace or EPA Ph ase II Certified or more stringent certification, as currently enforced under the NSPS, per dwelling unit in any residentia l development with a density equal to or less than two (2) dwelling units per acre.

5.4 Advertising Requiremen ts for Sale of Wood

5.4.1 No person shall sell, offer for sale, or supp ly any wood which is orally or in writing, advertised, described, or in any way re presented to be
“seasoned wood” unless th e wood has a moisture content of 20 percent or less by weight.

5.4.2 The APCO may delegate to another pe rson or agency the authority to test
wood for moisture content and determ ine compliance with Section 5.4.1.

5.5 Prohibited Fuel Types

No person shall cause or allow any of th e following materials to be burned in a wood burning fireplace, or wood burning heater, or outdoor wood burning device:

5.5.1 Garbage,

5.5.2 Treated wood,

5.5.3 Plastic products,

5.5.4 Rubber products,

5.5.5 Waste petroleum products,

5.5.6 Paints and paint solvents,

5.5.7 Coal, or

5.5.8 Any other material no t intended by a ma nufacturer for us e as fuel in a wood burning fireplace, wood burning heater, or outdoor wood burning
device. solid fuel burning device.

# PROPOSED September 18, 2014

4901-8 Proposed Amendments to Rule 4901 

## 5.6 Episodic Wood Bu rning Curtailment

This section shall be in effect annually during the months of Nove mber through February.

5.6.1 Level One Episodic Wood Burning Curtailment

The APCO shall declare a Leve l One Episodic Wood Burning Curtailment for a geogra phic region whenever the potential for a PM2.5
concentration is fo recast to equal or exceed 20 μg/m3 but is not likely to exceed 65 μg/m3 for the geographic region.

5.6.1.1 A wood burning fireplace , low mass fireplace, masonry heater, outdoor wood burning device, or nonregistered wood burning heater shall not be operated within the geographic region for which a Level One Episodic Wood Burning Curtailment is in effect.

5.6.1.2 A wood burning heater that has an approved and current registration with the District may be operated within the geographic region for which a Level One Episodic Wood Burning Curtailment is in effe ct provided the wood burning
heater:

5.6.1.2.1 Is not fired on a pr ohibited fuel type pursuant to Section 5.5,

5.6.1.2.2 Is maintained according to manufacturer instructions,

5.6.1.2.3 Is operated acco rding to manufacturer instructions, and

5.6.1.2.4 Has no visible smoke when operated under normal operating conditions.

5.6.2 Level Two Episodic Wood Burning Curtailment

The APCO shall d eclare a Level Two Episodic Wood Burning Curtailment for a geographic regi on whenever the potential for a PM2.5 concentration of greater than 65 μg/m3 or for a PM10 concentration of 135 μg/m3 or great er is predicted for the geographic region. No person within the ge ographic region for which a Level Two Episodic Wood Burning Curta ilment has been declared shall

# PROPOSED September 18, 2014

4901-9 Proposed Amendments to Rule 4901 

## operate a wood burning fi replace, low mass fireplace, masonry heater, wood burning heater, or outdoor wood burning device when a Level Two Episodic Wood Burning Cu rtailment is in effect.

5.6.1 No person shall ope rate a wood burning fire place, wood burning heater, or outdoor wood burning device whenever the APCO notifi es the public that an Episodic Curtailment is in e ffect for the geogra phic region in which the wood burning fi replace or wood burning heater is located.

5.6.2 The APCO shall notify the public of an Episodic Curtailment for a geographic region: whenever the potential for a PM2.5 concentration of 30 μg/m3 or greater or fo r a PM10 concentration of 135 μg/m3 or greater is predicted for the ge ographic region.

5.6.3 The following wood bur ning fireplaces and wood burning heaters are not subject to the provisions of Section 5.6. 1 and 5.6.2:

5.6.3.1 Those in locations where natural gas service is not available. For the purposes of this rule, propane and butane are is not considered natural gas, or.

5.6.3.2 Those that for whom a wo od burning fire place or wood burning heater is are the sole available source of heat in a
residence. This incl udes times of tempor ary service outages, as determined by the gas or electrical utility service.

5.6.4 Episodic Wood Burn ing Curtailment Notice

The APCO shall notify the public of each Episodic Wood Burning Curtailment by any of th e following methods:

5.6.4.1 Provide notice to newspapers of general circulation within the San Joaquin Valley.

5.6.4.2 Broadcast of messages presented by radio or television stations operating in the San Joaquin Valley.

5.6.4.3 A recorded telephone me ssage for which the telephone number is published. in the te lephone directory or newspaper of general circulation within the San Joaquin Valley.

5.6.4.4 Messages posted on the District’s website, www.valleyair.org.

# PROPOSED September 18, 2014

4901-10 Proposed Amendments to Rule 4901 

## 5.6.4.5 Any other such method as th e APCO determines is appropriate.

5.6.5 Contingency Provision

Notwithstanding Section 5. 6.2, on and after si xty days following the
effective date of EPA final rulema king that the San Joaquin Valley Air
Basin has failed to attain the 1997 PM2.5 National Ambient Air Quality Standards by the applicable deadline, the AP CO shall notify the public of an Episodic Curta ilment for a geographic region
whenever a PM2.5 concentration of 20 μg/m3 or greater or a PM10 concentration of 135 μg/m3 is pred icted for the geographic region.

5.7 Registrati on of Wood Burning Heaters

5.7.1 Eligibility for Registration

A wood burning heater is eligible to be regist ered with the District provided it is either:

5.7.1.1 EPA certified with a Phas e II Certification or has a more stringent certification as currently enforced under the NSPS at the time of purchase or installation, or

5.7.1.2 A pellet-fueled wood burning heater exempt from EPA certification requirements pursuant to requirements in the
NSPS at the time of purchase or installation.

5.7.1.3 Wood burning heat ers which do not meet the requirements of
Section 5.7.1.1 or 5.7.1.2 are in eligible for registration.

5.7.1.4 Any re gistration of a wood burning heater which does not meet eligibility requirements is invalid.

5.7.2 Interim Registration of Wood Burning Heaters

5.7.2.1 For the wood burning seas on of 2014/2015 on ly, an Interim Registration program will be in place. A wood burning heater may participate in th e Interim Registration program provided the wood burning heater:

5.7.2.1.1 Meets the eligibilit y requirements pursuant to Section 5.7.1,

# PROPOSED September 18, 2014

4901-11 Proposed Amendments to Rule 4901 

## 5.7.2.1.2 Is registered in the Interim Registration program prior to use during Le vel One Epis odic Wood Burning Curtailments, and

5.7.2.1.3 Is operated in compliance with Section 5.5 and
Section 5.6.

5.7.2.2 Any interim regi stration of a wood burnin g heater which does not meet qualifications pursuant to Section 5.7.1 is invalid.

5.7.2.3 Any interim registration of a wood burning heater may be disqualified pursuant to Section 5.9.

5.7.3 Registration Process

Effective during and af ter the 2015/2016 wood burni ng season, persons applying to register a wo od burning heater shall:

5.7.3.1 Submit a co mpleted application and supplemental documentation demonstrating co mpliance with the eligibility requirements sp ecified in Section 5.7. 1 to the District. Supplemental docume ntation shall include the following:

5.7.3.1.1 R eceipt or invoice from the installation or purchase that in cludes the manu facturer and model name of the wood burning heater, or

5.7.3.1.2 A certification from a District Registered Wood Burning Heater Profession al verifying that the wood burning heater meets eligibility requirements pursuant to Section 5.7.1.

5.7.3.1.3 If the wood burning heater was purch ased and/or
installed more than one year prior to registration with the District, the pe rson must show proof of inspection of the wood burning heater from a District Registered Wood Burning Heater
Professional.

5.7.3.2 Pay a registration fee as re quired by Section 3.0 of Rule 3901 (Fees for Registration of Wood Burning Heaters).

5.7.3.3 Operate the wood burning heater in compliance with the requirements in Section 5.5 and Se ction 5.6.

# PROPOSED September 18, 2014

4901-12 Proposed Amendments to Rule 4901 

## 5.8 Renewal of Registration

5.8.1 Registration shall be valid for a period of up to three wood burning
seasons from the date of registration issuance, unless the holder of the certificate is disqualified pursuant to Section 5.9.

5.8.2 Registration may be renewed by complying with the following requirements:

5.8.2.1 Complete and submit to th e District a Regi stration Renewal application with verification th at the wood burning heater has been inspected by District Regi stered Wood Bu rning Heater Professional to verify that it is maintained pursuant to manufacturer specifications.

5.8.2.2 Payment of a registration renewal fee as required by Section
4.0 of Rule 3901.

5.8.3 Failure to comply with Sectio ns 5.8.1 or 5.8.2 may result in disqualification of registration.

5.9 Disqualification of Registration

5.9.1 If the District fi nds a registered wood burni ng heater is operated in violation of the requirements of this rule, the registration may be disqualified, provided that notice and an opportunity for an office conference was afforded pursuant to Section 5.9.4.

5.9.2 A registration disqualified pursuant to Section 5.9.1 may be reinstated if subsequent to the disqualification th e operator of the w ood burning heater demonstrates compliance with the requirements of Section 5.5 and
Section 5.6.

5.9.3 Persons with a disqualified regist ration pursuant to Section 5.9.1 may appeal the determination by petitioning to the APCO.

5.9.4 Notice of Preliminary Disqualification Determination

If the District makes a preliminary dete rmination that a registered unit is in violation of Section 5.0, the following actions shall be taken:

5.9.4.1 Notify the person who registered th e wood burning heater, in writing, that the District has made a preliminary disqualification determination a nd pursuant to Section 5.9.1

# PROPOSED September 18, 2014

4901-13 Proposed Amendments to Rule 4901 

## the District may cancel the registration 30 calendar days after
the date on the notice. The notice shall include all of the relevant facts relating to the preliminary determination that
are known to the District at the time of the notice.

5.9.4.2 Request as part of the noti fication required by Section 5.9.4.1 that the person who re gistered the wood burning heater confer with the District, in an office conference wi thin 30 calendar days of the date on the notice to discuss the facts relating to the preliminary disqualification determination.

5.9.4.3 Conduct the o ffice conference requir ed by Section 5.9.4.2 provided that the person wh o registered th e wood burning heater accepts the re quest for the office conference.

5.9.5 Setting Aside a Disqualification

A disqualification determination pursuant to Section 5.9.1 shall be set aside by the APCO if the pe titioner demonstrates to the satisfaction of the APCO that the violations forming th e basis for the disq ualification were
the result of circum stances beyond the reas onable control of the petitioner and could not have been prevented by the exercise of r easonable care.

5.10 Registration of Wood Burning Heat er Professionals

5.10.1 To qualify to register as a Wood Burning H eater Professional with the District the applicant must meet one of the following criteria; this must be active, valid, and current:

5.10.1.1 Fireplace Inve stigation Research an d Education (F.I.R.E.) Certified Inspector, or

5.10.1.2 Chimney Safety Institute of America (CSIA) certification, or

5.10.1.3 National Fireplace Ins titute (NFI) certification, or

5.10.1.4 A person determ ined to be qualified to perform inspections, maintenance, and cleaning ac tivities on wood burning heaters by the APCO.

5.10.2 Persons ap plying to register as a Wood Bu rning Heater Prof essional with
the District shall:

5.10.2.1 Submit a completed applicat ion for registration to the District.

# PROPOSED September 18, 2014

4901-14 Proposed Amendments to Rule 4901 

## 5.10.2.2 Submit any n ecessary supplemental docum ents as determined by the APCO as necessary to verify statements and qualifications as presen ted in the application for registration.

5.10.2.3 If the applicant does no t have a certifi cation pursuant to Sections 5.10.1.1 through 5.10 .1.3 the applicant may submit an application to the APCO with supplemental documentation verifying that th e applicant meets the certificati on standards as required by certifi cations pursuant to Sections 5.10.1.1 through 5.10.1.3.

5.10.3 Registration as a Wood Burning H eater Professional with the District is valid for up to three years fr om the date of issuance.

5.10.4 The District shall maintain a list of registered Wood Burning Heater
Professionals on the Di strict web page.

5.11 Inspection of Register ed Wood Burning Heaters

The District has the right of entry for the purpose of inspecting any wood burning heater registered with the District in orde r to enforce or admini ster this rule.

6.0 Administrative Requirements

6.1 Upon request of the APCO, the manufact urer shall demonstrate that each wood burning heater subject to the requirements of Sections 5.1 or 5.2 is compliant with said requirements. meets EPA' s Phase II certification standards as applicable.

6.2 The person who registers the wood burni ng heater shall reta in a copy of the District issued regist ration and make it ava ilable upon request.

7.0 Test Methods

7.1 6.2 Moisture content of wood shall be determined by the current version of ASTM
Test Method D 4442-92.

7.2 Compliance with visible-smoke free operation of the wood burning heater pursuant to Section 5.6 shall be dete rmined using EPA Me thod 22 (Visible Determination of Fugitive Emissions from Material Sources and Smoke Emissions from Flares).

### San Joaquin Valley Unified Air Pollution Control District Meeting of the Governing Board September 18, 2014



## ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM

Attachment C :

Proposed New Rule 3901 ( 2 PAGES)

# PROPOSED September 18, 2014

3901-1 Proposed New Rule 3901 

## RULE 3901 FEES FOR REGISTRATION OF WOOD BURNING HEATERS (Adopted [ date of adoption ])

1.0 Purpose

The purpose of this rule is to establish the fee required for the registration of a wood burning heater (including pellet-fueled wood burning heaters) as defined in Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters).

2.0 Applicability

The requirements of this rule apply to a ny individual who chooses to register a wood burning heater pursuant to District Rule 4901.

3.0 Registration Fee

Applicants registering a wood burning heat er shall pay a non-ref undable registration fee of $12.50 as a part of the application process.

4.0 Renewal Fee

Individuals choosing to re new their registration with the District shall pay a nonrefundable renewal fee of $12.50 as a pa rt of the application process.

No earlier than 60 days prior to the expiration date of the registrati on, the District shall provide the individual with an invoice for the renewal fee. If the individual chooses to renew the registration, then the renewal fee shall be due to th e District within 60 days of
the invoice date.

# PROPOSED September 18, 2014

3901-2 Proposed New Rule 3901 

## This page intentionally blank.

### San Joaquin Valley Unified Air Pollution Control District Meeting of the Governing Board September 18, 2014



## ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM

Attachment D:

Final Draft Staff Report with Appendices for Proposed Amendments t o Residential Wood Burning Program ( 200 PAGES)

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program August 19, 2014

Prepared by: Anna Myers, Senior Air Quality Specialist

Contributors: Shawn Ferreria, Senior Air Quality Specialist David Lighthall, Ph.D., H ealth Science Advisor Janelle Schneider, Air Quality Education Rep II Ana Reyes, Air Quality Education Rep II Chelsea Gonzales, Air Quality Specialist II Mike Oldershaw, Compliance Manager Cat Thao, Senior Air Quality Specialist Megan Cox, Staff Technician II Jesse Madsen, Air Quality Specialist

Reviewed by: Nhia Vu, Supervising Air Quality Specialist Ellyce Baldwin, Comp liance Supervisor Amelia Yuan, Compliance Supervisor Heather Heinks, Public E ducation Administrator Jon Klassen, Program Manager Todd DeYoung, Pr ogram Manager Errol Villegas, Program Manager Michael Carrera, Compliance Manager Ryan Hayashi, Director of Compliance Sheraz Gill, Director of St rategies and Incentives Jessi Fierro, Assistant District Council Annette Ballatore-Williams on, District Council Jaime Holt, Chief Communications Officer Morgan Lambert, Deputy Air Po llution Control Officer Samir Sheikh, Deputy Air Pollution Control Officer 

# Final	Draft	Staff	Report
for	Amendments	to	the
District’s	Residential Wood	Burning	Program

September 1 8

, 2014

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

2 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# Table of Contents

I. Summary .............................................................................................................. 5

II. Importance of Reducing Resident ial Wood Burning Emissions ............................ 7

A. PM2.5 Attain ment .................................................................................................. 7

1. Valley’s Unique Air Q uality Cha llenges ........................................................... 7

2. Residential Wood Burn ing Emissi ons ............................................................. 8

3. PM2.5 Plan Modeling ...................................................................................... 9

B. Health Benefits from Reduc ing Wood Smoke Exposure ..................................... 10

III. Understanding Influence of Meteorological Conditions on Elevated PM2.5 ....... 12

A. Wind and Temperature Instability Provi de the Strongest Mechanisms for Pollution Di ffusion ............................................................................................... 12

B. Humidity and Sunlight Contribut e to PM2.5 Conc entrations ................................ 12

IV. Current Approach to Reduce Emi ssions ............................................................. 13

A. District Rule 4901 ................................................................................................ 13

B. Burn Cleaner Incent ive Progr am ......................................................................... 13

C. Public Educati on and Outr each ........................................................................... 16

V. Evaluation of Potential R egulatory Opportunities to Reduce Emissions ............. 19

A. Increase No Burn Days for Non-Registered Wood Burning Heaters and Wood Burning Fireplaces by Lower ing the Curtailment Level ....................................... 19

B. Encourage Transition to Cl ean Burning H eaters ................................................. 20

C. Allow more burning days fo r clean burning heaters ............................................. 22

D. Expanded Wood Burni ng Season ....................................................................... 23

E. Re-evaluate Current Exempti ons ........................................................................ 24

F. EPA Proposed New Source Pe rformance Standards (NSPS) ............................. 24

VI. Proposed Amendments to the District’s Residential Wood Burning Program ..... 26

A. Proposed Amendments to Rule 4 901 .................................................................. 26

1. Section 1.0 (P urpose) ................................................................................... 26

2. Section 2.0 (Applicability) .............................................................................. 26

3. “Phase II” rule cl arificati ons ........................................................................... 27

4. Addition of “NSPS” for clarificat ion of federal requirem ents .......................... 27

5. Section 3.0 (Def initions ) ................................................................................ 27

6. Section 4.0 (Exe mptions) .............................................................................. 28

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

3 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## 7. Section 5.1 (Sale or Transfer of Wood Burning Heaters) .............................. 28

8. Section 5.2 (Sale or Trans fer of Real Property) ............................................ 29

9. Section 5.3 (Limitations on Wood Burning Fireplaces or Wood Burning Heaters in New Residential Developments) ................................................. 29

10. Section 5.5 (Prohibite d Fuel Types) .............................................................. 30

11. Section 5.6 (Episodic Wood Burning Curtai lments) ...................................... 31

12. Section 5.7 (Registration of Wood Burning H eaters) .................................... 33

13. Section 5.8 (Renewal of Registration) ........................................................... 35

14. Section 5.9 (Disqualificati on of Regist ration) ................................................ 35

15. Section 5.10 (Registration of Wood Burning Heater Pr ofessionals) .............. 35

16. Section 5.11 (Inspection of Regi stered Wood Burni ng Heaters) ................... 37

17. Section 6.0 (Administrat ive Requirem ents) ................................................... 37

18. Section 7.0 (Tes t Methods) ........................................................................... 37

B. Proposed New Rule 3901 (Fees for Registration of Wood Burning Heaters) ...... 38

C. Enhancements to the District’s Burn Cleaner Incentiv e Program ........................ 38

1. Proposed Increased Inc entive Am ounts ....................................................... 38

2. Additional Assistance for Low-Income Re sidents .......................................... 39

3. Updates to Program Docum ents ................................................................... 40

D. Enhanced Forecasting ......................................................................................... 40

VII. Additional Analyses ............................................................................................ 41

A. Global Climate Change and Greenhouse Ga ses ................................................ 41

B. Health Bene fits .................................................................................................... 41

C. Emission Reducti on Analysi s .............................................................................. 41

D. Economic A nalyses ............................................................................................. 42

1. Cost Effectivene ss Analysi s .......................................................................... 42

2. Socioeconomic Analysis ............................................................................... 42

E. Rule Consisten cy Analysi s .................................................................................. 42

F. California Environmental Quality Act Analysi s ..................................................... 43

VIII. Rule Development Proce ss ................................................................................ 44

A. 2012 PM2.5 Plan De velopment ........................................................................... 44

B. Technical Workgroup Co mmittee Meet ings ......................................................... 44

C. Proposed Rule Amendments Guided by Scientific Pub lic Survey ....................... 45

D. Public Wor kshops ................................................................................................ 46

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

4 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## E. Public He aring ..................................................................................................... 46



# L IST OF 

# F IGURES



## Figure 1 San Joaquin Valley Topography Traps Ai r Pollution ..................................... 8
Figure 2 Burn Cleaner Gr aphic .................................................................................. 14
Figure 3 District's Check Before You Bu rn Graphi c ................................................... 16
Figure 4 District RAAN and iPhone A pp Images ........................................................ 17
Figure 5 District Heal thy Air Livi ng Graphi cs .............................................................. 17
Figure 6 Proportion of Residents with a W ood-Burning Fireplace, Wood Stove or Pellet St ove .................................................................................................. 21
Figure 7 Average PM2.5 emissions based on wood burning heater type .................. 22
Figure 8 Illustration of Se ction 5.3.1 R equirement s ................................................... 30
Figure 9 Illustration of Se ction 5.3.2 R equirement s ................................................... 30
Figure 10 Current and Proposed W ood Burning Curta ilment Lev els ........................... 31



# L IST OF 

# T ABLES



## Table 1 Winter Average Emissions (tpd) from Residential W ood Combustion ............... 9
Table 2 Average Number of Days Foreca st Above Curtailmen t Thresholds* ............... 20
Table 3 Days with PM2.5 ≥ 30μg/m 3 

## ............................................................................ 23
Table 4 Proposed Standards for New Wood Stoves and Pe llet Stoves ....................... 25
Table 5 Amendments from Implementi ng the Contingen cy Provision .......................... 33
Table 6 Summary of Proposed Incr eased Incentive Fu nding Amo unts ........................ 39



# A PPENDICES



## Appendix A Comments and Responses
Appendix B Emission Reduction Analysis
Appendix C Economic Analysis
Appendix D Health Benefit Analysis
Appendix E Public Survey Reports
Appendix F EPA List of Certified and Exempt Wood Burning Heaters

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

5 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# I. S UMMARY



## The U.S. Environmental Protection Agency (EPA) periodically reviews and establishes health-based air quality standards for ozone, particulates, and other pollutants. Although the San Joaquin valley’s (Valley) ai r quality is steadily improving, the Valley experiences unique and significant difficultie s in achieving these increasingly stringent standards. The San Joaquin Valley Air Pollu tion Control District (District) has implemented several generations of emissions control measures for those stationary and area sources under its jurisdiction. Sim ilarly, the California Air Resources Board (ARB) has adopted stringent regulations for mob ile sources. Together, these efforts represent the nation’s toughest air pollution emissions controls and have greatly contributed to reduced ozone and particulate matter concentrations in the Valley. Despite the significant progress under these r egulations, greatly aided by the efforts of Valley businesses and resi dents, many air quality challenges remain, including attainment of EPA’s most recent federal air quality standards for particulate matter that is 2.5 microns or less in diameter (PM2.5 ), which is set at a 24-hour average of 35 μg/m3.

The District left no stone unturned in evaluati ng all potential opportunities to reduce directly emitted PM2.5 emi ssions and PM2.5 precursors gui ded by the District’s Board adopted Guiding Principles and Health-Risk Reduction Strat egy. One result of this extensive effort was the commitment to amend District Rule 4901 (Wood Burning Fireplaces and Wood Burning Heat ers). Studies discussed later in this report show that emissions from residential wood burning are not only a major contributor to exceedances of the federal ai r quality standards for PM2.5 but are also toxic to human health and can even cause premature deat h. Modeling performed during the development of the Districts 2012 PM2.5 Plan demonstrates that reductions from this source are an essential compone nt of attaining the federal air quality standards.

The District takes a multidimensional and proac tive approach to reducing emissions in the Valley. This philosophy is especially true for reducing emissi ons from residential wood burning with a combination of regulator y controls through Ru le 4901, public outreach and education, and the District’ s Burn Cleaner Wood Stove Change-out Program (Burn Cleaner Program). The pr oposed amendments to the residential wood burning program will enable Valley residents to play a major role in reducing emissions at almost no cost, and, in many cases, wit h savings in heating-related energy costs. These amendments will encourage Valley resident s to transition from older more polluting wood burning heaters and wood burn ing fireplaces (also commonly called open hearth fireplaces) to cleaner alternatives , by decreasing the number of allowable burn days for high polluting wood burning heaters and fireplaces while at the same time increasing the number of bur n days allowed for register ed clean wood burning heaters through a tiered episodic wood burning curtailment program. The proposed amendments to Rule 4901 wi ll lower the No Burn threshold for high polluting wood burning heaters and fireplaces from the current limit of 30 μg/m 3 

## to 20 μg/m 3 

## . The

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

6 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## proposed amendments will signific antly increase the number of permissible burn days for cleaner certified wood burning devices by raising the No Burn threshold to 65 μg/m 3



## . If approved, the proposed amend ments will double the number of No Burn days for high polluting units that are the source of over 95% of the wintertime residential wood smoke emissions. By contrast, under the proposed ru le, clean certified units will be subject to minimal number of No Burn days ranging fr om zero to six days depending on the location in the Valley during the winter s eason. Updating the District’s Burn Cleaner Program amounts and accessibilit y will also assist with enc ouraging this transition. Emissions reduced through amen dments to the program are significantly greater than those achieved by reducing the curtailment threshold alone, as demonstrated in this report.

This section intentionally blank.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

7 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# II. I MPORTANCE OF 

# R EDUCING 

# R ESIDENTIAL 

# W OOD 

# B URNING 

# E MISSIONS



## Traditional regulatory controls are a core component of the District’s multi-faceted strategies to attain the PM2.5 federal heal th-based air quality st andards. The extreme air quality challenges of the Valley demand t hat the District and the community take extraordinary measures to improve air quality and public health. As a result, the District has developed the most stringent rules in the nation through the implementation of multiple generations of regulations. Sinc e 1992, the District has adopted over 500 rules and rule amendments, requiring t he installation and operation of the most effective air pollution control technologies and processes. Valley businesses are currently subject to the most stringent air quality regulations in t he nation. Despite significant progress in improving the Valley’s air qua lity, more reductions in emissions are needed to attain the ever toughening federal standards. The Dis trict’s attainment plans contain a comprehensive set of local and state measur es to reduce air pollution from stationary and mobile sources throughout the Valley. Ho wever, attaining t he 2006 federal PM2.5 standard is impossible without significant further reductions in wood smoke emissions.

A. PM2.5 ATTAINMENT

Photochemical modeling conducted for the development of the District’s 2012 PM2.5 Plan demonstrates that further reducing emissi ons from residential wood burning would contribute to improved PM2.5 ai r quality in the Valley, thus improving public health and expediting attainment of the PM2.5 federal air quality standards.

1. Valley’s Unique Air Quality Challenges The Valley’s geography, topography, and met eorology exacerbate the formation and retention of high levels of air pollution. The surrounding mountains trap pollution and block air flow, and the mild climate keeps pol lutant-scouring winds at bay most of the year. Temperature inversions, while pres ent to some degree throughout the year, can last for days during the winter holding in nigh ttime accumulations of pollutants including wood smoke. It is during the winter that these days of stagnant weather lead to most of the exceedances of PM2.5 air qu ality standards in the Valley.

Due to these unique circumstances, no other region in California faces the enormous degree of difficulty that the Valley faces in meeting federal air quality standards for ozone and particulate matter. The Valley has far fewer pollutant emissions per square mile (“emission density”) than other regions in California that have equivalent or even better air quality than the Valley. This is but one illustration of the unique challenges facing the Valley due to our geography and topography.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

8 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## Figure 1 San Joaquin Valley Topography Traps Air Pollution

The Valley’s natural challenge in cleaning ou t accumulated pollutants requires that the District and Valley businesses and residents take greater efforts to meet the challenging PM2.5 federal air quality standards and reduc e significant amounts of wintertime emissions. The episodic and seasonal nature of high PM2.5 concentrations helps to narrow the focus of emissions reductions, but it also limits the num ber of months that strategies are most effective in r educing peak PM2.5 concentrations.

2. Residential Wood Burning Emissions Wood smoke contains PM2.5 and an additional la rge number of ultrafine particles less than 0.1 microns (PM0.1). It is also a rich source of gases including carbon monoxide, formaldehyde, sulfur dioxide, irritant gas es, and known and suspected carcinogens, such as polycyclic aromatic hydrocarbons . People can be exposed to wood smoke when they or their neighbors use their wood burning heaters, wood burning fireplaces, or outdoor wood burning devices. Windows and doors cannot keep the particles in wood smoke out of homes. A recent ARB-funded study of residential wood smoke impacts on indoor air quality was conducted in Cambria, California and published in 2011. 1 

## Using aethalometers designed to moni tor carbon black as the definitive chemical signature of wood sm oke, the study found night-tim e outdoor concentrations in Cambria neighborhoods that were two to ten times higher than the cleanest part of the city. Most significantly, over the course of the winter seas on, indoor concentrations of carbon black in non-burning homes were found to be 74% as high as concentrations measured just outside the same homes. This combination of processes results in a

1 

### Thatcher, T. & Kirchstetter, T. (2011). Assessing Near-F ield Exposures from Distributed Residential Wood Smoke Combustion Sources. Report prepared for the Ca lifornia Air Resources Board. Retrieved from http://www.arb.ca.gov/researc h/rsc/10-28-11/item 2dfr07-308.pdf

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

9 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## very high intake fraction (the portion of the total emissions that actually end up being inhaled) from residential wood burning when compared to ot her sources of particulate matter that are less proximate. The following table is a summary of the winter average emissions in the Valley from the resident ial wood combustion source category as identified in the District’s 2012 PM2.5 Plan

. 2



## Table 1 Winter Average Emissions (t pd) from Residentia l Wood Combustion

Pollutant 2014 2015 2016 2017 2018 2019

PM2.5 8.35 8.35 8.35 8.35 8.35 8.35
NOx 0.94 0.94 0.94 0.94 0.94 0.94
SOx 0.15 0.15 0.15 0.15 0.15 0.15



## The emissions from resident ial wood combustion contribut e 15.6% of average winter PM2.5 emitted from stati onary and area sources in t he Valley’s 2012 emission inventory. The 2012 emission in ventory is comprised of thousands of sources, making residential wood burning one of the Valley’s largest sources of directly-emitted PM2.5. Refer to Table 1 for the emission inventory for the residential wood combustion source category. Also, emissions associated with residential wood burning are confined to the time of year when the Valley experiences air quality with PM2.5 concentrations that exceed the 24-hour PM2.5 feder al air quality standards. These emissions occur during the evening time, when inversions are more likely to occur, thus increasing the potential impacts on air quality and human health. Reduc ing emissions will expedite attainment and protect public health, which is a priority under the District’s Health-Risk Reduction Strategy given the significant localized heal th impacts associated with residential wood smoke.

3. PM2.5 Plan Modeling The Valley is one of the most studied air sheds in the world in terms of the number of publications in peer-reviewed scientific journal s and other major reports. Such scientific analyses, and the field studies providing t he data for these analyse s, are the foundation of the modeling efforts for the District’s 2012 PM2.5 Plan . Public and private sector partnership through the San Joaquin Valley Air Pollution Study Agency (Study Agency) provided funding and coor dination for many of these efforts. In particular, the Study Agency’s $28 million, ongoing California R egional Particulate Air Quality Study (CRPAQS) efforts have improved understandi ng of the Valley’s PM emissions, composition, and the dynamic atmospheric processe s surrounding them. Through CRPAQS and the establishment of a strong scientific f oundation about PM2.5 in the Valley, researchers have developed methods to identify the most efficient and costeffective emissions control strategi es to reduce PM2.5 concentrations.

2 

### SJVUAPCD (2012). 2012 PM2.5 Plan. Appendix D (Stationary and Area Source Control Strategy Evaluation). Retrieved on 8/15/14 from http://www.valleyair.org/Workshops/postings/2012/12-20- 12PM25/FinalVersion/14AppendixDStationaryandArea.pdf

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

10 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## In developing the District’s 2012 PM2.5 Plan , the District and ARB took full advantage of the extensive scientific research and knowledge that has been developed to characterize the Valley’s unique air quality chemistry and challenges. CRPAQS and the subsequent research built on its foundation, has shed light on the complexity of PM2.5 in the Valley. Using the extensive body of knowledge regarding formation of PM2.5 in the Valley, ARB performed extensive modeling to predict future PM2.5 concentrations throughout the Valley. This modeling was performed consistent with EPA guidance, and involved thousands of hour s of sophisticated computer modeling and review by a team of technical staff, in cluding close coordination with the District. The modeling approach was reviewed and vetted through a tec hnical advisory process that involved researchers and EPA. In addition to the modeling by ARB, the District has also performed extensive analysis that provides additional supporting evidence that the District’s 2012 PM2.5 Plan will effectively bring the Valley into attainment. Because of the concentration effect of winter nightti me inversions, urban residential wood combustion has a disproportionate impact on daily and yearly PM2.5 concentrations at urban monitors making emission reductions from residential wood burning a key contributor to bringing the entire Valley into attainment of the PM2.5 federal air quality standards.

B. HEALTH BENEFITS FROM RE DUCING WOOD SMOKE EXPOSURE

Based on a large body of interrelated scientif ic research conducted in the Valley and elsewhere, episodic curtailm ents of residential wood combus tion under Rule 4901 have resulted in substantial health benefits for the Valley population. The large value of these benefits is related to (1) the high leve l of cumulative population exposure to urban residential wood combustion emissions compar ed to other sources, (2) the relative effectiveness of burning curtailments in reduc ing per capita PM2.5 exposure levels in urban areas where the Valley popul ation is concentrated, (3) the relative toxicity of chemicals found in PM2.5 that are gener ated by wood combustion, and (4) the overnight penetration of PM2.5 into neighboring homes. As a result of these factors, Rule 4901 is a key component of the District’ s Health-Risk Reduction Strategy that was put forward in the District’s 2012 PM2.5 Plan . The Health-Risk Reduction Strategy goes beyond a simple focus on PM2.5 mass and incorporates additional health-related metrics (such as PM0.1 exposure) for priori tizing control strategi es for individual emission sources.

Polycyclic aromatic hydrocarbon species are recognized as potential carcinogens and are also highly implicated in the triggering of oxidativ e stress that promotes the malfunctioning of the immune system, par ticularly among previously sensitized individuals such as asthmatics. 3 

## The toxic air pollutants in wood smoke can cause human health impacts such as coughs, headaches, and eye and throat irritation. Studies also show that prolonged inhalati on of wood smoke contributes to chronic

3 

### Kelly, F.J. (2006) Oxidative Stress: Its Role in Air Po llution and Adverse Health Effects. Occupational Environmental

Medicine 60:612–616. Retrieved from http://oem.bmj.com/content/60/8/612.full

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

11 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## interstitial lung disease, 4 

## pulmonary arterial hypertension, 5 

## and pulmonary heart disease, 6 

## which can eventually lead to heart failure in adults. 7 

## Wood smoke has also been linked to detrimental mutagenic and system ic effects such as oxidative stress and blood coagulation, which can ultimately re sult in cell damage and possibly lead to

cancer. 8,9,10 

## Children with the highest exposure to wood smoke show a significant decrease in lung function. 11



## On a regional level, the enc losed geophysical environment of the Valley acts to magnify the health impacts of wintertime residentia l wood combustion. The Valley regularly experiences multi-day periods of atmospher ic stagnation during which very little air mass is transferred in and out of the Valley. The net result is a day-to-day buildup of PM2.5 levels. Compounding these multi-day stagnation events, the region experiences severe winter inversions upon nightfall, characterized by a marked reduction in the height of the mixing layer. This results in a magnified conc entration of directly emitted particulates that envel op urban neighborhoods.

Windows and doors cannot prevent ultrafine par ticles in wood smoke from penetrating homes, meaning neighboring hous eholds that are downwind of wood-burning neighbors during inversion events are exposed to t he wood smoke of thei r neighbors.

In 2008, the Central Valley Health Policy In stitute found that District wood burning curtailments on high pollution days reduced annua l exposure by 13.6% in daily PM2.5 exposure for Fresno, and an esti mated 12.9% for Bakersfield 12 

## resulting in 30 to 70 avoided cases of annual prematur e mortality. The increase in the number of curtailment days resulting from the lower threshold ad opted in the 2008 amendments to Rule 4901 has resulted in a proportional increase in t he health benefits of the rule. Further proportional health benefits can be expecte d from lowering the threshold again.

4 

### Defined as a group of lung diseases affe cting the interstitium resulting in a progressive scarring of lung tissue. The scarring

associated with interstitial lung disease eventually affects t he ability to breathe and get enough oxygen into the bloodstream.

5 

### Pulmonary arterial hypertension begins when tiny arteries in the lungs, called pulmonary arte ries, and capillaries become

narrowed, blocked, or destroyed. Making it harder for blood to flow to the lungs, and raises pressure within lung arteries.

6 

### Defined as an abnormal enlargement of the right side of the heart resulting from high blood pressure in the pulmonary blood

vessels (aka pulmonary arterial hypertension).

7 

### Sandoval, J.; Slas, J.; Martinez -Guerra, M.L.; Gomez, A.; Mart inez, C.; Portales, A.; Paloma r, A.; Villegas, M.; and Barrios, R.

Pulmonary Arterial Hypertension and Cor Pulmonale Associat ed with Chronic Domestic Woodsmoke Inhalation. (1993) Chest 103:12-20.

8 

### Danielsen, P.H.; Bräuner, E.V.; Barregard, L.; Sällsten, G.; Wallin, M.; Olinski, R.; Rozalski, R.; Møller, P.; Loft, S. Oxida tively

damaged DNA & its repair after experimental exposur e to wood smoke in healthy humans. (2008) Mutat Res . 642(1-2):37- 42.

9 

### Barregard, L.; Allsten, G.S.; Gustafson, P.; Johansson, L.; Johannesson, S.; Basu, S.; Stigendal, L. Experimental Exposure

to Wood-Smoke Particles in Healthy Humans: Effects on Mark ers of Inflammation, Coagul ation, and Lipid Peroxidation (2006) Inhalation Toxicology 18:845–853.

10 

### Sapkota, A.; Gajalakshmi, V.; Jetly, D. H.; Roychowdhury, S.; Dikshit, R.P.; Brennan, P.; Hashibe, M.; Boffetta, P. Indoor air

pollution from solid fuels and risk of hypopharyngeal/laryngeal and lung cancers: a multicentric case-control study from India. (2008) Int J Epidemiol . 37(2):321-8.

11 

### Heumann, M.; Foster, L.R.; Johnson, L; Kelly, L. Woods moke Air Pollution and Changes in Pulmonary Function Among

Elementary School Children (1991) Air & Waste Management Association 84th Annual Meeti ng & Exhibition, Vancouver, British Columbia.

12 

### Lighthall, D., D. Nunes, and T. Tyner. Environmental Health Evaluation of Rule 4901: Domestic Wood Burning. Central

Valley Health Policy Institute, Calif ornia State University, Fresno. See www.cvhpi.org

.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

12 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# III. U NDERSTANDING 

# I NFLUENCE OF 

# M ETEOROLOGICAL 

# C ONDITIONS ON 

# E LEVATED 

# PM2.5

Weather plays a key role in atmospheric PM 2.5 concentrations. Various meteorological conditions not only determine how fast PM2.5 par ticles are dispersed, it also controls how fast photochemistry converts precursor em issions into PM2.5 and controls whether or not certain gases are in a particulate (sol id) phase or a gas phase. There are several key meteorological physical properties that influence PM2.5 concentrations.

A. WIND AND TEMPERATURE INST ABILITY PROVIDE THE STRONGEST MECHANISMS FOR POLLUTION DIFFUSION

A common misconception is that rainfall is w hat primarily disperses pollutants; however, horizontal and vertical mixing is required to di sperse PM2.5 pollutants in the air. PM2.5 levels will not decrease on days when there is rainfall without signific ant wind. In order to disperse particulates in the atmospher e, wind flow (horizont al mixing) and/or temperature instability (decreasing temperat ure with height leading to vertical mixing) provide the strongest mechanisms for dispersing pollutants.

Atmospheric stability refers to the vertical mixing of the atmosphere. An inversion is defined as the temperature increasing with vertical height. Prolonged periods of high pressure and stable conditions with low wind speeds can cause stagnant conditions that trap pollutants near the earth’s surface. PM2.5 concentrations increase during these poor dispersion periods. During low pressure events unstable conditions and stronger wind speeds occur. PM2.5 concentrations can decrease or increase depending on the strength and characteristics of the low pressure system.

Generally, the higher the wind speed the lower the PM2.5 concentrations. Winds mix pollutants and disperse them over a larger area, which generally im proves air quality.

B. HUMIDITY AND SUNLIGHT CONTRIBUTE TO PM2. 5 CONCENTRATIONS

Humidity and sunlight can lead to the cr eation of PM2.5 through photochemistry. In essence, particulate ammonium nitrate (NH4NO3) forms when the concentration product of gas-phase ammonia (NH3) and nitric acid (HNO3) exceeds a saturation point dependent on temperature, relati ve humidity, and the composit ion of the pre-existing particles that act as condensation s ubstrate (Wexler and Seinfeld, 1991). 13 

## The fraction of reactive nitrogen that form s nitric acid and/or nitrate depends on the concentration of NOx and VOC as well as meteorological condit ions such as temperature, relative humidity, and solar intensity. 14



## , 15

13 

### Wexler, A.S., Seinfeld, J.H. (1991). 2nd-Generation inorganic aerosol model. Atmospheric Environment Part aGeneral Topics 25 (12), 2731–2748.

14 

### Aw, J., Kleeman, M.J. (2003). Evaluating the First-Order E ffect of Intra-Annual Temperature Variability on Urban Air Pollution. Journal of Geophysical Research-Atmospheres 108 (D12).

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

13 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# IV. C URRENT 

# A PPROACH TO 

# R EDUCE 

# E MISSIONS



## The District takes a multifaceted and proacti ve approach to reducing emissions from residential wood burning. Equal ly important to regulatory controls are the District’s public outreach and education efforts which are aimed at giving the public a better understanding of why emissions from residential wood burning are so important and to empower them to know that they too can take actions to reduce emissions. Another component of the Districts efforts includes in centive programs to assist with the cost impacts of replacing older more polluting wood burni ng heaters and wood burning fireplaces with cleaner alternatives.

A. DISTRICT RULE 4901

District Rule 4901 is one of the most health pr otective District rules because it reduces emissions when most needed, such as during multi-day periods of stagnation and in the evening hours; and where the emissions reductions are needed most, in densely populated areas such as neighborhoods.

Adopted in 1993 and subsequently amended in 2003 and 2008, District Rule 4901 has been essential to limiting winter time directly emitted PM2.5 emissions in the Valley. Applicable to wood burning fireplaces, w ood burning heaters, and outdoor wood burning devices, Rule 4901 limits emissions by restri cting the sale and transfer of wood burning heaters to EPA certified wood burning heater s; setting limits on the number of wood burning fireplaces and wood burni ng heaters installed in new residential developments; establishing a list of prohibited fuel ty pes; and implementing episodic wood burning curtailments for days when air quality is foreca sted to exceed the curtailment threshold.

B. BURN CLEANER INCENTIVE PROGRAM

The District’s Burn Cleaner Wood Stove C hange-out Program (Burn Cleaner Program) plays a key role in the success of the transit ion from older more polluting wood burning heaters and fireplaces to cl eaner wood burning heaters. Si nce 2006, the Burn Cleaner Program has been helping resi dents overcome some of the financial obstacles in purchasing cleaner alternatives. There are cu rrently more than 30 hearth retailers in the Valley that have part nered with the District to successfu lly implement the Burn Cleaner Program.

15 

### Nguyen, K. & Dabdub, D. (2002). NOx and VOC Cont rol and Its Effects on the Formation of Aerosols. Aerosol Science and Technology 36 (5) , 560–572.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

14 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## The Burn Cleaner Program helps residents overco me some of the financial obstacles in purchasing cleaner alternatives through mu ltiple levels of incentive funding:

 $500 to replace a qualifying unit with a gas heater

 $250 to replace a qualifying unit with a qualif ying pellet-fueled wood burning heater

 $100 to replace a qualifying unit with qualifying wood burning heater

The District’s low-income incentive amount of $1,500 per qualifying unit for applicants
that meet the District’s low-in come criteria continues to be critical in assisting lowincome households with the transiti on to cleaner burning alternatives.

Figure 2 Burn Cleaner Graphic

During the 2013-14 wood-burning season t he District issued 717 vouchers under the standard incentive funding levels totaling $313,500. Under the low-income incentive component, the District funded $57,000 for th e replacement of 38 wood burning heaters. To date, the Distr ict has provided funding of over $2.3 million towards the replacement of 4,083 wood burning heaters th rough the Burn Cleaner Program, of which, 323 are verified low-in come Valley residents.

Recently Implemented Enhancements The District recently implemented enhancement s to the Burn Cleaner Program in the 2013/14 winter season to furt her outreach efforts and impr ove the usability of the program. The following is a summary of some of the ke y enhancements:

Low-income provisions As part of the District’s ongoing efforts to encourage more low-income qualified applicants to participate in the Burn Clean er Program, significant enhancements were made to the low-income cat egory of the Burn Cleaner Program. One of the key enhancements includes reducing a substantial portion of the upfront, out-of-pocket cost of a new qualifying unit. The District has par tnered with contracted hearth retailers to allow low-income qualified ap plicants to make the purchase at a reduced price by deducting the incentive amount from the invoice at the point of purc hase. Allowing the incentive funding to be directly applied when purchase is made makes it more feasible for additional low-income applicants to take advantage of the program.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

15 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## Even though a higher incentive amount is prov ided to low-income applicants under the program, the District recognizes that the upfront cost of a new wood burning heater can still pose a financial challenge for many of those applicants and become a deterrent for them to participate in the program.

Additional enhancements include refining the lo w-income eligibility form to streamline the determination process and identifying the hearth retailers that provide the reduced upfront cost option.

Program documents in Spanish Program documents are now ava ilable in Spanish to furthe r extend the outreach efforts to the local community. While District st aff is open and available to assist applicants with explaining how the progr am works and filling out t he forms, the documents in Spanish are accessible for those who would like to review and complete the documents on their own.

Incentive program documents Updates to program documents have made t hem more user-friendly and has further improved the process during t he application, installation, and claim for payment request phases. Key enhancements include:

 Submittal of the pre-installation phot o of the old wood burning heater or wood burning fireplace during t he application phase to deter mine eligibility.

 The application now includes a section to provide the retailer’s information and projected installation date as an option. This helps the District work with the applicant and retailer to ensure that everyt hing done is within program guidelines.

 Heater-rated gas fireplaces have been identified in program documents as eligible for the Burn Cleaner Program.

Document submittal process Applications and claim for payment requests can now be emailed to the District for faster processing. Supplemental forms have been developed to further streamline the review process and help keep the retailers and applicants informed on the status of projects.

Collaboration with partic ipating hearth retailers The District has renewed its contracts with the hearth retailers and hosted informational meetings to discuss program changes in or der to ensure a smooth roll out of the enhancements. As part of the District’s init iative to increase the effectiveness of the program, District staff has wo rked closely with the participating hearth retailers on outreach efforts and provided them with promot ional tools, such as flyers and quick screens with information about the Burn Cleaner Program.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

16 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## C. PUBLIC EDUCATION AND OUTREACH

The District has an extremely successful out reach and education program with regards to residential wood burning and educating Vall ey residents about air quality, the effects of air pollution on the population’s health, and on options they can take to reduce emissions. In the 2013-14 wood-burning seas on the District took part in 51 media interviews about extreme w eather and wood burning.

The District’s informational Check Before You Burn program minimizes elevated PM2.5 concentrations throughout the winter. The PM2.5 air quality improvements that the Valley has experienced since the adopti on of Rule 4901 have been assisted by strong multimedia outreach by the Di strict and a resultant increas e in public awareness and participation in winter District programs.

Figure 3 District's Check Before You Burn Graphic

During the wood-burning season of 2013-14, the District Outreach staff received hundreds of public calls and emails specific to residential wood burning. An interesting new trend has surfaced regarding public op inion, an increased number of the phone calls were in support of an outright ban on residential wood burning year-round (with the exception of residents for whom wood burning is the sole source of heat). This is attributed to heightened awareness among t he general population of the deleterious effects of wood burning on public health.

Since the inception of Check Before You Burn , the District’s complementary tools, such as the Real-time Air Advisory Network (RAAN) and the “Valley Air” smart phone app, have continued to gain in popularity. Annual publ ic call and website “hit” statistics, plus growth in the District’s Facebook page activity , also illustrate continued growth in woodburning awareness. Survey results discuss ed in this staff report also show an increased public awareness with eight out of ten respondents being aware of the District’s Check Before You Burn program, 78% of whom confirmed reduced woodburning activities as a direct result of the program.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

17 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## Figure 4 District RAAN and iPhone App Images

The District also incorporates wood-bur ning messaging into other public outreach products, including Healthy Air Living Schools materials, “Blue Sky, Brown Sky ... It’s Up to You!” elementary curri culum and other materials.

Figure 5 District Heal thy Air Living Graphics

Multimedia Advertising Campaign The District’s seasonal public outreach adver tising campaign is retooled each year to include timely and relevant messaging. In the past few seasons, this messaging has been delivered by the District’s Governing B oard members, with billboards in English and Spanish strategically pl aced throughout the Valley, radio and TV spots, and valueadded messaging delivered through m edia throughout the Valley.

Expanding New Media Outreach The most significant evolution of Check Before You Burn messaging has occurred with the expanded and accelerated use of new media: Facebook and Twitter posts. Facebook “likes” have nearly doubled from t he 2012-13 season, to more than 1,100 at the end of the 2013-14 season. This has proven to be a valuable way to deliver immediate messaging regarding wood-burning statuses, in addition to providing a platform for direct, two-way interaction with the public.

Strengthening Media Partnerships The District maintains partnerships with television, newspaper, radio, outdoor and print, as well as more non-traditional media, su ch as on-screen messaging in local movie theaters, internet advertising and video loops in medical offices. During seasonal Check Before You Burn campaigns, the District runs media on 11 broadcast television stations in the Fresno and Bakersfield markets, including four Spanish stations, as well as 10 cable networks in four cable markets including zoned cable in Stockton, Modesto,

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

18 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## Turlock and Manteca. In the Sacramento ma rket, which includes the District’s northern counties, the wood-burning message runs on tw o English language broadcast television stations and one Spanish language broadcast television station.

The District also typically runs messaging on 42 radio stations and 18 newspapers (six of them Spanish) throughout the eight-county area. Check Before You Burn outdoor messaging appears on more than 100 outdoor bill boards (including large-format vinyl billboards) and smaller “one-sheets” in Envi ronmental Justice communities throughout the Valley. With these purchases come added value in the form of bonus spots, news sponsorships, and extra billboards and overages in outdoor messaging. Outdoor messaging is strategically placed in high-tr affic areas as well as neighborhood and rural communities to ensure a wide reach in t hose areas where residential wood burning might be common.

The District’s print campaign incl udes major papers such as the Bakersfield Californian

, Fresno and Modesto Bees and Stockton Record , but also rural newspapers such as the Arvin Tiller

, Manteca Bulletin and Shafter Press . The District also appears in each issue of the Bakersfield Business Journal, which o ffers the opportunity to promote seasonal campaigns. Media buys allow leveraging bu ying power that typically returns an additional $100,000+ in media placement. The related Cinemedia campaign is also regularly featured on 100 movie screens from Stockton to Bakersfield, with more than 25,000 spots that reach more than 475,000 people.

This section intentionally blank.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

19 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# V. E VALUATION OF 

# P OTENTIAL 

# R EGULATORY 

# O PPORTUNITIES TO 

# R EDUCE 

# E MISSIONS



## The District periodically evaluates stati onary sources for potential opportunities to further reduce emissions. Po tential opportunities to reduce emissions from the residential wood burning source category that were identified for further evaluation during the development of the District’s 2012 PM2.5 Plan include lowering the curtailment threshold level, allowing the use of cleaner w ood burning heaters under certain circumstances, the possibility of extending the wood burning season, and the possibility of amending the porti on of the rule pertaining to the quantity of units allowed in new developments. These potential opportuni ties were further evaluated as a part of the development of these ru le amendments. The followin g is a summary of those evaluations.

A. INCREASE NO BURN DAYS FOR NO N-REGISTERED WOOD BURNING HEATERS AND WOOD BURNING FIREPLACES BY LOWERING THE CURTAILMENT LEVEL

Currently the District prohibits residential w ood burning activities in each County within the Valley when PM2.5 concentrations are forecast to equal to or exceed 30 μg/m 3 

## in that county. These prohibitions are called No Burn days. Lowering the current episodic curtailment level would reduce emissions by increasing the number of No Burn days. The increase in No Burn days would reduce the build-up of emissions during the long stagnation periods experienced in the Valley during the winter season, as previously discussed.

The District estimated the av erage number of additional No Burn days likely to occur in future years as a result of lowering the curt ailment level from the current threshold level of 30 μg/m3 to the draft threshold level of 20 μg/m3. The average increase in No Burn days in future years in each county was calc ulated by averaging the historical data from the past five wood burning seasons of the number of days with PM2.5 concentrations were forecast to be equal to or exceed 30 μg/m3 versus 20 μg/m3. This analysis is summarized in Table 2. The estimated aver age increase in No Burn days in future years would be 34 days per county (an average of the last column in Table 2) per wood burning season. However, the estimation of 34 additional No Burn days per wood burning season in the future will vary. No Burn days are called based on the air quality forecast for each day and are dependent on severa l variables as discussed in this staff report.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

20 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## Table 2 Average Number of Days Forecast Above Curtailment Thresholds*

County Current Threshold ( ≥ 30 μg/m3) Proposed Threshold ( ≥ 20 μg/m3) Additional No Burn

days
San Joaquin 24 53 29
Stanislaus 36 72 36
Merced 19 55 36
Madera 29 67 38
Fresno 49 85 36 Kings 39 70 31
Tulare 36 69 33
Kern 44 79 35
*Based on Forecast values from the 2009- 10, 2010-11, 2011-12, 2012-13, 2013-14 woodburning seasons



## Although a No Burn day can potentially incr ease a resident’s natural gas costs from using a central heating system in lieu of a w ood burning heater, this potential cost is offset by the central heating system since a central heating system more efficiently heats the whole home, resulting in less money being spent on firewood based on the increase in No Burn days. Compared to other District rules, curtailing residential wood burning under Rule 4901 is the most cost e ffective rule for reducing directly emitted PM2.5 emissions.

B. ENCOURAGE TRANSITION TO CLEAN BURNING HEATERS

The Valley would experience greater ai r quality and health benefit s throughout the wood burning season if more residents transitioned from older more pol luting wood burning heaters and wood burning fireplaces to clean burning alternatives beyond the benefits gained by only lowering the episodic curtailment threshold from 30 μg/m3 to 20 μg/m3.

A third party survey of Vall ey residents (see Appendix E) re vealed that the majority of Valley residents do not have wood burning heaters or wood burning fireplaces. However, of those that do have wood burning heaters and wood burning fireplaces, the majority have wood burning fi replaces, refer to Figure 6 Proportion of Residents with a Wood-Burning Fireplace, Wood Stove or Pelle t Stove) for a graphica l representation of the proportion of Valley resident s with wood burning he aters, pellet-fueled wood burning heaters, and wood burning fireplaces.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

21 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## Figure 6 Proportion of Residents with a Wood-Burning Fireplace, Wood Stove or Pellet Stove

EPA reports that 75% of wood stoves (also called wood burning heaters) in the United States are non EPA-certified stoves. EPA certified wood burning heaters produce 70% less particle pollution then their older dirtie r counterparts, refer to Figure 7 for the EPA reported average PM2.5 emissions bas ed on wood burning heater type.

Survey results indicate the most effectiv e ways to encourage transition to clean burning heaters is to allow more wood burning da ys for less polluting wood burning heaters and update the District’s Burn Cleaner Program to increase incentive amounts. By encouraging Valley residents to transition to clean wood burning heaters, emissions would not only be reduced on No Burn days but also on days when burning is allowed. This health and air quality benefit would occur because cleaner alternatives such as EPA Phase II Certified wood burning heaters and pellet-fueled wood burning heaters, and gaseous-fueled heaters would be in use in stead of the older more polluting wood burning heaters and wood burni ng fireplaces, as illustrated in Figure 7. No Wood-Burning Device, 68% Pellet Stove, 3% Wood Stove, 4% Wood-Burning Fireplace, 25%

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

22 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## Figure 7 Average PM2.5 emissions based on wood burning heater type 16



## C. ALLOW MORE BURNING DAYS FOR CLEAN BURNING HEATERS

A tiered approach to episodic wood burning cu rtailments would allow more burn days for less polluting wood burning heat ers at the same time as in creasing the number of No Burn days for the older more polluting wood burning heaters and wood burning fireplaces. The two tiers under consideration would reduce the curtailment threshold for the more polluting wood burni ng heaters and wood burning firepl aces from the current level of 30 μg/m3 to 20 μg/m3 as discussed a bove, and the second tier would prohibit all residential wood burning when PM2. 5 concentrations are forecast to exceed 65 μg/m3. Analysis indicates this tiered curtailment approach would result in greater emissions reductions than would occur from only reduci ng the curtailment threshold from 30 μg/m3 to 20 μg/m3 because of the incentive of additional burn days for Valley residents for registered wood burning heaters (see Appendix E). As such , the District recommends implementing a tiered approach to episodic cu rtailments. See Figure 10 on page 30 for a visual representation of the proposed new tiered episodic curtailm ent approach.

16 

### Modified from: EPA. Consumers – Energy Efficiency and W ood-Burning Stoves and Fireplaces. (2012, November 14). Retrieved from http://www.epa.gov/burnwise/energyefficiency.html

.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

23 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## D. EXPANDED WOOD BURNING SEASON

Extending the wood burning curtailment se ason was analyzed as a potential opportunity for further reducing emissions from the residential wood burning source category. The current wood-burning season runs from t he beginning of Novem ber until the end of February. Expanding the wood-burning season to include October and/or March could potentially increase the number of No Burn days in each wood-burning season. Measured Valley concentrations of levogluc osan, a primary indicator for wood burning, are not nearly as high in October or Ma rch as found to be dur ing the current wood burning season of November through February . Additionally, a six-year average was calculated for the number of No Burn da ys in each county from 2008 through 2013 for the months of October and Marc h as illustrated in Table 3. The resulting estimated number of increased No Burn days based on hist orical data is in the range of less than one day up to six days. Extending the wood burning season would not significantly benefit air quality in the Valley due to the co mbination of less extensive burning activity and the minute number of additional No Burn da ys. Therefore, it is not recommended that the wood burning s eason be extended.

Table 3 Days with PM2.5 ≥ 30μg/m 3



## County Month 2008 2009 2010 2011 2012 2013 Average

Fresno March 3 0 0 0 0 0 0.5

Kern March 2 0 0 1 0 2 0.8 Kings March 1 0 1 0 0 4 1

Madera March NA NA NA 0 0 0 0

Merced March 0 0 0 0 0 0 0 San Joaquin March 0 0 0 0 0 0 0

Stanislaus March 0 0 0 0 0 0 0

Tulare March 2 0 0 0 0 3 0.8

Fresno October 6 2 2 7 1 1 3.2

Kern October 6 6 3 3 2 NA 4 Kings October 10 9 7 10 2 1 6.5

Madera October NA NA NA 3 0 0 1

Merced October 3 0 2 0 0 0 0.8 San Joaquin October 2 0 0 0 0 0 0.3

Stanislaus October 5 1 2 5 0 0 2.2

Tulare October 4 5 1 6 0 3 3.2

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

24 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## E. RE-EVALUATE CURRENT EXEMPTIONS

District Rule 4901 currently has two exempti ons in the Exemptions Section (Section 4.0). Section 4.1 exempts heaters that are exclusively gaseous-fueled and Section 4.2 exempts Cookstoves. Evaluation of these two exemptions did not reveal potential opportunities to reduce emissi ons; therefore, no amendments to the exemption section of Rule 4901 are recommended at this time.

F. EPA PROPOSED NEW SOURC E PERFORMANCE STANDARDS (NSPS)

On February 3, 2014, EPA published proposed am endments to 40 CFR Part 60 Subpart AAA, Standards of Performance for New Residential Wood Heaters. 17 

## The proposed rule lowers emission limits for currently ce rtified wood heaters and sets certification emission limits for a broader range of wood- or pellet-burning heaters, stoves, and home heating appliances not previously inclu ded in the regulation, including all pellet stoves, single burn rate wood or pellet-burni ng stoves and heaters. Additionally, the proposed rule strengthens test ing methods and certificati on procedures of wood or pellet-burning heaters.

Current NSPS Requirements Under the current NSPS (adopted in 1988), only those wood or pellet-burning units meeting the following criteria require certification and all ot her units are not required to obtain certification and are therefore considered exempt:

1. Units that have an air-to-fuel ratio averaging less than 35-to-1; 2. Units with a usable firebox volume less than 20 cubic feet; 3. Units with a minimum burn rate less than 5 kilograms per hour (11 pounds per hour); and 4. Units that weig h 1,760 pounds or less.

For wood heaters meeting these requirements, the current certification emissions limits are 4.1 grams per hour (g/hr) of PM for uni ts equipped with a catalytic combustor and 7.5 g/hr for units witho ut a catalytic combustor. Units certified to these emission limits are said to be Phase-II Certified and will maintain that certific ation until the certification expires, which is up to 5 year s from the issuance date.

Under the current NSPS, pellet stoves ar e not explicitly ex empt from required certification; however, most models currently sold fall outside the regulation because they operate on an air-to-fuel ra tio greater than 35-to-1. Si ngle burn rate wood heaters are also not explicitly exempt from the curr ent NSPS but are not regulated by it because they operate below the burn rate crit eria of 5 kilograms per hour.

17 

### 40 CFR Part 60 Subpart AAA, Standards of Performance for New Residential Wood Heaters (FR 79 6330–6416)

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

25 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## Proposed NSPS The proposed NSPS significantly lowers t he certification emission limits for woodburning heaters that are current ly required to be certified and sets certification limits for a broader range of wood-burning heat ers by removing the existi ng certification criteria 1–4 above. Moving forward, if the pr oposed NSPS is finalized as-is with no amendments prior to finalization, then certification will be r equired for all pellet stoves and heaters, all single burn rate wood heaters, and all existing previously certified adjustable burn rate wood heaters once thei r current certificat ion expires.

In the proposed NSPS, EPA is proposing either a two-step five-year phase in of new standards or a three-step eight-year phase in of new standards. Both phase-in timelines ultimately end up at the same emi ssion limit of 1.3 g/hr for all woodstoves and pellet stoves. Refer to Table 4 for t he proposed standards and phase-in schedules. With implementation of the proposed NSPS, a ll existing previously certified adjustable burn rate wood heaters will be required to ei ther obtain certific ation under the new emission limits or cease production once thei r current certification expires.

Although they do not require EPA certificat ion, 96 percent of pe llet heaters meet the proposed Step 1 PM emissions limit of 4.5 grams per hour. Single burn rate wood heaters are incapable of operati ng at the lowest burn rates, and it is the lower burn rates that result in the highest le vel of PM emissions; therefor e, most single burn rate wood heaters will also meet the pr oposed Step 1 PM emissions limi t. Manufacturers of such units will not initially be required to modify their design if they already meet the emissions standard, but they will be required to go through the certification process. Each adjustable burn rate wood heater or pellet stove manufactured on or after the effective date of the final rule or sold at re tail for use in the United States on or after six months after the effective date of the final rule must comply with the emission limits specified in Table 4.

Table 4 Proposed Standards for New Wood Stoves 18 

## and Pellet Stoves 19



## 2-Step, 5-Year Phase-In Step Proposed PM limit Compliance deadline

1 4.5 g/hr 60 days after final rule is published in Federal Register
2 1.3 g/hr 5 years after effective date of final rule 3-Step, 8-Year Phase-In Step Proposed PM limit Compliance deadline

1 4.5 g/hr 60 days after final rule is published in Federal Register
2 2.5 g/hr 3 years after effective date of final rule
3 1.3 g/hr 8 years after effective date of final rule

18 

### Two types of woodstoves: adjustable and single burn-ra te. Adjustable burn-rate are covered by EPA’s current requirements. Single burn-rate are not covered by EPA’s current requirements.
19 

### Most pellet stoves are exempt from current NSPS. Under proposed rule, all pellet stoves would have to meet same emission limits as for woodstoves, in the same two-step process.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

26 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# VI. P ROPOSED 

# A MENDMENTS TO THE 

# D ISTRICT 

# ’ S 

# R ESIDENTIAL 

# W OOD 

# B URNING 

# P ROGRAM



## Proposed amendments to the District’s Re sidential Wood Burning Program would encourage owners and users of older more polluting w ood burning heaters and wood burning fireplaces to transition to less pollu ting alternatives. This transition would benefit Valley air quality throughout the w ood burning season regardless of episodic wood burning curtailments because clean wood burning heaters produce significantly less emissions then older more pollu ting wood burning heat ers and wood burning fireplaces as illustrated in Figure 7 in this st aff report. Emissions reduced as a result of amendments to the Residentia l Wood Burning Progr am are greater than those achieved through lowering the curtailment threshold alone, as discussed later in this section of the staff report.

The District recommends the following amen dments to the District’s Residential Wood Burning program:

1. Amendments to Ru le 4901 language a. Incorporate tiered episodi c wood burning curtailments b. Add a registration program for qualif ied wood burning heat ers, as defined in Rule 4901 to participate in the additional wood burning days provided through the tiered episodic wood burning curtailments c. Add a registration program fo r qualified Wood Burning Heater Professionals to perform inspections on qualified wood burning heaters d. Provide clarifications to existing rule requirements 2. Proposed new Rule 3901 (Fees for Regi stration of Wood Burning Heaters) 3. Enhancements to the District’s Burn Cleaner incentive program 4. Enhancements to the District’s foreca sting activities to support the tiered curtailments

A. PROPOSED AMENDMENTS TO RULE 4901

Refer to this section for a description of t he rule amendments to Rule 4901 and refer to the proposed rule for the pr oposed language changes.

1. Section 1.0 (Purpose) The purpose of the rule would be updated to remove outdated lang uage stating that the District will establish a public education program. The removed language is no longer relevant because the District has already es tablished a robust educational program for residential wood burning heaters as discussed in other sections of th is staff report.

2. Section 2.0 (Applicability) The applicability of Rule 4091 would be amended to clarify that the rule is applicable to outdoor wood burning heater s, as mentioned throughout t he rule, and to remove “wood

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

27 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## burning stove” from section 2.3 because this is included in the definition of “wood burning heater” and ther efore redundant.

3. “Phase II” rule clarifications EPA’s proposal of amending the existing NS PS for certification requirements for new wood burning heaters does not currently incl ude the “Phase II” style nomenclature to identify new emission limit levels. To be proactive and ensure the rule language remains timely, all mention of Phase II will have been replaced with language to clarify it as Phase II certified or the most stringent EPA certification as enf orced by the NSPS. This additional language will vary slightly in each section due to the meaning of the rule and necessity of the verbiage to enforce the requirements.

Updates to “Phase II” in rule language will affect the follo wing sections:

 Section 3.6 (Definiti on of “EPA Certified”)

 Section 5.1 (Sale or Transfe r of Wood Burning Heaters)

 Section 5.2 (Sale or Transfer of Real Property)

 Section 5.3 (Limitations on Wood Burning Fireplaces or Wood Burning Heaters in New Residential Developments)

 Section 6.0 (Administr ative Requirements)

4. Addition of “NSPS” for clarifi cation of federal requirements To ensure compliance with the most recent and up-to-date federa l standards, the rule would be amended to add the “NSPS” as the acr onym representing the Code of Federal Regulations Part 60, Subpart AAA.

5. Section 3.0 (Definitions) The Definitions section of the rule would have several amendments to clarify existing rule requirements and to support new rule requirements. As a result of the amendments to Section 3.0, t he numbering will also be affect ed. For purposes of this staff report, the following am endment summaries are discu ssed using the updated draft numbering.

Section 3.6 (EPA Phase II Certified) woul d be amended to replace the Code of Federal Regulations Part 60, Subpart AA A with NSPS consistent with the previous discussion.

Section 3.10 (Masonry Heater) would be up dated to make it consistent with rule requirements in Section 5.1.2, and to clar ify that a solid fuel is wood fuel.

Section 3.13 (Normal Operat ing Conditions) would be added to the rule to establish what the District considers and will enfor ce as normal operating conditions for a registered wood burning heater, this new def inition is in suppor t of new Section 5.6.1.2.4.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

28 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## Section 3.14 (NSPS) would be added to the rule to define NSPS. Doing so will simplify rule language by allowing reference to the NSPS instead of the full language of “Code of Federal Regulations, Part 60, Title 40, Subpart AAA.”

Section 3.15 (Outdoor Wood Burning De vice) would be amended to remove the redundant “wood burning stove” languag e, and clarify that “fire rings” includes “fire pits” to better clarify rule requirements.

Section 3.18 (Pellet-Fueled Wood Burning Heater) would be updated to clarify the definition of a pellet-f ueled wood burning heater and remove superfluous language regarding certification of such heaters that is included in Section 5.0 in the rule.

Section 3.19 (Pellet Fuel) would be updated to clarify that fuel used as pellet fuel must be compressed.

Section 3.20 (Permanently Inoperable) woul d be updated to clarify requirements by replacing “device” with “wood burning heater.”

Section 3.23 (Sole Source) would be remo ved from rule language because it is redundant to rule requirements in Section 5.6.3.2.

Section 3.28 (Wood Burning Fireplace) wo uld be updated to clarify that even factory built wood burning heaters are intended to only burn wood and no other fuels such as those listed in Section 5.5.

Section 3.29 (Wood Burning Heater) would be amended to clarify that pellet-fueled wood burning heaters are a type of wood burning heater as s upported by the definition of Pellet-Fueled Wood Burning Heater.

Section 3.30 (Wood Burning Season) would be added to rule language to clarify which months of the year are include d in the wood bur ning season.

6. Section 4.0 (Exemptions) New Section 4.3 would clarify that open burns are regulated by the District’s Rule 4103 (Open Burning). This is not a new exem ption, but a clarif ication of existing requirements by referencing the other District rule.

7. Section 5.1 (Sale or Transfer of Wood Burning Heaters) Section 5.1 is applicable to any person who adv ertises, sells, offers for sale, supplies, installs, or transfers a new wood burning heater. This secti on would be amended to clarify that these requirements are applicable to the sale and to the transfer of new and used wood burning heater s. Rule language would be am ended to clarify that the certification of wood burning heat ers is pursuant to the NSPS to ensure that the most recent and stringent requirements in the NSPS are being implemented for these wood burning heaters and to account for changes proposed by EPA in the NSPS for the

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

29 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## certification criteria of w ood burning heaters. Amendments to this section reflect the proposed EPA amendments to the NSPS, as these amendments have not been finalized by EPA at the time of this rule am endment, the District is taking proactive steps to ensure the language in the rule is consistent with new EPA NSPS language.

a) Section 5.1.1 (New Wood Burning Heaters) Requirements in Section 5.1. 1 requires that if a new w ood burning heater is sold or installed in the Valley that it is the cleanest available w ood burning heater to ensure emissions continue to decrease from this sour ce category. As such this section would be amended to clarify that the wood burni ng heater must have t he most stringent EPA certification as currently enf orced by EPA. If the wood bu rning heater is a pellet-fueled unit, then it must be either exempt from EPA certification require ments pursuant to language in the NSPS or it must be certifi ed pursuant to the NSPS, whichever is more stringent at the time of purchase or installati on of the pellet-fueled wood burning heater.

b) Section 5.1.2 (Used Wood Burning Heaters) Section 5.1.2 would be amended to simplify rule language.

c) Section 5.1.3 (Public Awareness Information) Section 5.1.3 would be amended to require retailers to provide public awareness information to their customers about the new episodic wood burning curtailment levels as defined in the rule.

8. Section 5.2 (Sale or Transf er of Real Property) Section 5.2 would be amended to incorporat e NSPS language as discussed earlier, and to simplify rule language.

9. Section 5.3 (Limitations on Wood Burning Fireplaces or Wood Burning Heaters in New Residential Developments) Section 5.3 sets limits for the quantity of wood burning fireplaces or wood burning heaters that can be installed in new resident ial developments. Cu rrent language is not completely clear as to the number of heaters allowed to be installed if that number falls between two whole numbers. The rule language will be strengthened by amending this section to clarify the number of heaters allowed for insta llation in a given area, in addition to the language being clarified with regards to the applicability of the density requirements by the removal of the term “new” from rule language. These amendments would be effective as of January 1, 2015 to pr ovide time for builders to comply with new standards, which is consistent with the time frame provi ded in the 2003 amendments to Rule 4901 which first introduced thes e requirements to the rule.

a) Section 5.3.1 (Effecti ve until December 31, 214) Current language provides for:

 5.3.1.1: >2 dwellings/acre: no wood burning fireplaces

 5.3.1.2: ≥ 3 dwellings/acre: max of two certified units

 5.3.1.3: ≤ 2 dwellings/acre: max of one wood burning fireplace or wood burning heater per dwelling

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

30 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## Figure 8 Illustration of Section 5.3.1 Requirements

Density/ Acre 0 1 2 3

b) Section 5.3.2 (Effective on and after January 1, 2015) New language provides for:

 5.3.2.1: >2 dwellings/acre: no wood burning fireplaces

 5.3.2.2: >2 dwellings/acre: max of two certified units

 5.3.2.3: ≤ 2 dwellings/acre: max of one wood bur ning fireplace or certified wood burning heater per dwelling

Figure 9 Illustration of Section 5.3.2 Requirements

Density/ Acre 0 1 2 3

Section 5.3.2.1 prohibits t he installation of a wood burning fireplace in a residential development with a density great er than two dwelling units per acre. While this could be misinterpreted as being less stringent than a similar requirement in South Coast Air Quality Management District (SCAQMD) Rule 445 (Wood Burning Devices), it is in reality more stringent because Rule 4901 does not afford t he same flexibilities as SCAQMD rule does. While SCAQMD Rule 445 has language prohibiting the installation of a permanently installed wood burning device into any new development, this requirement is not applicable to new dev elopments where there is no existing infrastructure for natural gas service within 150 feet of the property line or those 3,000 or more feet above mean sea le vel. District Rule 4901 is more stringent in that for the extremely limited cases wher e wood burning devices are allo wed to be installed, the number of units allowed is limited to no more than two per acre. Additionally, Rule 4901 does not exempt any homes from any aspect of rule requirements based on elevation.

10. Section 5.5 (Prohibited Fuel Types) Section 5.5 would be updated to clarify that prohibited fuels are not only not allowed in indoor wood burning heaters but also in outdoor wood burning devices. Rule language would also be clarified by r eplacing the term “solid fuel burning device” with an identification of the applicab le units – wood burning fireplac e, wood burning heater, or outdoor wood burning device.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

31 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## 11. Section 5.6 (Episodic Wood Burning Curtailments) Section 5.6 (Episodic Wood Burning Curt ailments) would be amended to replace existing language with a two-tiered episodic wood burning curtailment program. The first tier would lower the ex isting residential wood burning curt ailment threshold from the current threshold of 30 μg/m 3 

## to a new more stringent limit of 20 μg/m 3 

## . This will increase the number of No Burn days for resi dential wood burning. The addition of a second tier would effectively create a windo w of additional burn days for individuals who have the cleanest wood burning heaters that choose to register those wood burning heaters with the District.

a) Section 5.6.1 (Level One Epis odic Wood Burning Curtailment) Section 5.6.1 would be amended to provide requirements for Level One Episodic Wood Burning Curtailments. Level One Episodic Wood Burning Curtailments would be called when the PM2.5 concentrations are foreca st to be equal to or exceed 20 μg/m 3 

## but not to exceed 65 μg/m 3 

## . The use of registered wood burning heaters woul d be allowed provided it is operated in compliance with rule requirem ents. When PM2.5 concentrations are in this range it is gener ally because the air has become stagnant and the pollutant concentrations are rising. Prohi biting the use of dirty wood burning heaters and wood burning fireplaces would dramatica lly slow down or even stop the PM2.5 concentrations from building up.

Figure 10 Current and Proposed Wood Burning Curtailment Levels

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

32 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## b) Section 5.6.2 (Level Two Epis odic Wood Burning Curtailment) Section 5.6.2 would be amended to add provisi ons to the rule for Level Two Episodic Wood Burning Curtailments. A Level Two Wood Burning Curtailment would be called when the PM2.5 concentrations ar e forecast to exceed 65 μg/m 3 

## for a given region. No wood burning heaters, wood burning fireplaces , or outdoor wood burning devices located in the region shall be operated duri ng a Level Two Episodic curtailment.

The PM10 135 μg/m 3 

## threshold in the existing rule would also be in the Tier Two Episodic Curtailment level because these events are extremely rare and generally only become elevated above this level due to wind-blown dust events.

c) Section 5.6.3 Section 5.6.3.1 would be amended to add but ane to the list of gases that are not considered natural gas. This addition clar ifies for the public an existing and current understanding of what is and what is not interpreted to be natural gas.

d) Section 5.6.4 (Episodic Wood Burning Curtailment Notice) Section 5.6.4 would be amended to simplif y and clarify rule requirements.

e) Section 5.6.5 (Cont ingency Provision) Section 5.6.5 would be delet ed from the rule because it is no longer relevant as a contingency measure. The Clean Air Act requires attainment plans to include contingency measures, which achieve “extra ” emission reductions beyond what is needed for the plan’s modeled attainment demons tration or the Reasonable Further Progress (RFP) demonstration. Contingency measures must be fully adopted rules or control measures that are ready to be impl emented quickly upon failure to meet RFP or failure to meet the standard by the attainment date. 20



## The District’s 2008 amendment to Rule 4901 added Section 5.6.5, which provided contingency emissions reductions by loweri ng the curtailment level to 20 μg/m3 of PM2.5, to be triggered with an EPA finding th at the Valley failed to attain the 1997 PM2.5 standard. Section 5.6.5 was relied upon in the District’s recent contingency demonstration for the 2008 PM2.5 Plan 21



## , approved by EPA on May 22, 2014 22



## .

However, with this 2014 amendm ent to the Rule 4901 curtailm ent level, the District will already be implementing a curt ailment level of 20 μg/m3 of PM2.5 starting in the 2014- 15 wood burning season, without an EPA finding of failure to attain. As documented in this rule staff report, this 2014 amendment to Rule 4901 will achieve an additional emissions reduction of 5.1 tpd of PM2.5 during the w ood burning season, more than what would have been achieved through t he contingency measure commitment for 2015 (see Table 5). Even if the District assum ed a transition from older higher polluting devices to cleaner devices of only 2%, the emission reductions from the proposed

20 

### Clean Air Act Section 172(c)9, 40 CFR 51.1012.

21 

### http://www.valleyair.org/Board_meetings/GB/ agenda_minutes/Agenda/ 2013/June/items/11.pdf

22 

### http://www.gpo.gov/fdsys/pkg/ FR-2014-05-22/pdf/2014-11681.pdf

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

33 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## amendments would still exceed the commitm ent required under the contingency. However, as discussed earlier, results of t he scientific survey indicate that a much larger percentage of people will be transiti oning to cleaner devices and the emissions reductions achieved through the proposed amendments will be significantly higher.. Thus, the lowered curtailment level in t he 2014 amendment to Rule 4901 can take the place of the previous Section 5.6.5 c ontingency measure, and Section 5.6.5 can be removed from the rule.

It is also important to note that the pr oposed amendments to the District’s residential wood burning program would reduce more emissions than would be accomplished by lowering the curtailment threshold through implementation of th e contingency measure alone. Proposed amendments to the resi dential wood burning program will reduce an estimated 5.1 tons per day (t pd) of directly emitted PM2. 5 emissions (see Appendix B Table B-10); whereas, implement ation of the contingency prov ision would result in 3.40 tpd PM2.5 emission reductions (see Table 5 below).

Table 5 Amendments from Implem enting the Contingency Provision

A B C D Source/ Formula Table B-2 Table B-5 A x B C / 120

County Residential Wood Burning PM2.5 Emission Inventory (tpd) Additional No Burn

Days Determine emissions reduced through additional No Burn days (tons per season) Convert emission reductions tons per season to tons per day (tpd)
Fresno 2.11 36 76.07 0.63
Kern 1.21 35 42.49 0.35 Kings 0.23 31 7.04 0.06
Madera 0.66 38 25.16 0.21
Merced 1.04 36 37.44 0.31 San Joaquin 2.48 29 72.04 0.60 Stanislaus 1.87 36 67.14 0.56
Tulare 2.45 33 80.98 0.67 TOTAL 408.35 3.40



## 12. Section 5.7 (Registration of Wood Burning Heaters) The approach under the proposed rule that will allow clean units to burn on days when burning is prohibited for convent ional units will be nearly impo ssible to enforce without a mechanism to readily identify and verify qualif ying devices. To provide the District with an enforceable mechanism for allowing cert ified devices to burn during a level one curtailment (greater than 20 μg/m 3 

## but less than 65 μg/m 3 

## ), the District proposes a registration program for these cleaner bur ning devices. Without preregistering qualifying devices the District would be forced to resort to more intrusive enforcement techniques which would involve routine access to private property. The preregistration will also enhance enforcement capabilities by allowing t he District to better focus

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

34 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## resources. Registration will also ensure t hat the equipment is maintained in proper working condition and provides the expe cted reduction in emissions.

Registration would be voluntary and will only be nec essary if the owner of a certified unit wishes to take advantage of the additional bu rn days provided under the proposed rule. Under the proposed approach, registrations would be valid for three wood burning seasons and registered devices would be required to operate with no visible smoke under normal operating conditions, be maintai ned properly, and refrain from burning prohibited materials.

a) Section 5.7.1 (Eligibi lity for Registration) New Section 5.7.1 would establ ish eligibility requirements fo r the voluntary registration of a qualifying wood burning heater so that it may be used during a Level One Episodic Wood Burning Curtailment.

The EPA Proposed NSPS Subpart AAA require ments will strengthen the standard and eliminate the “phase” nomenclature, maki ng the use of clean burning heaters during Level One Episodic Curtailments challenging to define. The District recognizes that Valley residents have invested significant am ounts of money to install and transition from dirty heaters to clean burning EPA Phase II certified heaters and pellet stoves that are exempt from Phase II certification requi rements. The Distr ict has also invested grant funds, as discussed in Section IV.B of this staff report, to as sist with the purchase of these heaters.

Wood burning heaters that qualif y for registration include he aters that are EPA Phase II certified or have a more stri ngent certification pursuant to requirements in the Code of Federal Regulations (CFR), Part 60, Titl e 40, Subpart AAA at the time of purchase and/or installation, or an ex empt pellet-fueled wood burni ng heater that is exempt pursuant to the aforementioned CFR at the ti me of purchase and/or installation.

b) Section 5.7.2 (Interim Regist ration of Wood Burn ing Heaters) New Section 5.7.2 would provide a one seas on (2014-15) interim registration period to aid with the transition to the registration pr ogram for Valley residents. This interim period of transition will be a simplified versio n of the full registra tion program in that supplemental documentation, a registration f ee, and a verification of inspection would not be required for this interim period. Th is section also clarifies that an interim registration obtained under false information is void and also an interi m registration may be disqualified pursuant to Section 5.9 of t he rule. This interim registration program would not violate the District’s commitment in the 2012 PM2.5 Plan because that plan committed to amend Rule 4901 effectiv e beginning in the 2016-17 wood burning season. Emissions reduced during the 2016- 17 wood burning season as a result of these proposed amendments will ex ceed plan commitments.

c) Section 5.7.3 (Reg istration Process) New Section 5.7.3 would define the registration process. This registration process would be effective during and after the 2015-16 wood burning season. This process

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

35 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## would be much more in-depth than the interi m registration process and be accompanied by a fee. The rule defines required information, documentat ion, operation requirements, and reference to new Rule 3901 for the registration fee.

The applicant will be required to verify t hat the wood burning heater qualifies for registration through the submittal of a receipt or invoice from the installation of purchase of the wood burning heater that includes th e manufacturer and the model name of the wood burning heater or a certif ication from a District Regi stered Wood Burning Heater Professional. Additionally, if the wood bur ning heater is older than twelve months, then the registration application will also require a certification of inspection from a District Registered Wood Burning H eater Professional.

13. Section 5.8 (Renewal of Registration) New Section 5.8 would provide information related to the renewal of wood burning heater registrations. Similar to the initial registration pr ocess, registration renewals would also be accompanied by a fee. Sect ion 5.8.1 states that a District issued registration for a wood burning heater would be valid for a period of up to three wood burning seasons. This section defines how o ften heater registrations would be required to be renewed and the documenta tion that would be required to apply for a renewal. The purpose of registration renewals is to provide the District with a mechanism to ensure that registered wood burning heaters are oper ated and maintained per manufacturer specifications and continue to burn as cleanly as certified by the EPA. This registration renewal program would po tentially reduce emissions beyond those already achieved from the clean burning EPA Phase II certified wood burning heaters because there is no way to guarantee the ow ners of said wood burning heaters are cleaning and maintaining t hem on a regular basis.

14. Section 5.9 (Disqualificat ion of Registration) New Section 5.9 would provide information on the disqualificati on process for heater registrations. This section discusses what actions would qualify for a disqualification of wood burning heater registration, how the Dis trict would notify someone of a potential disqualification and work with them to resolve any issues, and how a disqualification could be resolved.

15. Section 5.10 (Registrat ion of Wood Burning H eater Professionals) New Section 5.10 would define the requirements for a Regi stered Wood Burning Heater Professional. This section states what cert ifications would be requ ired to qualify as a registered Wood Burning Heater Professional and the applicat ion process for registering as one. A list of registered Wood Burning H eater Professionals w ould be posted on the District’s webpage and made available upon request.

This provision would be added to rule lang uage to ensure that the District does not inadvertently exclude qualified individuals who have certif ications from any other certifying agencies that the District may not yet be aware of. Although extensive outreach has been performed throughout the rule amendment process the District

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

36 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## wants to ensure as many qualified indivi duals with professional certifications are registered as possible in order to provide the public with the necessary resources to comply with proposed rule requirements. The District intentionally limited its own ability to register qualified in dividuals by adding specific langu age to Section 5.10.2 that states “If the applicant does not have a certificati on pursuant to Sections 5.10.1.1 through 5.10.1.3 the applicant may submit an app lication to the APCO with supplemental documentation verifying that the applicant meets the certif ication standards as required by certifications pursuant to Se ctions 5.10.1.1 th rough 5.10.1.3.”

a) Section 5.10.1 New Section 5.10.1 would provid e the qualification requirement s that an individual must meet in order to register with the District as a Wood Burn ing Heater Professional. The District would require a professional certif ication from the Fir eplace Investigation Research and Education (F.I.R .E), the Chimney Safety Inst itute of America (CSIA), or from the National Fireplace Institute (NFI) or an equival ent qualification as determined by the APCO. Each of the thr ee certifications are voluntary certifications to establish standardized criteria for certification and ar e recognized as such industry-wide.

The F.I.R.E. certification recognizes indivi duals as having the minimum professional training, education, and experience to inspec t, investigate fire and explosion incidents, and/or participate in related civ il and criminal litigat ion. This certification includes a training materials and a certification ex am. Depending on options selected, the certification costs range bet ween $1,795 and $2,385. Certific ations are valid for three years. Inspectors become re-certified by either passing a test based on changes within the current edition of the Inte rnational Residentia l Building Code/Inter national Building Code, or by attending, completing, and showi ng proof of attendance of a qualified eighthour educational class. 23



## The CSIA Certified Chimney Sweep (CCS) credential program verifies a chimney sweep’s knowledge of the evaluation and maintenance of chimney and venting systems. The non-profit organization is gov erned by volunteer industry professionals and technical experts, and is an American Society of Home Inspectors (ASHI) Affiliate. Certification includes an onli ne or in-person review sessi on, completion of exams, payment of annual certification fees, and signi ng of the CSIA Code of Ethics. Costs range from $249 to $1080 depending on course options selected and membership with the National Chimney Sweep Guild (NCSG). Ce rtification is valid for one year and must be renewed by paying a $159 certification fee. Every three years certificate holders must re-certify by passing the exam again or submitting proof of the completion of required courses. 24



## The NFI certifies technicians to properly plan and install hearth products and associated venting systems. NFI is the professional certification divi sion of the Hearth, Patio &

23 

### Fireplace Investigation Research an d Education. (2014). Obtained from http://www.f-i-r-e-service.com/LandingCertified-Inspector.php

24 

### Chimney Safety Institute of America. (2014). Obtained from http://www.csia.org/

.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

37 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## Barbecue Association (HPBA) , a non-profit education or ganization for the hearth industry. Certification costs $399 for H PBA members and $598.50 for non-members. Certification is valid for three years and re-cer tification is achieved by submitting proof of completing required courses and a $139 certification fee, re-t esting directly with NFI for $289. 25



## b) Section 5.10.2 New Section 5.10.2 would outline the registration process for individuals to register with the District, including a description of required supplemental doc umentation.

c) Section 5.10.3 New Section 5.10.3 defines t hat a registration with the District as a Wood Burning Heater Professional is valid for up to three years. Conversation with industry representatives indicates that the certifications i dentified in Section 5.10.1 are generally valid for three years; therefore, to coincide with the certifications, the registrations with the District will mirror the prof essional certifications and be valid until said certification expires, or three years, whic hever is shorter. For thos e individuals without one of the aforementioned certifications wh o registers with the District as a W ood Burning Heater Professional as determined by the APCO, t heir registration would be valid for three years from the date of iss uance from the District.

d) Section 5.10.4 New Section 5.10.4 would requi re the District to maintain a list of registered Wood Burning Heater Professionals on the District’s web page to make it accessible to the public.

16. Section 5.11 (Inspection of Regi stered Wood Burning Heaters) New Section 5.11 would allow District st aff to inspect any wood burning heater registered with the District in order ensure enforceability of rule requirements.

17. Section 6.0 (Administr ative Requirements) New Section 6.2 would require the pers on who registers a qualified wood burning heater to keep a copy of the District i ssued wood burning heater registration and to make it available upon District request.

18. Section 7.0 (Test Methods) Section 7.1 would be amended to clarify that the ASTM that shall be used to test the moisture content of wood shall be the most recent and current version of the ASTM to ensure that the rule enforce s the most up-to-date test methods at all times without necessitating the amendment of the rule further.

New Section 7.2 would specify the test method for determining compliance with the visible smoke requirements for the operatio n of a registered w ood burning heater pursuant to Section 5.6.1.2.4

25 

### National Fireplace Institute. (2014). Obtained from http://nficertified. org/pages_ind ustry/industry-1v2.cfm

.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

38 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## B. PROPOSED NEW RULE 3901 (F EES FOR REGISTRATION OF WOOD BURNING HEATERS)

New Rule 3901 (Fees for Registration of W ood Burning Heaters) would be created to complement amendments to Rule 4901. This rule would specify specific fee amounts and process requirements for t he registration of heaters purs uant to Section 5.7.1 of Rule 4901.

The applicant would be required to pay a r egistration fee of $12.50 with an equivalent fee for renewal of registrations. Analysis of administrative processes incurred by the District to create and implement a registrati on program identified t hat resources would be required from the ITS Department, t he Finance Department, and the Compliance Department to implement the r egistration program. Conser vative estimates determined an average of one hour of staff time (at $100/ hr) would be needed for each application. However, the District recognizes that additi onal costs will be incurred by the applicant for verification, operation, maintenance, and inspection of the registered heaters and therefore set the fee cost at $12.50 per registration and renewal.

Registrations would be valid for three season s unless the registration is disqualified by the District. The District commits to notif y persons with registered heaters 60 days prior to expiration of said registration of the upcoming expiration date.

C. ENHANCEMENTS TO THE DISTRI CT’S BURN CLEANER INCENTIVE PROGRAM

The District continues to take proactive steps to enhance the Burn Cleaner Program. The District works with its pr ogram partners and is also actively engaged with the community and hearth industry to encourage par ticipation in the program, particularly among low-income Valley residents. In conjunction with amending Rule 4901, the District proposes the following changes to the current Burn Cleaner Program as a complementary strategy to the proposed regulatory amendments::

1. Proposed Increased Incentive Amounts Survey results indicated that 24% of Va lley residents with wood bur ning heaters would transition to cleaner burning heaters if they were provided a discount of up to 50% off the total cost of the heater. 26 

## In light of this new informati on, the District is proposing to increase the current incentive amounts to about half of the total cost of entry level heaters. The dollar amounts are based on information gathered from local hearth retailers and the District’s database of funded Burn Cleaner projects.

The increase in incentive funding amount s would encourage more residential property owners to replace their existing heat ers with cleaner burning heaters sooner in conjunction with the upcoming proposed Rule 4901 amendments by making the

26 

### Gomez Research. Residential Wood Burning, Lawn Care, and Commuting Survey Final Report. February 2014. Retrieved from http://www.valleyair.org/Board_meetings/GB/ agenda_minutes/Agenda/2 014/march/final/09.pdf

.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

39 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## replacement costs more feas ible. More importantly, th e proposed funding amount for low-income qualified applicants w ould help them pay for a ma jority of the costs of a replacement, as many are unable to affo rd these expensive new heaters. The proposed funding amounts are summarized in Table 1 below.

Table 6 Summary of Proposed Increased Incentive Funding Amounts

New Heater Current Funding Proposed Funding Gas Insert/Stove/Fireplace* $500 $1,500
EPA Certified Pellet Insert/Stove $250 $1,500

EPA Certified Wood Insert/Stove $100 $1,500

Any Eligible Heaters for Low Income Qualified Applicants $1,500 $2,500

Additional Incentive for the Installation of Gas Insert/Stove/Fireplace* Not Available $500**

*Gas fireplaces must be certified as heater-rated (ANSI Z21.88/CSA 2.33) **Applies only to eligible insta llation costs beyond the proposed fu nding amount for the new gas heater.



## 2. Additional Assistance for Low-Income Residents The District recognizes that a significant number of low-income residents in the San Joaquin Valley rent their homes (tenants). District staff has continued to look for ways to assist low-income residents and has eval uated the option of pr oviding low-income tenants an opportunity to reduce their emissions from residential wood burning through the Burn Cleaner Program. T he tenants are directly affected by the emissions produced from using older, higher-po lluting heaters, and any asso ciated utility costs with the home. As a result, the District is proposi ng to extend the low-income provisions to homeowners who rent to low-income qualified tenants, provided specif ic criteria are met through a careful District review and approval process.

The proposed criteria include the following:

o Residential properties owned by local Pub lic Housing Authorit ies are ineligible.

o Residential properties with eligible heaters must have ex isting tenants that either: 1) Qualify under the Housing Choice Voucher Program (Section 8); or 2) Meet the program’s low- income eligibility requirem ents (verification required).

o Eligible low-income tenants must obtain written consent from residential property owners to participate in the program. Residential property owners can apply on behalf of eligible tenants. Residential property owners must have va lid signed lease/rent al agreements with eligible low-income tenants with at leas t 6 months remaining on the lease.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

40 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## 3. Updates to Program Documents The District proposes to update program guide lines and applications to allow applicants the option to receive their approved voucher packe ts via email. This option will help the qualified applicant move forw ard with the purchase and inst allation of their new heater more quickly instead of waiting fo r approval by standard mail.

D. ENHANCED FORECASTING

Calling residential wood-burni ng curtailments at lower leve ls minimizes direct PM2.5 emissions, thus lowering the rate of PM2. 5 build-up during peri ods of atmospheric stagnation. The District already dedicates su fficient resources and technological tools to the forecasting staff for t he existing episodic curtailment program. However, the new tiered curtailment approach will require additi onal time and effort to ensure that forecasts account for the two proposed thres hold levels instead as opposed to just one threshold level. Accurate forecasts are vital to the success of reducing emissions through a tiered episodic wood burning curtailm ent approach. Accuracy of forecasts will ensure that the appropriate episo dic curtailment level is called by the District based on the weather conditions and pollutant conc entrations forecast for each day.

This section intentionally blank.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

41 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# VII. A DDITIONAL 

# A NALYSES



## A. GLOBAL CLIMATE CHANG E AND GREENHOUSE GASES

The California Global Warming Solutions Ac t of 2006 (AB 32) created a comprehensive, multi-year program to reduc e greenhouse gas (GHG) emissions in California, with the overall goal of restoring emi ssions to 1990 levels by the year 2020. ARB and the State Legislature developed policies and programs to implement AB 32. The District believes that the evidence and the rati onale that climate change is occurring is compelling and convincing. In addition to the long-term c onsequences of climate ch ange, the District is concerned with the potential rami fications of more modera te but imminent changes in weather patterns. The Valley depends heav ily on agriculture for its economy and has developed agricultural practices based on the last several decades of weather patterns. Unanticipated and large fluctuations in thes e patterns could have a devastating effect on the Valley’s economy.

While there are many win-win strategies that can reduc e both GHG and criteria/toxic pollutant emissions, when faced with situati ons that involve tradeoffs between the two, the District believes that the more immediate public health co ncerns that may arise from an increase in criteria or toxi c pollutant emissions should take precedence. The District Governing Board adopted the Climate Change Action Plan (CCAP) in August 2008. For California Environmental Quality Act (CEQ A) requirements, one of the goals of the CCAP is to establish District processes fo r assessing the significance of greenhouse gas impacts. The District has developed a policy and guidance for addressing greenhouse gases under CEQA.

B. HEALTH BENEFITS

The District is a public health agency whose mission is to improve the health and quality of life for all Valley residents through effici ent, effective and entrepreneurial air quality management strategies. The District periodica lly compiles attainment plans to identify individual regulations and other strategies that will achieve the emissions reductions needed for the Valley to meet federal health-bas ed air quality standar ds. Guided by its Health-Risk Reduction Strategy, the Distr ict develops and implements both attainment plans and regulations to attain the federal air quality standards in the quickest, most health-protective, and most cost-effective m anner. The control stra tegy as a whole, then, has important public he alth benefits and health costs savings. This amendment to Rule 4901 and adoption of new Rule 3901 is one component of this overall control strategy. Since amendments to Rule 4901 reduce NOx em issions, it benefits public health by contributing to impr oved ozone and PM2.5 air quality.

C. EMISSION REDUCTION ANALYSIS

District staff evaluated the emissions reducti ons that would result from amendments to Rule 4901. The District’s 2012 PM2.5 Plan committed the District to reduce 1.5 tons

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

42 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## per day of directly emitt ed PM2.5 upon full implem entation of rule amendments; this commitment has been satisfied.

The total emission reductions achieved from the proposed amendments to Rule 4901 is calculated to be 5.1 tons per wood burning season day which includes:

 3.33 tons of reductions from simply lowering the threshold from 30 μg/m 3 

## to 20 μg/m 3



## ,

 0.065 tons/day increase in emissions if a ll existing clean certified units registered and burned on days when PM2.5 concentrations are projected to be between 30 μg/m 3 

## to 65 μg/m 3



## ,

 0.22 tons/day increase in emissions if 24% of existing higher polluting devices transition to clean certified units and all registered and burned on days when PM2.5 concentrations are pr ojected to be between 20 μg/m 3 

## to 65 μg/m 3 

## , and

 2.04 tons/day of reducti ons from the transition of older dirtier wood burning heaters and wood burning fireplaces to cleaner certified devices.

Refer to Appendix B (Emission Reduction Analysi s) for the analysis for Rule 4901. Rule 3901 has no emissions reductions associated with it therefore t here is no emission reductions analysis for Rule 3901.

D. ECONOMIC ANALYSES

1. Cost Effectiveness Analysis Pursuant to California Health & Safety C ode (CH&SC) Section 409 20.6(a), the District analyzes the cost effectiveness of new rule s or rule amendments. The amendments are cost effective. Refer to Appendix C (E conomic Analyses) for the analysis for Rule 4901. Rule 3901 does not have emissions reducti ons associated with it; therefore there is no cost effectiveness analysis for Rule 3901.

2. Socioeconomic Analysis Pursuant to CH&SC Section 40728.5(a), “Whenev er a district intends to propose the adoption, amendment, or repeal of a rule or r egulation that will significantly affect air quality or emissions limitations, that agency shall to the extent data are available perform an assessment of the socioeconomic impacts of the adoption, amendment, or repeal of the rule or regulat ion.” No significant soci oeconomic impacts are expected from these rule amendment s. Refer to Appendix C (E conomic Analyses) for the analysis for amendments to Rule 4901. Rule 3901 will not significantly affect air quality or emissions limitations; ther efore, is not subject to a socioeconomic analysis.

E. RULE CONSISTENCY ANALYSIS

Pursuant to Sections 40727 and 40727.2 of the Ca lifornia Health and Safety Code, prior to adopting, amending, or repeali ng a rule or regulation, the District performs a written analysis that identifies and compares the air pollution control elements of the rule or regulation with corresponding el ements of existing or propos ed District rules, existing

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

43 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## statues, and state and federal ru les, regulations, and guidelines that apply to the same source category. The rule elements analyzed are emission limits, monitoring and testing requirements, recordkeeping and reporting requirem ents, and operating parameters and work practice requirem ents. Amendments to Rule 4901 and requirements in new Rule 3901 do not conf lict with any District or federal rules, regulations, or policies applicable to similar stationary sources, as demonstrated below.

District Rules There are no other District prohibitory rule s or regulations or fee rules tailored specifically for wood burning fireplaces or w ood burning heaters; ther efore, there are no rules in conflict with or inconsistent with the requirements of Rule 4901 and Rule 3901.

State Rules, Regulat ions, and Policies There are no identified Ca lifornia state rules, regulations, or policies specific to reducing emissions from residential wood combustion.

Federal Rules, Regulations, and Policies Rule 4901 is as stringent as the current federal New Source Performance Standards (NSPS) (40 CFR 60 Subpart AAA (Standards of Performance for New Residential Wood Heaters). Additionally there are no EPA Control Techni ques Guidelines (CTG), Alternative Control Techniques (ACT), Na tional Emission Standards for Hazardous Air Pollutants (NESHAP), or Maximum Achievab le Control Technology (MACT) guidelines for this source category.

EPA New Source Performance Standard (NSPS) EPA proposed revisions to 40 CFR Subpart AAA (Standards of Performance for New Residential Wood Heaters) on February 3, 2014. Although proposed amendments in Rule 4901 account for the EPA proposed am endments to the NSPS, the standard has not yet been finalized at the time of t hese proposed rule amendments and therefore cannot be compared to the existing or the proposed rule.

F. CALIFORNIA ENVIRONMEN TAL QUALITY ACT ANALYSIS

According to the California En vironmental Quality Act (CEQA) statutes and pursuant to Section 15061 of the CEQA Guidelines, the District in vestigated the possible environmental impacts of the amendments to Rule 4901. Based on the lack of evidence to the contrary, the District has conclude d that the rule amendments will not have any significant adverse effects on the environment. As such, the District finds that the rule amendment project is ex empt per the general rule that CE QA applies only to projects which have the potential for causing a signi ficant effect on t he environment (CEQA Guidelines §15061 (b)(3)). Therefore pur suant to Section 15062 of the CEQA Guidelines, Staff will file a Notice of Exemption upon Governi ng Board approval of amendments to Rule 4901.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

44 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# VIII. R ULE 

# D EVELOPMENT 

# P ROCESS



## The public process for these rule amendm ents began with the development of the District’s 2012 PM2.5 Plan . The District has been providing updates on the development and progress of potential ame ndments to Rule 4901 to the Governing Board, Citizen’s Advisory Committee (CAC), and Environmental Justice Advisory Group (EJAG) since February 2013.

Additionally, to increase public outreach and educational opportunities, in the first quarter of 2014, District has created a web page to serve as a central location for residential wood burning. T he web page includes informati on about the existing rule and proposed amendments under consideration, Distric t incentive programs, compliance information including how to report a violation, and EPA and ARB informational and educational materials. The web page is located at http://www.valleyair.org/rule4901 and can also be linked to from the District home page
at www.valleyair.org

.

A. 2012 PM2.5 PLAN DEVELOPMENT

During the development of the District’s 2012 PM2.5 Plan staff evaluated all potential opportunities to reduce emissions to expedite attainment of the federal air quality standards for PM2.5. This thorough and comprehensive effort resulted in the identification of Rule 4901 as a feasible oppo rtunity to reduce emissions of directly emitted PM2.5 in the Valley. Additionally , because emission reducti ons from residential wood burning activities occur at the neighborhood leve l, amending this rule is a priority under the District’s Health-Risk Reduction Stra tegy; therefore, the District committed to amend this rule in the 2012 PM2.5 Plan . The public participated in the development of this commitment in that they were invited to attend public workshops to provide verbal comments and to provide additional comment s beyond those provi ded at the public workshops throughout the plan development process until and including at the Governing Board Public Hearing to adopt the plan. Public comments specific to the potential of amending Rule 4901 were re ceived throughout the plan development process and incorporated into the plan as appropriate.

B. TECHNICAL WORKGROUP COMMITTEE MEETINGS

In preparation for the rule and incentive amending efforts, the District formed an Ad Hoc Technical Workgroup Committee consisting of District staff and management, retailers of residential wood burning heaters, and r epresentatives of the Hearth, Patio & Barbeque Association. The technical workgr oup committee met once a month for five months during the summer of 2013 to discuss i ndividual aspects of rule requirements, implementation, and alternatives. Topics of discussion at these proactive, productive, and cooperative meetings included the pr os and cons of implementing a tiered curtailment approach in the Valley; enfor cement of existing and future rule requirements; the Districts current Burn Cleaner incentive program and potential

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

45 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## opportunities to improve it in the future ; and the District’s approach to public outreach and education with regard to residential wood burning heater s, regulations, and incentive programs. Information gained durin g these technical workgroup meetings has been incorporated into the staff report, am endments to the rule , amendments to the District’s Burn Cleaner incentive program , and outreach and education efforts as appropriate.

C. SCIENTIFIC PUBLIC SURVEY

In September 2013 the District hired a thir d party company, Gomez Research, to develop and administer a bilingual user surv ey of residential wood combustion, lawn care and personal commuting activity in the Valley. In January 2014 the telephone survey of 1,000 random Valley residents took pl ace, the final draft report was drafted in February 2014 and presented to the District’ s Governing Board in March 2014. Information gained from th is survey has been incorporated into the proposed amendments to the rule, the Burn Cleaner incentive program, and District public outreach and educati on efforts.

The study results show a great u nderstanding of and compliance with the Check Before You Burn program. While the Check Before You Burn program is very recognizable with Valley residents, the survey revealed that awareness of the Burn Cleaner incentive program is relatively low despite this program being hugely popu lar and, at times, oversubscribed. The following is a summary of some of the survey results relevant to residential wood burning (Refer to Appendix E for Survey Result Reports):

 Of the 1,000 respondents, 32% reported having a wood-burning heater

o Of the 32% of respondents with a wood- burning heater, more than half of those households reported not using their heater

o Of those that reported having a wood-burning heater, 37 percent live in the northern region (San Joaquin, Stanislaus and Merced counties)

 80% of respondents were aware of the District’s Check Before You Burn Program

o 75% of whom have reduced wood-burni ng activity in response to the
program

 Just 17% of respondents knew about t he Districts’ Burn Cleaner incentive
program

 In assessing what would motivate an ow ner of a wood-burning heater to upgrade to a cleaner heater

o 29% indicated they would upgrade if allowed to burn more often

o 12% would be willing to do it with a 15% rebate

o 24% would be willing to do it with a 50% rebate

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Final Draft Staff Report: Residential W ood Burning Program September 18, 2014

46 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## D. PUBLIC WORKSHOPS

The District hosted a public Scoping Meeting on March 27, 2014. At that meeting the District presented conceptual informa tion and plan commitments, new NSPS regulations, potential methods of public outreach, and potential incentive program enhancements. The District then solicited f eedback and comments from the public at the workshop and for a two week comment period after the wo rkshop that ended at 5:00 PM on Thursday, April 10, 2014. Refer to Appendix A (Comments and Responses) for a summary of significant comme nts and District responses.

The District hosted a public workshop on the ev ening of July 31, 2014. The draft rules were made available for the public workshop. The Public workshop was followed by a two-week public comment period ending at 5: 00 PM on August 14, 2014. All significant comments received before the comment period deadline were reviewed and incorporated into the proposed rule, staf f report, and appendices as appropriate ahead of the September Governing Board Public Hearing.

E. PUBLIC HEARING

In accordance with CH&SC Section 40725, the proposed amendments to Rule 4901 and proposed new Rule 3901 and the final draft staff report were be publicly noticed and made available prior to the September 18, 2014 Governing Board public hearing to consider adoption of the proposed rule amendm ents. The public is invited to provide comments to District Governing Boar d Members during the public hearing.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 1 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# APPENDIX A

Summary of Significant Comments and Responses

Proposed Amendments to Resi dential Wood Burning Program

September 18, 2014

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 2 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## This page intentionally blank.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 3 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## SUMMARY OF SIGNIFICANT COMMENTS RULE 4901 (WOOD BURNI NG FIREPLACES AND WOOD BURNING HEATERS) Proposed Rule Package – August 19, 2014

The rule package for proposed amendments to Rule 4901 (Wood Burning Fireplaces and Wood Burning heaters) and proposed new Rule 3901 (Fees for Registration of Wood Burning Heaters) were made available for public review and comment by the San Joaquin Valley Unified Air Pollution Contro l District (District) on August 19, 2014. Summaries of significant comments receiv ed during the public comment period are summarized below.

EPA REGION IX COMMENTS:

A comment letter was not received from EPA.

ARB COMMENTS:

A comment letter was not received from ARB.

PUBLIC COMMENTS: Comments were received from the following:

Mike Bond (MB) Tom Frantz, Association of Irritated Residents (AIR)

1. COMMENT: There are a lot of factors that cont ribute to our high PM in the winter months. The amount of vehicles that trav el in our Valley as well as the PM that enters from outside our Valley is hard to contro l, but they both play a significant role and must be considered in your evaluation of the proper steps to take to reduce the PM in our air. Also, if you decide to implement controls on the type of wood we burn, that could also have a positive impac t on the emissions of particulate matter that is released into the atmosphere. Hu mans are capable of change, it’s the big changes too fast that make us feel lik e we have no control or say so about our everyday lives. Then we start pointing finger s in the direction of who it is that is telling us we have to change. (MB)

RESPONSE: Due to the Valley’s geography, topography, and meteorology, the challenges that we face in meeting t he federal health-based ambient air quality standards are unmatched by any other region in the nation. In response to these federal mandates and to impr ove quality of life for Valley residents, the District has developed and implemented multip le generations of rules on various sources of air pollution. Despite significant progress in improving the Valley’s air quality, more reductions in emissions are needed to attain the ever toughening f ederal standards. The District’s attainment plans contain a comprehensive set of local and state

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 4 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## measures to reduce air pollution from st ationary and mobile sources throughout the Valley. However, attaining the 2006 f ederal PM2.5 standard is impossible without significant further reductions in wood smok e emissions. Although the District is not proposing to control the type of wood reside nts are allowed to burn, the District will encourage the transition to less polluting wood burning heaters by decreasing the number of allowable burn days for high polluting wood burning heaters and fireplaces while at the same time incr easing the number of burn days allowed for registered clean wood burni ng heaters through a tiered episodic wood burning curtailment program.

2. COMMENT: The proposed amendments are flawed for the following reasons:

 Increasing the number of burn days a llowed for EPA certified wood burners allows an unjustified increase in emissi ons of PM2.5 when levels are already high, which will have a negative health effect on the public greater than any benefit from the reductions obtained at the lower cu rtailment levels.

 Wood burning in fireplaces and dirty stoves should be tota lly banned in the Valley at forecasted levels higher than 12-15 μg/m 3 

## as this is the new EPA health based standard.

 There should be no new fireplaces inst alled in the Valley in any home within a mile of 5 other homes existing at altitudes below 2,000 feet.

 Nearly all the PM2.5 reductions from incentives will come from fireplaces converting to gas burners. Therefore, there should only be an incentive to change from fireplaces to gas burner inse rts but not to certif ied wood inserts.

 The reductions gained from the dirty w ood stoves only burning on days below 20 μg/m 3 

## is totally offset by the certified stoves burning between 20 and 65 μg/m 3


## because the certified stove em its 30% as many emissions as the dirty stove and will be allowed to burn 3 times as many days.

 A two tier system of 12 and 35 μg/m 3 

## will be incentive enough for people to make the conversion from a dirty wood stov e to a certified wood stove.

 There should be a cost effectivene ss analysis for the proposed increase to economic incentives. $1,000 to change a dirty wood stove to a certified wood stove then operating those st oves at the proposed tiered levels means that for every 1,000 such conversions one million dollars would be spent by the District and would result in virtually no emission reductions. (AIR)

RESPONSE: The proposed amendments will make this rule the most stringent wood burning curtailment rule in the nation. The District is proposing to lower the curtailment threshold to 20 μg/m 3 

## for older more polluting wood burning heaters and wood burning fireplaces, which comprise ov er 95% of wood burni ng emissions. In addition, the operation of non-registered clean dev ices will also be restricted at the 20 μg/m 3 

## threshold. This proposed curtailment level is significantly lower than the current curtailment threshold of 30 μg/m 3 

## . Amending the rule to allow the cleanest wood burning heaters to be used between 20 and 65 μg/m 3 

## would provide significant

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 5 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## motivation to Valley residents for transiti oning away from older higher polluting devices to the cleanest wood burning heaters. Refer to the final draft staff report and to Appendix E (Public Survey Reports) for supporting information that Valley residents would be motivated to upgrade to a cleaner burning alternative if given more burn days than currently allowed. A registered wood burni ng heater pollutes at least twenty times less than a wood burning fi replace (refer to Figure 7 in the final draft staff report); theref ore, encouraging this transit ion would reduce emissions beyond those that could be accomplished by only reducing the curtailment threshold to 20 μg/m 3 

## . The proposed amendments will achiev e an estimated reduction of 5.1 tons per day of PM2.5 emissions (refer to Appendix B (Emission Reduction Analysis) for more details on this analysis).

This section intentionally blank.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 6 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## SUMMARY OF SIGNIFICANT COMMENTS RULE 4901 (WOOD BURNI NG FIREPLACES AND WOOD BURNING HEATERS) Public Workshop – July 31, 2014

The San Joaquin Valley Unified Air Pollution Control District (District) held a public workshop to present, discuss, and hear co mments on draft amendments to Rule 4901 and Draft New Rule 3901. Summaries of significant comments received during the public workshop and the associated two- week commenting period following the workshop are summarized below.

EPA REGION IX COMMENTS:

No comments were received from EPA.

ARB COMMENTS:

No comments were received from ARB.

PUBLIC COMMENTS: Comments were received from the following:

Central Valley Air Q uality Coalition (CVAQ) 1 

## Duraflame, Inc., (DI) Hearth, Patio, & Barbecue Association (HPBA) Gail Burke (GB) John Crouch (JC) Kurt Kautz (KK) Ryan Bros. Chimney Sweeping (RB) Steve Combs (SC) Steve Goldstein (SG) Thomas Menz (TM)

1. COMMENT: Fireplace burning should be prohibited in the City of Fresno and should only be allowed if a home has no other means of heating. (GB)

RESPONSE: Rule 4901 currently has a provision (S ection 5.6.3.2) that allows for the use of a wood burning heater or wood burning fireplace on No Burn days if it is the sole source of heat for the home.

1 

### Comment letter submitted by CVAQ on behalf of Earthjustice; Central Calif ornia Environmental Justice Network; Catholic Charities, Stockton Dioces e; College Community Congregational C hurch, UCC (Fresno); Coalition for Clean Air; and Sierra Club California Tehipite Chapter.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 7 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## 2. COMMENT: The District should not change Rule 4901. Tiered curtailment will confuse people, create additional record keeping and enforcement issues, and increase the number of District staff. The increase in no-burn days will destroy the wood business and jobs within the Valley. The wood business is no different than any other business in the Valley, and no other business has been required to shut down for 44% to 72% of its season. (KK)

RESPONSE: In recognition of potential confusi on that the public may experience with a tiered curtailment pr ogram the District is prepar ing public outreach and educational materials that will build off of the already established outreach for residential wood burning. Public educat ion and continuous messaging through multi-media as described in the staff r eport will enable the Dis trict to minimize potential confusion experienced by the public. Additionally, District staff is available to speak with members of the public and pr ovide any requested clarifications about the tiered residential w ood burning program.

The proposed tiered episodic wood burning curt ailment program is anticipated to have two different impacts on the sale of wood in the Valley that would essentially nullify each other’s impacts while effect ively reducing direct ly emitted PM2.5 emissions at the same time. The ol der more polluting wood burning heaters and wood burning fireplaces are expected to exper ience an increase of an average of 34 additional No Burn days per wood burning s eason per county. This will result in reduced amounts of wood purchased for those 34 days. However, the clean burning registered wood burning heaters are expected to experience an average increase of 31 additional burn days per county; therefor e the users of these units would be purchasing more wood to burn in their w ood burning heater. As demonstrated in Figure 7 in the staff report, the use of registered wood burning heaters will produce fewer emissions than the use of older mo re polluting wood burni ng heaters or wood burning fireplaces, providing an ov erall benefit to the Valley.

3. COMMENT: The incentives offered for residents to switch to cleaner burning wood burning heaters are great and the more inc entives offered the better; however, allowing more burning on days that exceed the federal standard is a step backwards. The District should increase subsidies for new devices, but should not allow more burn days. (TM)

RESPONSE: The District employs a multifac eted approach in reducing winter PM2.5 emissions. The increase in in centive amounts comb ined with the tiered episodic wood burning curtailments will encour age the transition from the older more polluting wood burning heaters and wood burn ing fireplaces to achieve emission reductions beyond those that would be r educed through offering larger incentive amounts alone. Refer to the staff r eport for a complete discussion.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 8 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## 4. COMMENT: There are not enough qualified individuals to perform all the inspections that will be required under the new program; however, all retailers have installers and technicians that are familiar with these devices. Suggestions for the certification and registration components of the new program include allowing retailers to sign off on insta llers and technicians (SG):

 Allow retailers to sign off on installers and technicians who are qualified to do inspections to verify that the unit qualifies and is bei ng used properly. Retailers could create a list of needed criteria.

 Retailers can provide a list of chimney sweeps they think are qualified to perform inspections

RESPONSE: Proposed rule language allows a prov ision for qualified individuals who do not have one of the thr ee identified certifications to become registered with the District as a Wood Burning Heater Pr ofessional, provided they prove to the District that they are qualified to do so . Please see Section 5.10.1.4 and Section 5.10.2.3 of the proposed rule.

5. COMMENT: Amending the curtailment threshold fo r all wood burning devices in the Valley from 30 μg/m 3 

## to 65 μg/m 3 

## is a relaxation of the ru le. The draft curtailment threshold should be no higher than 30 μg/m 3 

## . (CVAQ)

RESPONSE: On the contrary, the proposed am endments will make this rule the most stringent wood burning curtailment rule in the nation. The District is proposing to lower the curtailment threshold to 20 μg/m 3 

## for older more polluting wood burning heaters and wood burning fireplaces, which comprise over 95% of wood burning emissions. In addition, the operation of non-registered clean devices will also be restricted at the 20 μg/m 3 

## threshold. This proposed curt ailment level is significantly lower than the current curta ilment threshold of 30 μg/m 3 

## . Amending the rule to allow the cleanest wood burning heaters to be used between 20 and 65 μg/m 3 

## would provide significant motivation to Valley re sidents for transitioning away from older higher polluting devices to the cleanest wood burning heaters. A registered wood burning heater pollutes at least twenty times less than a wood burning fireplace; therefore, encouraging this transition w ould reduce emissions beyond those that could be accomplished by only reducing the curtailment threshold to 20 μg/m 3 

## . The proposed amendments will achieve an estimated reduction of 5.1 tons per day of PM2.5 emissions.

6. COMMENT: The draft rule continues to a llow the installation of wood burning fireplaces and other wood burning devices in new residential devel opments. This is less stringent than South Coast AQMD (SCA QMD), which bans the installation of wood burning fireplaces and wood burning heaters in new developments. (CVAQ)

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 9 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## RESPONSE: The statement that SCAQMD does not allow the installation of wood burning devices in new developments is in correct. In fact, SCAQMD Rule 445 allows the installation of wood burning dev ices in new developments that have limited access to natural gas or are locat ed above 3,000 feet. The District’s Rule 4901 is actually more stringent in that fo r the extremely limited cases where wood burning devices are allowed to be insta lled, the number of units allowed are restricted to no more than 2 per acre.

7. COMMENT: We urge the District to remove the section of the rule that requires a NFI, CSIA, or FIRE service certificat ion should be enforced for a wood burning heater professional to be able to certify and sign off on devices. (HPBA)

RESPONSE: Although Sections 5.10.1.1 thr ough 5.10.1.3 identify specific certifications, Section 5.10.1. 4 provides criteria by whic h an individual without these certifications can become registered with t he District to perform the inspections and certifications. Adding Section 5.10 to t he rule would require that the individuals signing off on the wood burning heaters for applicants are qualified to do so, thus ensuring the wood burning heater is operat ing as cleanly as designed by the manufacturer and as certified by EPA.

8. COMMENT: The rule should be clarified to st ate the wood burning heater should be operated with no “visible” smoke. (HPBA)

RESPONSE: This clarification has been added to rule language.

9. COMMENT: The proposed revision of lowering the concentration threshold to 20 μg/m 3 

## dramatically increases the number of No Burn days and tilts the burden of reducing PM2.5 emissions far beyond the cont ribution that occasional residential wood burning makes to PM2.5 emissions in the Valley. Additionally, even though general fireplace usage declined significant ly, pollution levels were still high; indicating other sources of PM2.5 drove increased polluti on levels on warm stagnant air days. Proposed amendments effectively double the number of pr ojected No Burn days and prohibits burning for most resi dents for more than half of the 120-day wintertime period. The District does not pr ovide substantial evidence that such an incentive program will pr omote reduction of PM2.5 emissions. (DI)

RESPONSE: Valley Businesses are already subjec t to toughest air regulations in the nation. The District’s attainment plans ca ll for significant reductions in emissions from mobile and stationary s ources throughout the Valley. With regards to directly emitted PM2.5 emissions, residential wood bu rning is the largest source in the Valley during the winter mont hs, as supported by Appendi x B (Emissions Inventory)

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 10 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## of the District’s 2012 PM2.5 Plan.2 Duri ng the 2013-14 winter season, the Valley experienced unprecedented stagnation and extr eme weather conditions with century old drought records being broken in many of the cities in California. These unique conditions resulted in abnormally high PM2.5 concentrations during the 2013-14 winter season and the Valley’s PM2.5 conc entrations would have been even higher absent the wood burning restrictions. The Di strict and the California Air Resources Board also conducted extensive grid bas ed and photochemical modeling during the development of the 2012 PM 2.5 Plan and determined that significant PM2.5 reductions were achieved through the implem entation of the Districts PM2.5 control strategy which includes the wood burning he ater and wood burning fireplace rule. Reducing directly emitted PM2.5 emissions will have a greater benefit on Valley air and public health than reducing precursor emissions to PM2.5 as supported by California Air Resources Board modelin g summarized in Chapter 4 (Scientific Foundation and PM2.5 Modeling Results) of the 2012 PM2.5 Plan. 3 Nonetheless, given the ever tightening federal health st andards, the District is mandated to pursue all available measures to reduce direct and indirect sources of particulate emissions.

In addition, prolonged inhalation of wood smoke has adverse impacts on human health. Inhalation of wood smoke contribut es to lung disease, pulmonary arterial hypertension, and pulmonary hear t disease, which can eventually lead to heart failure. Wood smoke has also been linked to oxidative stress and blood coagulation and can ultimately lead to cancer. Ch ildren with the highest exposure to wood smoke show a significant decrease in lung function.

Health benefits from reducin g emissions from residential wood burning are related to the high level of population exposure to urban residential wood burning emissions with relation to other stationary sources. A Central Valley Health Policy Institute Study found that wood burning curtailm ents on high pollution days reduced annual exposure by 13.6% in Fresno, and an estimat ed 12.9% in Bakersfield resulting in 30 to 70 avoided cases of annual premature deaths.

10. COMMENT: All pellet-fueled devices are ei ther EPA certified or EPA exempt. Language should be added to the rule that allo ws the use of EPA-certified pellet heaters, not just EPA-exempt pellet heaters. Additionally , can people register pelletfueled devices without inspection for the inte rim registration? People will already not use prohibited fuels because the devices will not work if prohibited fuels are used. Interim registrants could meet the requirements of 5.7.2 by submitting a picture of the device and a copy of the sale invoice. (SG)

2 

### SJVUAPCD. 2012 PM2.5 Plan. Appendix B (Emissions Inventory). Dece mber 2012. Retrieved on 8/15/14 from http://www.valleyair.org/Air_Quality_Plans/PM25Plans2012.htm

. 3 

### SJVUAPCD. 2012 PM2.5 Plan. Chapter 4 (Scientific Foundation and PM2.5 Modeling Results), page 4-24. December 2012 Retrieved on 8/15/14 from http://www.valleyair.org/Workshops/postings/2012/12-20- 12PM25/FinalVersion/04%20Chapter%204%20S ci%20Foundation%20and%20Modeling.pdf

.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 11 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## RESPONSE: While it is true that all pellet-f ueled wood burning heat ers are currently either EPA certified or EPA exempt, this will change with the adoption of the proposed EPA amendments to the NSPS (see staff report). Ea ch section of the rule that uses the terminology EPA certified wood burning heater is referring to both the wood-fueled and pellet-fueled wood burning heaters; this is clarified through the definition of wood burning heater (Sec tion 3.29) which would be amended to specifically identify pellet-f ueled wood burning heaters.

This section intentionally blank.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 12 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## SUMMARY OF SIGNIFICANT COMMENTS RULE 4901 (WOOD BURNI NG FIREPLACES AND WOOD BURNING HEATERS) Public Scoping Meeting – March 27, 2014

The San Joaquin Valley Unified Air Pollution Control District (District) held a public workshop to present, discuss, and hear comment s on strategies under consideration for reducing emissions from sources subject to Rule 4901. Comments received during the public workshop and the associated two week commenting period following the workshop are summarized below.

Comments were received from the following: Bob Haun (BH) Chuck Spears (CS) Dennis Fox (DF) Hearth, Patio & Barbecue Assoc. (HPBA) James Hodges (JH) Jon (Jo) John Crouch, (JC) Kaity Van Amersfort (KVA) Kautz Farms (KF) Keith Harrison (KH) Lane Embry (LE) Larry Boone (LB) Leon Thomas (LT) Mark Anaforian (MA) Maryann Beasley (MB) Michael Gatley (MG) Peggy Christiansan (PC) Richard (Ri) Ron Bohegian (RB) Roxanne Lemos (RL) Thomas Menz (TM)

1. COMMENT: Members of the public expres sed differing opinions on the implementation of increased restricti ons on residential wood burning through a lowered threshold level for episodic wood burning curtailments. Some members of the public support increasing restrictions on residential wood burning (JH, RB, PC, Jo, KH, KF). Some member s of the public oppose more st ringent restrictions (LT, KH, KF). Some members of the public are in favor of more st ringent restrictions then 20 μg/m 3 

## (TM).

RESPONSE: Directly emitted PM2.5 emissions from residential wood burning have adverse health impacts on the public. These emissions generally occur in densely populated areas such as neighborhoods. R educing emissions from this source provide some of the most co st effective and health protective emission reductions in the Valley as discussed throughout the staf f report. That said, the District recognizes that replacing older more polluting wood burning heaters and wood burning fireplaces with less polluting alternat ives can be a significant investment for residents of the Valley and therefore supports such transitions through the District’s Burn Cleaner incentive program whereby the District offers grant funding to assist Valley residents with the purchase of clean burning devices.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 13 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## 2. COMMENT: Members of the public expressed opposing sentiments on the tiered episodic curtailment approach that the Distr ict is considering. Some commenters expressed support of a tier ed approach to episodic wood bur ning curtailments (BH, KVA), while others expressed that they do not support a tiered approach to episodic wood burning curtailments. (TM)

RESPONSE: A tiered approach to calling episodic wood burning curtailments would encourage Valley residents who own older mo re polluting wood burning heaters and wood burning fireplaces to replace those uni ts with less polluting alternatives such as EPA Phase II Certified wood burni ng heaters and gaseous-fueled heaters, as supported by survey results (See Appendix E). The emissions reduced from amendments to the District’s Residential Wood Burning Program would result in greater reductions of directly emitted PM2.5 emissions than w ould be achieved by reducing the curtailment threshold alone. These increased emission reductions will result in health benefits and progress the Va lley towards attainment of the federal PM2.5 standards.

3. COMMENT: The potential opportunity of reducing emissions by extending the wood burning season to include October and/or Ma rch was presented to the public at the workshop. Some members of the publ ic did not support expanding the wood burning season because the benefits gained through a longer would burning season would be minimal (KF), while others di d support expanding the wood burning season. (TM)

RESPONSE: The District evaluated the potent ial benefits and feasibility of expanding the wood burning season to incl ude one or two additional months and based on the results of the evaluation t he District will not pur sue expanding the wood burning season. See the staff report for more in formation.

4. COMMENT: Some members of the public calle d for increased public outreach efforts, including more advertising on No Burn days, to promote th e philosophy that if one is going to burn, then that person should burn wisely and as cleanly as possible. (LB, HPBA)

RESPONSE: The District has a robust and proacti ve public outreach and education program in place to educate the public of the hazards of residential wood burning, as discussed in the staff report. The District plans to continue these on-going efforts and to continue to seek additional opportuni ties for increased public outreach and education.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 14 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## 5. COMMENT: Enforcement efforts need to be increased as well as consequences for burning on “No Burn” days. T he public should be allowed to help enforce the rule by documenting infractions with time/date stamped photos of violators. A phone number should be provided to repor t violators. (LB, PC, TM)

RESPONSE: Enforcement efforts currently in clude several phone numbers to report violations of episodic curtailments in cluding the following: 559-230-6000 in the Central Region, 209-557-6400 in the Northern Region , and 661-392-5500 in the Southern Region. Violators can also be reported on the District’s web page at: http://www.valleyair.org/busind/comply/complaint.htm , or http://www.valleyair.org/r4901/ . Additionally, District Compliance staff performs surveillance and issue Notices of Violation (NOVs) to those Valley residents who are using wood burning heater s, wood burning fireplaces , or outdoor wood burning devices on No Burn days. In the 2013-14 wood burning season the District dedicated 2,750 Compliance staff hours to residential wood burning enforcement, of the 66 No Burn Days (Valley-wide) 564 NOVs were issued.

6. COMMENT: The District should not have a regi stration program for qualifying wood burning heaters because it may discourage homeowners from buying these wood burning heaters, r egardless of ultimately allowing t hem the right to burn. (HPBA)

RESPONSE: A registration program provides the District with an enforcement mechanism which allows for the use of r egistered wood burning heaters to be used during certain times when the use of non-registered wood bur ning heaters would be prohibited. A registration pr ogram helps the District to ensure that the person who registers a qualifying wood bur ning heater understands all pr ovisions of Rule 4901 and operates the wood burning heater in comp liance with those provisions. It can also be used to confirm that the wood burning heater is cleaned and maintained per the manufacturer guidelines to ensure that the wood burning heater is burning as cleanly as certified by EPA.

7. COMMENT: If the District chooses the implement ation of a registration program, registration fees should be waived because homeowners make significant investments for these clean bur ning devices and making them pay District fees could discourage them from partici pating. (BH, KVA, LT, MG, RL, HPBA) Additionally, registration should only happen one time and not require renewals. The District should work with hearth retailers to help Vall ey residents register their devices if the District chooses to pursue this option. (BH, KVA)

RESPONSE: The District incurs additional st affing and other costs to create and maintain a registration program and would therefore need to recover some of these costs. Registration of a qua lifying wood burning heater is vo luntary; owners of these wood burning heaters have the option to not register the wood burning heater and

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 15 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## therefore not participate in the additi onal burn days provided through a tiered curtailment program. The Dis trict looks forward to continuing to work with hearth retailers to assist Valley residents to take full advantage of District incentive programs and compliance with regulatory requirements.

8. COMMENT: The District should focus on regulat ing businesses, the agricultural community, and mobile sources instead of the Valley residents. (MB, KH, CS, LE, RL, MA, MG)

RESPONSE: To date the District has adopted over 500 rules and rule amendments almost all of which are applicable to bus inesses and not individual residents in the Valley. Many of the District’s prohibitor y rules on Valley businesses are fourth or fifth generation, meaning they have been revi sed several times and emissions limits have been lowered as new emission contro l technologies have become available and cost effective. Valley businesses hav e invested millions of dollars to reduce emissions. With regards to the agricultur al community specifically, emissions are reduced through District rules including but not limited to Rule 4702 (Internal Combustion Engines), Rule 4103 (Open Burn ing), Rule 4204 (Cotton Gins), Rule 4303 (Orchard Heaters), Rule 4570 (Confined Animal Facilities), and the Regulation VII rules for fugitive dust.

In addition to the emissions reduced thr ough regulatory actions, the District also provides incentive funding that is matc hed by the grantee to fund the purchase, replacement or retrofit of equipment. To date, the District has provided over $500,000,000 in incentive funding and grant recipient s have invested over $400,000,000 in matching funds to purchase, r eplace, or retrofit thousands of pieces of mobile and agricultural source equipment , such as irrigation pump engines and agricultural tractor replacement.

9. COMMENT: How does the District determine that t he emissions are fr om residential wood burning? (MB)

RESPONSE: Since PM2.5 measurements are mass-based, the mass can be separated into its various species com ponents through an analysis called speciation. Speciation of the Valley’s PM 2.5 emissions demonstrates t hat organic carbon is the major species contributing to wintertime PM2.5 levels. Wood burning emissions are proven to contribute to a large component of the organic carbon formed in the Valley. Residential wood burni ng emissions play a key role in the amount of organic carbon and overall PM2.5 mass being formed in the Valley.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 16 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## 10. COMMENT: Will the exemption for homes where the only sour ce of heat is a woodburning fireplace be removed from the rule? (Ri)

RESPONSE: Draft amendments to Rule 4901 do not include the removal of this provision in the rule at this time.

11. COMMENT: Clean burning devices should be allo wed to burn every single day regardless of air quality. (RL)

RESPONSE: The District has evaluated the potent ial benefits of allowing additional days for clean burning devices to be utiliz ed in the Valley and has drafted the episodic tiered curtailment levels to reflec t this evaluation. Registered wood burning heaters would be allowed to be used and ol der more polluting wood burning heaters and wood burning fireplaces would not be allo wed to be used when the air quality is forecast to have PM2.5 c oncentrations between 20 μg/m 3 

## and 65 μg/m 3 

## because it is during this time that the fine particulates are building up in the Valleys air. Preventing the use of the more polluti ng wood burning heaters and wood burning fireplaces while at the same time a llowing the use of registered wood burning heaters will slow down or even stop the accumu lation of fine particulates in the air. However, when air quality becomes so bad as to have PM2.5 concentrations forecast to be above 65 μg/m 3 

## , the 1997 federal standard for PM2.5, all wood burning in the Valley will be prohibited so as to expedite the lowering of fine particulate concentrations in the air.

12. COMMENT: The District is advertising too mu ch against wood-burning and never mentions other things people burn. Shutti ng down family business that are based on firewood sales will hurt t he local economy. (CS)

RESPONSE: District outreach efforts include educ ating the public as to which materials can and cannot be burned at any given time. Rule 4901 prohibits the burning of garbage, treated wood, plastic pr oducts, waste petroleum products, paints and paint solvents, coal, and any other mate rial not intended by a manufacturer for use as a fuel in a wood burning heater or wood burning fireplace. District No Burn days currently prohibit the burning of wood and pellets alike.

13. COMMENT: Some members of the public suppor t an increase in incentive funding for clean burning devices (RB, BH, KVA, H PBA), while others support only subsidy of natural gas devices in areas that have natural gas service. (TM)

RESPONSE: While natural gas devices may be the cleanest burning devices, there are some areas in the Vall ey that do not have natural gas service and therefore would not be able to use these devices. District incentive programs are aimed at

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 17 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## assisting all Valley residents with older more polluting wood burning heaters to transition to less polluting alternatives.

14. COMMENT: Is it better to burn wood from dead tr ee crops in the fireplace or the field? (DF)

RESPONSE: It is better to burn wood from dead tree crops at biomass plants because these facilities have control te chnologies to capture and control the emissions from such burning and that burned matter is converted to energy.

15. COMMENT: Homes with natural gas service should never be allowed to remove their existing heating apparatus and be gr anted a permanent exem ption from rule requirements. (DF)

RESPONSE: While District Rule 4901 does not have provisions addressing the removal of existing heating devices, Title 24 of the California C ode of Regulations require all homes, apartments, rooms for rent, or other habi table spaces be provided with heating facilities capabl e of maintaining minimum room temperature requirements, with the exce ption of certain limited-density owner-built rural dwellings. Open-hearth firepl aces do not comply with this code requirement, since such fireplaces do not function as effici ent whole-house heating devices; additional requirements apply to wood- burning or pellet stoves. 4

4 

### California Building Standards Commission. California Code of Regulations, Title 24, Part 2.5. ISBN 978-1 58001-
975-0. 2010

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Comments and Re sponses September 18, 2014

A - 18 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## This page intentionally blank.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B - 1 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# APPENDIX B

Emission Reduction Analysis

Proposed Amendments to Resi dential Wood Burning Program

September 18, 2014

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-2 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## This page intentionally blank.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-3 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## EMISSION REDUCTION ANALYSIS FOR PROPOSED RULE 4901

I. SUMMARY

The District’s residential wood burning pr ogram reduces directly emitted PM2.5 emissions from residential wood burni ng using the three pronged approach of a prohibitory rule, public outreach and education, and the District’s Burn Cleaner incentive program (Burn Cleaner Program ). Proposed amendments to the Districts residential wood burning program would further reduce emissions by encouraging the transition from older more polluting wood burning heat ers and wood burning fireplaces (commonly called open hearth fireplaces) to cleaner alternat ives. Emissions reduced as a result of the proposed amendments to the residential wood burning program would achieve emission reductions beyond those reduced thr ough lowering the curtailment threshold in Rule 4901 alone.

Proposed amendments to the pr ogram include amendments to District Rule 4901 (Wood Burning Fireplaces and Wood Burning heaters) to implement a tiered episodic wood burning curtailment progr am; proposed new Rule 3901 (Fees for Registration of Wood Burning Heaters) to establish a fee st ructure to support a robust registration program for certified clean devices; and enhanc ements to the District’s Burn Cleaner Program that include significantly increased incentives.

This emission reductions analysis appendix consists of two distinct emission reductions analysis scenarios. The first analysis accoun ts for the emissions reduced as a direct result of implementing the proposed tiered curtailment program. The second analysis accounts for the overall emissions reduc ed from the amendments to the District’s residential wood burning program and the associated transition to registered wood burning heaters.

The total emission reductions achieved from the proposed amendments to Rule 4901 is estimated at 5.1 tons per wood burning se ason day. Even if the expected reductions from turnover to clean w ood burning devices are not accounted for, the proposed amendments to Rule 4901 would result in a r eduction of at least 3.27 tons per day (tpd) of directly emitted PM2.5 emissions during the wood burning season.

In the 2012 PM2.5 Plan the District committed to reduc e 1.5 tpd of PM2.5 during the winter season (November through April) effe ctive as of the 2016/17 winter season. Since the winter season is 180 days and the wood burning season is 120 days, the 3.27 tpd of wood burning season emission reducti ons equates to 2.18 tpd when averaged over the entire winter season, exceedi ng the 1.5 tpd commitment in the 2012 PM2.5 Plan

.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-4 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## II. EMISSION REDUCTIONS FROM PROPO SED EPISODIC TIERED CURTAILMENT PROGRAM

For purposes of claiming emission reduction s in the SIP for proposed rule amendments this emission reduction analysis will only ac count for those emissions reduced as a result of the proposed tiered episodic curtai lment program. The current episodic wood burning curtailment threshold level of 30 μg/m 3 

## would be lowered to 20 μg/m 3 

## for wood burning fireplaces and non-registered wood burning heaters. Proposed amendments would create a second tier to allow the us e of registered wood burning heaters when pollutant levels are forecast to exceed 20 μg/m 3 

## but not to exceed 65 μg/m 3 

## . All residential wood burning would be prohibited if the pollutant levels are forecast to exceed 65 μg/m 3



## .
The calculations within this analysis are made with the conservative assumption that all wood burning heaters and wood burni ng fireplaces in the Valley will remain unchanged and not be transitioned to cleaner alternatives . Even though the District anticipates that many un-certified EPA wood burning heaters and wood burning fireplaces in the Valley will be replaced with new cl eaner technologies.

The emission reduction analysis was per formed using the following steps:

A. Identify the ARB emissi on inventory for residential wood burning devices B. Determine the wood-burning seasonal em issions from resi dential wood burning C. Divide the ARB Wood Stov e category into its components of pellet-fueled wood burning heaters, clean wood burning heat ers, and dirty wood burning heaters D. Distribute the ARB emission inventory for Wood Stoves between pellet-fueled wood burning heaters, clean wood burning heaters, and dirty wood burning heaters E. Distribute the emission inventory into the new categories of Clean Wood Burning Heaters and Dirty Wood Burning Heaters F. Determine the average number of estima ted No Burn days fo r future years G. Determine the emission reductions H. Determine the number of average estimat ed increase in burn days for registered wood burning heaters for future years I. Determine the additional emissions fr om the additional number of burn days for registered wood burning heaters J. Determine the overall emission reductions from implementation of the episodic tiered curtailment program K. Determine the wood burning season total emission reductions for the Valley L. Determine the total winter season tota l emission reductions for the Valley

The following provides the methodology, assu mptions, and calculations for the emission reductions analysis steps identified above.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-5 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## A. ARB emission inventory for residential wood burning devices

The ARB distributes the emission inventor y for residential wood burning into two categories of devices: 1) Fireplaces and 2) Wood Stoves. However, the wood burning devices in the Valley consist of three cat egories: 1) Fireplaces , 2) Pellet-Fueled Wood Burning Heaters, and 3) Wood Burning Heat ers. The ARB emis sion inventory for “Wood Stoves” includes emissions from bot h types of heaters ( pellet-fuelled wood burning heaters and wood burning heaters).

Table B-1 ARB 2015 PM2.5 Winter S eason Residential Wood Burning Emission Inventory by County (tpd) 1



## County Wood Stoves Fireplaces Total Fresno 0.541 0.867 1.408
Kern 0.240 0.569 0.809 Kings 0.036 0.115 0.151
Madera 0.224 0.217 0.441
Merced 0.405 0.288 0.693 San Joaquin 0.254 1.402 1.656 Stanislaus 0.497 0.746 1.243
Tulare 1.032 0.604 1.636 VALLEY TOTAL 3.229 4.808 8.037



## B. Determine the wood-burning seasonal emissions from residential wood burning

1. Determine the daily burn season emissi ons from the daily winter emission inventory a. The existing emission inventory accounts for the winter season which includes the months of November th rough April (180 days) . However, the wood-burning season consists of t he months of November through February (120 days). b. Because there is little to no resident ial wood burning activities during the months of March and April, the District assumes all emissions are limited to the wood-burning season months of November through February. c. Convert the winter daily emission inventory into a daily burn-season inventory. By multiply ing the inventory by 180 days (winter season) then dividing it by 120 days (wood-burning season). i. Example: 1. Fresno County Wood Stove emi ssions x number of winter season days 2. 0.541 tpd x 180 days per winter season 3. 97.38 tons per winter season

1 

### CEPAM – NorCal v. 1.04 – Winter Average

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-6 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## 4. 97.38 tons per winter season / number of wood-burning season days 5. 97.38 tons per winter season / 120 days per wood burning

season 6. 0.812 tons per wood-burning season day

Table B-2 2015 PM2.5 Wood-Bu rning Season Emission Inventory by Co unty (tons per day)

County Wood Stoves Fireplaces

Fresno 0.812 1.301

Kern 0.360 0.854 Kings 0.054 0.173

Madera 0.336 0.326

Merced 0.608 0.432 San Joaquin 0.381 2.103

Stanislaus 0.746 1.119

Tulare 1.548 0.906

VALLEY TOTAL 4.844 7.212



## C. Divide the ARB Wood Stove category into its components of pellet-fueled wood burning heaters, cl ean wood burning heaters, and dirty wood burning heaters

Amendments to Rule 4901 wi ll implement a tiered episodi c curtailment program in which episodic curtailments will be called at different thresholds for wood burning heaters that are regist ered with the District versus w ood burning heaters that are not registered with the Dist rict. Refer to the staff report for more details on this tiered episodic curtailment program. For purposes of this emission reductions analysis the District assumes all wood burning heaters that qua lify to register will do so. To calculate the emissions reduced based on the tiered epi sodic curtailments the emission inventory must first be divided into the two categories: 1) clean wo od burning heaters that qualify for registration and 2) dirt y wood burning heaters.

D. Distribute the ARB emissi on inventory for Wood Stoves between pellet fueled wood burning heaters, EPA certified wood burning heaters, and non-EPA certified wood burning heaters

1. Determine the percentage of emissions fr om Wood Stoves that are attributed to the three categories

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-7 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## a. Based on the EPA data 2 

## the emissions are accountable for in the following percentages i. Dirty wood burning heaters: 75% ii. Clean wood burning heaters: 20% iii. Pellet-fueled wood burning heaters: 5% b. Based on EPA emission dat a the fireplaces are 20 times dirtier than the certified wood burning heat ers, and over 50 times dirtier than certified pellet stoves. 3 

## Therefore the District assumes the inventory is as follows: i. Dirty wood burning heaters: 95% ii. Clean wood burning heaters: 4% iii. Pellet fueled wood burning heaters: 1%

2. Distribute the Valley Total ARB emissi on inventory (Table B-2) between the wood burning heaters with the percentages above. a. EXAMPLE: i. Dirty wood burning heaters 1. Fresno County Wood Stove em ission inventory x percentage of emissions from dirty wood burning stoves 2. 0.812 tpd x 0.95 3. 0.771 tpd from dirt y wood burning heaters

Table B-3 2015 PM2.5 Em ission Inventory for Wood Stoves (tons per woodburning season day)

County Dirty Wood Burning Heaters Clean Wood Burning Heaters Pellet-Fueled Wood Burning Heaters
Fresno 

## 0.771 0.032 0.008
Kern 

## 0.342 0.014 0.004 Kings 

## 0.051 0.002 0.001
Madera 

## 0.319 0.013 0.003
Merced 

## 0.578 0.024 0.006 San Joaquin 

## 0.362 0.015 0.004
Stanislaus 

## 0.709 0.030 0.007
Tulare 

## 1.471 0.062 0.015

2 

### EPA. Consumers – Energy Efficiency and Wood-Burning Stoves and Fireplaces. (2012, November 14). Retrieved from http://www.epa.gov/burnwise/energyefficiency.html

3 

### EPA. Consumers – Energy Efficiency and Wood-Burni ng Stoves and Fireplaces. (2012, November 14). Retrieved from http://www.epa.gov/burnwis e/energyefficiency.html

.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-8 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## E. Distribute the inventory into new categor ies. The new categories are: 1) Clean wood burning heaters and 2) Di rty wood burning heaters

The determination of the emissions reduc ed relies on a tiered approach to episodic curtailments. Wood burning heaters that are categorized as “Clean” wood burning heaters consist of pellet-fueled wood burning heaters and wood burning heaters with an EPA Phase II or more stringent certification. These clean wood burning heaters would be allowed to be used up to the 65 μg/m 3 

## threshold. Wood burning heaters categorized as “Dirty” wood burning heaters consis t of wood burning heaters without EPA certification, EPA Phase I certified wood burning heaters, and wood burning fireplaces. Dirty wood burning heaters would only be allowed to be used up to the 20 μg/m 3 

## threshold. Therefore, it is necessary at this point in the emission reduction process to distribute the emission inventory into the two categories, thus allowing for accurate emission reductions calculations later in this analysis.

1. Determine the ton per day emissions for clean wood burning heaters for each county by adding the pellet-fueled w ood burning heater emission inventory (Table B-3) and the clean wood burning heater inventory (Table B-3). a. Example: i. Fresno County pellet-fueled wo od burning heater inventory + Fresno County clean wood bur ning heater inventory ii. 0.008 tpd + 0.032 tpd iii. 0.041 tpd 2. Determine the ton per day emissions for Dirty wood burning heaters for each county by adding the dirty wood burning heat er emission inventory (Table B-3) and the fireplace emission inventory (Table B-2) a. Example: i. Fresno County dirty wood burning heater inventory + fireplace inventory ii. 0.771 + 1.301 iii. 2.072 tpd

Table B-4 2015 PM2.5 Emissi ons for Clean and Dirty wood burning heaters by County (tpd)

County Clean Wood Burning Heaters Dirty Wood Burning Heaters Fresno 0.041 2.072
Kern 0.018 1.196 Kings 0.003 0.224
Madera 0.017 0.645
Merced 0.030 1.010 San Joaquin 0.019 2.465 Stanislaus 0.037 1.828
Tulare 0.077 2.377

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-9 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## F. Determine the number of estimated No Burn days for future years

Dirty wood burning heaters (non- EPA certified wood burning heaters and fireplaces) will experience an increase in No Burn days as discussed in t he staff report.

Table B-5 Average Number of Days Forecast Abov e Curtailment Thresholds*

County Current Threshold ( ≥ 30 μg/m3) Proposed Threshold ( ≥ 20 μg/m3) Additional No Burn days

Fresno 49 85 36
Kern 44 79 35 Kings 39 70 31
Madera 29 67 38
Merced 19 55 36 San Joaquin 24 53 29 Stanislaus 36 72 36
Tulare 36 69 33 Average: 34
*Based on Forecast values from the 2009- 10, 2010-11, 2011-12, 2012-13, 2013-14 woodburning seasons



## G. Determine the emission reductions

1. Determine the emission reductions for eac h county by multiplying the number of additional No Burn days (Table B-5) for each county by the daily emission inventory for Dirty wood burning heat ers that county (Table B-4). a. Example: i. Fresno County additional no burn days x Fresno County Dirty wood burning heater inventory ii. 36 additional days per season x 2.072 tons per day iii. 74.61 tons per season reduced

Table B-6 Total Emissions Reduced by County (tons per season)

County Emissions Reduced Fresno 74.61
Kern 41.86 Kings 6.95
Madera 24.52
Merced 36.35 San Joaquin 71.48 Stanislaus 65.80
Tulare 78.43 TOTAL 399.99

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-10 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## H. Determine the number of estimated in crease in burn days for registered wood burning heaters for future years

Wood burning heaters that regist er with the District will ex perience an increase in days they are allowed to burn during the wood burning season, as discussed in the staff report.

Table B-7 Average Number of Days Forecast Above 65 μg/m 3



## County Current Threshold ( ≥ 30 μg/m3) Days over ≥ 65 μg/m3 Additional Burn days
Fresno 49 6 43

Kern 44 6 38 Kings 39 6 33

Madera 29 1 28

Merced 19 0 19 San Joaquin 24 0 24

Stanislaus 36 2 34

Tulare 36 4 32 Average: 31
*Based on Forecast values from the 200 9-10, 2010-11, 2011-12, 2012-13, 2013-14 wood-burning seasons



## I. Determine the additional emissions fr om the additional number of burn days for the registered wood burning heaters

1. Determine the emissions for each county by multiplying the number of additional burn days (Table B-7) for each county by the daily emission inventory for clean wood burning heaters that county (Table B-4). a. Example: i. Fresno County additional burn days x Fresno County clean wood burning heater inventory ii. 43 additional days per season x 0.041 tons per day iii. 1.75 tons per season

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-11 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## Table B-8 Emissions from Additional Bu rn Days from Registered Wood Burning Heaters (tons per season)

County Emissions Increase Fresno 1.75

Kern 0.68 Kings 0.09
Madera 0.47
Merced 0.58 San Joaquin 0.46

Stanislaus 1.27

Tulare 2.48 TOTAL 7.77



## J. Determine the overall emission reducti ons from implementation of the tiered curtailment program

1. Determine the total emission reducti ons for the Valley by subtracting the emissions increase from registered w ood burning heaters (Table B-8) from the emissions reduced (Table B-6). a. Example: i. Fresno County emission reducti ons – Fresno County emissions increase ii. 74.61 tons per season – 1.75 tons per season iii. 72.86 tons of PM2.5 em issions reduced per season

Table B-9 Overall Emissions Reductions (tons per season)

County Emissions Reduced Emissions Increased Overall

Fresno 74.61 

## 1.75 72.86

Kern 41.86 

## 0.68 41.18 Kings 6.95 

## 0.09 6.86

Madera 24.52 

## 0.47 24.05

Merced 36.35 

## 0.58 35.77 San Joaquin 71.48 

## 0.46 71.03

Stanislaus 65.80 

## 1.27 64.53

Tulare 78.43 

## 2.48 75.95
TOTAL 399.99 

## 7.77 392.22

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-12 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## K. Determine the total burn season emission reductions for the Valley Determine the total burn season emission reductions for the Valley in tons per day by dividing the overall total emissions reduced (Table B-9) by the number of wood burning season days. a. Overall total emissions reduced per season/number of wood burning season days b. 392.22 tons per season / 120 wood burning season days c. 3.27 tons per day

L. Determine the total winter seas on emission reductions for the Valley Determine the total winter season emission reductions for the Valley in tons per day by dividing the overall total emissions reduced (Table B-10) by the number of winter season days. a. Overall total emissions reduc ed per season/number of wood burning season days b. 392.22 tons per season / 180 wood burning season days c. 2.18 tons per day

This section intentionally blank.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-13 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## III. EMISSION REDUCTIONS FROM PROP OSED AMENDMENTS TO RESIDENTIAL WOOD BURNING PROGRAM

A. Contributing factors to emission reductions from proposed amendments to the District’s resident ial wood burning program The directly emitted PM2.5 emissions reduced through the implementation of the amendments to the District’s residential wood burning program would be the result of the following:

1) The replacement of older more polluting wood burning heaters and wood burning fireplaces to cleaner alternatives as a re sult of the combinat ion of the episodic curtailment levels and the increased incent ive amounts as discussed in detail in the staff report; and 2) The implementation of the lowered cu rtailment threshold from 30 to 20 μg/m 3



## .
The following is a summary of this analysis.

Survey Results The results from a third party survey of Valley residents (see A ppendix E) identify the two main motivators for t he transition to clean wood bur ning heaters. 24% of Valley residents with non-EPA certified wood bur ning heaters and wood bur ning fireplaces would transition to cleaner burning wood burning heaters if they were provided a discount of up to 50% off the cost of the new wood burning heater. 29% of Valley residents would be willing to replace thei r current wood burning fireplace or wood burning heater with a cl eaner, less-polluting wood burning heater if they could use it more often than currently allowed. Taking th is information into account, the District is recommending increasing incentive amounts and increasing the number of burn days allowed for qualified regi stered wood burning heaters th rough a tiered curtailment
program.

Conservative Analysis To perform a conservative emission reduc tion analysis for the transition of non-EPA certified wood burning heaters and wood burni ng fireplaces to cleaner wood burning heaters the District assumes 24% of the older more pollu ting wood burning heaters and wood burning fireplaces would be transitioned to clean wood burning heaters. This is a conservative estimate because based on survey results it’s more likely that 29% of the more polluting wood burning heaters and wood burning fireplaces would be replaced. Additionally, based on data in the Burn Cleane r Program database, the majority of wood burning heaters and wood burning fireplaces that are r eplaced are actually replaced with gas-fired units (which are cleaner than wood burning heaters) instead of wood burning heaters.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-14 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## B. Emission reduction cal culation methodology

Total emissions reduced as a result of am endments to the Distr ict’s residential wood burning program would be equal to the emissi on reductions resultin g from 24% of the older more polluting wood burning heaters and wood burning fireplaces being replaced with clean wood burning heaters pl us the emissions that w ould be reduced from the remaining dirty wood burning he ater emission inventory due to the implementation of the tiered curtailment program , discussed above, minus the additional emissions that would be generated from the now clean re gistered wood burning heaters being operated on days when the pollutant levels would be forecast to be 20-65 μg/m 3



## .

Table B-10 below summarizes the calculat ions performed to determine the emission reductions from the proposed amendments to the residential wood burning program.

In summary: 3.33 tpd -0.065 tpd + 2.04 tpd – 0.22 tpd = 5.1 tpd of directly emitted PM2.5 emissions reduced.

This section intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTFinal Draft Staff Report: Residential WoodBurning Program September 18, 2014B-15Final Draft Staff Report with Appendices forProposed Amendments to Residential Wood Burning ProgramTable B-10 Emission Reductions Resulting fromConversion of Dirty Heaters to Clean HeatersA B C D E F G H I JSource /FormulaTable B-6 A / 120 Table B-8 C / 120Table B-4(total) - BF x 0.24 G x 20%Table B-5 +Table B-7G x H I / 120Emissionsreduced fromdirty devicesresulting fromlowering thecurtailment from30 to 20 μg/m3(tons/season)Emissionsreduced fromdirty devicesresulting fromlowering thecurtailment from30 to 20 μg/m3(tpd)Emissionsfrom registeredwood burningheaters onadditional burndays (whenforecast isbetween 30and 65 μg/m3)(tons/season)Emissionsfrom registeredwood burningheaters onadditional burndays (whenforecast isbetween 30and 65 μg/m3)(tpd)Remainingemissionsfrom dirtydevices afterlowering thecurtailmentthreshold(tpd)Emissionsreducedfrom 24% ofdirty devicestransitioningto cleandevices(tpd)20% increasein emissionsfrom newlyregistereddevices(whenforecast isbetween 20and 65 μg/m3)(tpd)Number ofadditionalburn days forregistereddevices(whenforecast isbetween 20and 65 μg/m3)(tpd)Emissionsfrom newlyregistereddevices onadditionalburn days(whenforecast isbetween 20and 65 μg/m3)(tons/season)Emissionsfrom newlyregistereddevices onadditionalburn days(whenforecast isbetween 20and 65 μg/m3)(tpd)Fresno 74.606 0.62 1.75 0.015 1.450 0.348 0.070 79 5.50 0.05Kern 41.860 0.35 0.68 0.006 0.847 0.203 0.041 73 2.97 0.02Kings 6.953 0.06 0.09 0.001 0.166 0.040 0.008 64 0.51 0.00Madera 24.518 0.20 0.47 0.004 0.441 0.106 0.021 66 1.40 0.01Merced 36.346 0.30 0.58 0.005 0.707 0.170 0.034 55 1.87 0.02SanJoaquin71.484 0.60 0.46 0.004 1.8690.449 0.090 53 4.76 0.04Stanislaus 65.797 0.55 1.27 0.0111.280 0.307 0.061 70 4.30 0.04Tulare 78.428 0.65 2.48 0.021 1.723 0.414 0.083 65 5.38 0.04TOTAL 3.33 0.065 2.04 0.22

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis September 18, 2014

B-16 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## This page intentionally blank.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Economic Anal ysis September 18, 2014

C - 1 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# APPENDIX C

Economic Analysis

Proposed Amendments to Resi dential Wood Burning Program

September 18, 2014

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Economic Anal ysis September 18, 2014

C - 2 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## This page intentionally blank.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Economic Anal ysis September 18, 2014

C - 3 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## ECONOMIC ANALYSIS Amendments to Rule 4901

Pursuant to California Health and Safety C ode (CH&SC) requirements, the District has performed a cost effectiveness analysis and socioeconomic analysis to assess the economic impacts of amendments to Rule 4 901 in the Valley. The registration of residential wood burning heaters is an optiona l program; no Valley resident is required to replace an existing wood bur ning heater or to register their wood burning heater. Therefore, there are no required costs or economic impacts associated with the new registration program. Howeve r, potential economic impa cts could result from the revised Episodic Wood Burning Curtailments.

Rule amendments would reduce emissions from residential wood burning activities by implementing a tiered approach to episodically curtailing wood burning based on air quality each day during the w ood burning season. In summary, Level One Episodic Curtailments would be declared when the PM2.5 concentrations are forecast to exceed 20 μg/m 3 

## but not to exceed 65 μg/m 3 

## ; the use of registered clean wood burning heaters would be allowed. Level Two Episodic Curt ailments would be decla red when the PM2.5 concentrations are forecast to exceed 65 μg/m 3 

## ; the use of all residential wood burning heaters would be prohibited. Re fer to the staff report for a more detailed discussion of the Episodic Wood Burning Curtailments; see Figure C-1 for a visual representation of these curtailments.

Figure C-1 Visual Representation of Ep isodic Tiered Curtailment Thresholds

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Economic Anal ysis September 18, 2014

C - 4 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## I. Cost Effectiveness Analysis

Per CH&SC Section (§) 40920.6(a), the Distric t conducts absolute and incremental cost effectiveness analyses of available emission control options to evaluate the economic reasonableness of a rule or ru le amendment prior to adoption. As the following write-up will explain, these rule amendments resu lt in an annual emissi on reduction of 392.22 tons of directly emitted PM2.5 (refer to A ppendix B), with no significant additional cost to Valley residents.

Absolute cost effectiveness of a control opt ion is the additional annual compliance cost (in dollars per year) of the control technol ogy or technique divided by the emission reduction achieved in tons of pollutant reduced per year (tons/year).

Incremental cost effectiveness is the differ ence in cost between two successively more effective controls, divided by the addition al emission reduction achieved. An incremental cost effectiveness analysis was not performed because it is not applicable to this project as there is only one control option

As discussed in the body of t he staff report, lowering of the threshold for Episodic Wood Burning Curtailments from 30 μg/m 3 

## to 20 μg/m 3 

## would result in an estimated Valleywide average increase of 34 No Burn days per wood burning season per county. The costs resulting from this anal ysis are not significant.

Additionally, the registra tion of clean burning residentia l wood burning devices is an entirely optional program; no Valley resident is required to replace an existing device or register their device. As these requirem ents are not mandatory, there are no required costs associated with them.

Table 1 Additional No Burn Days Proj ected for Each Wood Burning Season by County

County Additional No Burn days San Joaquin 29
Stanislaus 36
Merced 36
Madera 38
Fresno 36 Kings 31
Tulare 33
Kern 35



## Costs incurred by Valley residents would be t he cost of turning on the home’s heating system instead of burning an approved fuel such as seasoned wood or pellets in the

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Economic Anal ysis September 18, 2014

C - 5 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## home’s wood burning heater. Be cause these costs only occur for an additional 34 days per year and because the cost of the electricity is offset by the cost of the approved fuel, amendments to this rule are considered no co st amendments. The Dis trict is aware that some residents burn free wood; however this is considered an anomaly due to its rarity and will therefore not be accounted for in this analysis.

II. Socioeconomic Analysis

A. I NTRODUCTION



## Pursuant to CH&SC §40728.5 as well as the District’s 2011 Economic Analysis Process Recommendations

, 1 

## the District conducted a socioec onomic analysis of the proposed rule amendments. This so cioeconomic analysis, guided by the CH&SC, examines how rule amendments may impact the San Joaquin Valley’s (Valley’s) industries and businesses, employment rates, and economy.

B. S OCIOECONOMIC 

## A NALYSIS



## The CH&SC consists of six specific requirem ents. The discussion of the necessity of adopting, amending, or repeali ng Rule 4901 to attain st ate and federal ambient air quality standards is in the body of the staff re port. The emission reductions potential of amendments to the rule are discussed in Appendix B (Emission Reduction Analysis). The other four CH&SC requirements for a socioeconomic analysis are satisfied through this appendix.

1. Type of industries or businesses, in cluding small businesses, affected by amendments to the rule A socioeconomic impact is any effect to the Valley’s employment or economy due to a regulatory action. The followi ng groups that could potentially be affected by these rule amendments are manufacturers of the devices, retailers who sell the devices and associated fuels, retailers who sell t he seasoned wood for fireplaces, and Valley residents who live in homes with fireplaces or wood burning heaters that do not qualify to be registered with the District.

There are no manufacturers of wood burning heaters in the Va lley. Retailers who sell residential wood burning devices and associated fuels are in a position to increase profits due to the estimated in crease in Valley residents w ho will upgrade their existing fireplaces and older more polluting devices for EPA certified devices. Retailers who sell the seasoned wood for fireplaces would experi ence some decrease in profits due to the additional No Burn days, however they w ould still be able to sell smaller amounts of wood to those homes with r egistered wood burning devices who will see an increase in

1 

### San Joaquin Valley Air Pollution Contro l District [SJVAPCD]. (2011, October 20). Enhancements to District Economic Analysis of Regulations. Fresno, CA. Retrieved from http://www.valleyair.org/Board_meetings/GB/agenda_min utes/Agenda/2011/October/GB_Agenda_Item_13_Oct_20_ 2011.pdf

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Economic Anal ysis September 18, 2014

C - 6 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## the use of their wood burning he aters. The combi nation of relatively few increased No Burn days with the continued use of wood in EPA certified devices, and the ability of the retailer to pass on profit losses to the c onsumer will minimize economic impacts on these retailers. No significant socioeconomic impacts are expected to result from rule amendments.

2. Availability and cost effectiveness of alternatives to the rule amendments There are no alternatives to lowering the episodic wood burning curtailment threshold; therefore, there would be no increased cost.

3. Impact of amendments on employ ment and the economy of the region Because this is a no cost rule and the so cioeconomic impacts on Valley businesses and industries is not significant, no impact is ant icipated on employment or the economy of the region.

C. A DDITIONAL 

## S OCIOECONOMIC 

## A NALYSES



## Per the 2011 Economic Analysis Pr ocess Recommendations document, District staff is advised to include additional analyses as a part of each socioeconomic analysis for new or amended rules. As such, the District al so evaluated the costs and socioeconomic impacts from previous versions of a rule and Impacts to small businesses, municipalities, and at-risk communities.

1. Costs and Socioeconomic Impacts fr om Previous Versions of the Rule Rule 4901 was adopted on July 15, 1993 and subsequently amended in July 2003 and again in October 2008. For purposes of th is analysis, the District did a ten year historical review which in cluded the October 2008 amendm ents. The analyses for the 2008 amendments resulted in the conclusion t hat impacts stemming from the proposed amendments are less than significant across the board, particularl y from the vantage point of the retailers that sell logs and sm all businesses are not disproportionately impacted by the rule.

2. Impacts to Small Businesses, Muni cipalities, and At-Risk Communities As discussed in the analyses above, the impact to small businesses and at-risk communities is less than significant and munici palities would not be affected by rule amendments.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Health Benefit Analysis September 18, 2014

D - 1 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

# APPENDIX D

Health Benefit Analysis

Proposed Amendments to Resi dential Wood Burning Program

September 18, 2014

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Health Benefit Analysis September 18, 2014

D - 2 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## This page intentionally blank.

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Health Benefit Analysis September 18, 2014

D - 3 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## HEALTH BENEFIT ANALYSIS

I. Health Benefits from Reducing Wood Smoke Exposure

Based on a large body of interrelated scientif ic research conducted in the San Joaquin Valley (Valley) and elsewhere, episodic cu rtailments of resident ial wood combustion (RWC) under Rule 4901 have resulted in subs tantial health benef its for the Valley population since these controls were adopted in 2003 and strengthened in 2008. Furthermore, the rule is the most cost-effect ive rule adopted by the San Joaquin Valley Air Pollution Control District (District), c onferring the greatest abs olute health benefit of any rule ever adopted by the District at the lowest per unit cost. As discussed further below, the large value of these benefits is re lated to (1) the high level of cumulative population exposure to urban RWC emissions compared to other sources, (2) the relative effectiveness of burning curtailment s in reducing per capita PM2.5 exposure levels in urban areas where the Valley popul ation is concentrated, (3) the relative toxicity of chemicals found in the fine (PM2 .5) and ultrafine (PM0.1) particles that are generated by wood combustion, and (4) the overnight penetrati on of ultrafine particles from RWC into neighboring homes. As a resu lt of these factors, Rule 4901 is a key component of the District’s Health Risk R eduction Strategy (HRRS) that was put forward in the 2012 PM2.5 Plan . The HRRS goes beyond a simple focus on PM2.5 mass and incorporates additional health-related metrics (such as PM0.1 exposure) for prioritizing control strategies fo r individual emission sources.

Wood smoke contains a combination of aeros ols (particles) that are less than 2.5 microns in diameter (PM2.5) with an additional large number of ultr afine particles less than 0.1 microns (PM0.1). It is also a rich source of gasses including carbon monoxide, formaldehyde, sulfur dioxide, and other irri tant gases such as polycyclic aromatic hydrocarbons (PAH). PAH species are re cognized as potential carcinogens and are also highly implicated in the triggering of oxidative stress that promotes the malfunctioning of the immune system, par ticularly among previously sensitized individuals such as asthmatics. 1 

## The toxic air pollutants in wood smoke can cause human health impacts such as coughs, headaches, and eye and throat irritation. Studies also show that prolonged inhalati on of wood smoke contributes to chronic interstitial lung disease, 2 

## pulmonary arterial hypertension, 3 

## and pulmonary heart disease, 4 

## which can eventually lead to heart failure in adults. 5 

## Wood smoke has also

1 

### Kelly, F.J. (2006) Oxidative Stress: Its Role in Air Po llution and Adverse Health Effects. Occupational Environmental

Medicine 60:612–616. Retrieved from http://oem.bmj.com/content/60/8/612.full

2 

### Defined as a group of lung diseases affecting the inte rstitium (the tissue and space around the air sacs of the

lungs), resulting in a progressive scarring of lung tissue. The scarring associated with interstitial lung disease eventually affects the ability to breathe and get enough oxygen into the bloodstream.

3 

### Pulmonary arterial hypertension begins when tiny arteries in the lungs, called pulmonary arteries, and capillaries

become narrowed, blocked, or destroyed. This makes it har der for blood to flow through to the lungs, and raises pressure within lung arteries.

4 

### Defined as an abnormal enlargement of the right side of the heart resulting from high blood pressure in the

pulmonary blood vessels (aka pulmonary arterial hypertension).

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Health Benefit Analysis September 18, 2014

D - 4 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## been linked to detrimental mutagenic and system ic effects such as oxidative stress and blood coagulation, which can ultimately re sult in cell damage and possibly lead to

cancer. 6, 7, 8 

## Children with the highest exposure to wood smoke show a significant decrease in lung function. 9



## On a regional level, the enc losed geophysical environment of the Valley acts to magnify the health impacts of wintertime RWC relative to other Californ ia air basins such as the Bay Area and South Coast that are well-expos ed to fresh marine air currents and not surrounded by mountains that tr ap the pollutants. The Va lley regularly experiences multi-day periods of atmospheric stagnati on during which very little air mass is transferred in and out of the Va lley. The net result is a day-to-day buildup of PM2.5 levels, sometimes well beyond the federal daily standard of 35 μg/m 3 

## . Compounding these multi-day stagnation event s, the region experiences severe winter inversions upon nightfall, characterized by a marked reduc tion in the height of the mixing layer. This results in a magnified concentration of directly emitted particulates that envelop urban neighborhoods. Because of the conc entration effect of winter nighttime inversions, urban RWC has a disproportiona te impact on daily and yearly PM2.5 concentrations at urban monitors.

People are exposed to wood smoke when they use their wood burning devices, particularly when starting or re loading wood stoves or fireplaces. Additionally, because windows and doors cannot prevent ultrafine particles (PM0.1) in wood smoke from penetrating homes, neighbori ng households that are dow nwind of wood-burning neighbors during inversion ev ents are exposed to PM0.1 found in wood smoke. A recent ARB-funded study of residential wood smoke impacts on indoor air quality was conducted in Cambria, Ca lifornia and published in 2011. 10 

## Using aethalometers designed to monitor carbon black found in wood smoke, the study found nighttime outdoor concentrations in Cambria neighbor hoods were 2 to 10 times higher than the cleanest part of the city. Most significantly, over the course of the winter season, indoor

5 

### Sandoval, J.; Slas, J.; Martinez-Guerra, M.L.; Gomez, A.; Martinez , C.; Portales, A.; Palomar, A.; Villegas, M.; and

Barrios, R. Pulmonary Arterial Hypertension and Cor Pulm onale Associated with Chronic Domestic Woodsmoke Inhalation. (1993) Chest 103:12-20.

6 

### Danielsen, P.H.; Bräuner, E.V.; Barregar d, L.; Sällsten, G.; Wallin, M.; Olinski, R.; Rozalski, R.; Mø ller, P.; Loft, S.

Oxidatively damaged DNA and its repair after experiment al exposure to wood smoke in healthy humans. (2008) Mutat Res . 642(1-2):37-42.

7 

### Barregard, L.; Allsten, G.S.; Gustafson, P.; Johansson, L .; Johannesson, S.; Basu, S.; Stigendal, L. Experimental

Exposure to Wood-Smoke Particles in Healthy Humans: Effects on Markers of Inflammation, Coagulation, and Lipid Peroxidation (2006) Inhalation Toxicology 18:845–853.

8 

### Sapkota, A.; Gajalakshmi, V.; Jetly, D.H.; Roychowdhury, S.; Dikshit, R.P.; Brennan, P .; Hashibe, M.; Boffetta, P.

Indoor air pollution from solid fuels and risk of hypopharyn geal/laryngeal and lung cancers: a multicentric casecontrol study from India. (2008) Int J Epidemiol . 37(2):321-8.

9 

### Heumann, M.; Foster, L.R.; Johnson, L; Kelly, L. Woodsmoke Air Pollutio n and Changes in Pulmonary Function

Among Elementary School Children (1991) Air & Waste Management Association 84th Annual Meeting & Exhibition, Vancouver, British Columbia.

10 

### Thatcher, T. & Kirchstetter, T. (2011). Assessing Near-Field Exposures from Distributed Residential Wood Smoke

Combustion Sources . Report prepared for the California Air Resources Board. Retrieved from http://www.arb.ca.gov/researc h/rsc/10-28-11/it em2dfr07-308.pdf

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Health Benefit Analysis September 18, 2014

D - 5 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## concentrations of carbon black in neigh boring non-burning homes were found to be 74% as high as concentrations meas ured just outside the same homes.

This combination of processes results in a very high intake fraction (the portion of a source’s total emissions that actua lly end up being inhaled) for neighborhood wood combustion when compared to other sources of PM that are less proximate to urban neighborhoods or do not generat e large numbers of PM0.1. Taking into consideration the length of PM0.1 inhalation during sleeping hours, the relati vely high concentration of PM0.1 found in RWC plumes, and the number affected of individuals in an urban neighborhood, the intake frac tion resulting from the sour ce of the wood smoke is relatively high. Assuming that this nightly exposure occurred over the course of a season, the cumulative health risk to the neighborhood from PM0.1 exposure is likely to exceed the risk indicated by daily concent rations of PM2.5 measured by urban monitors.

Any evaluation of the relative health benefits of Rule 4901 mu st take in consideration a number of risk factors that am plify the health effects of wood smoke emissions relative to other sources addressed in the 2012 PM2.5 Plan . First, it is recognized that the organic carbon compounds such as PAH th at compose wood smoke are known to trigger negative pulmonary and cardiovascular, especially for sensitive populations. A recent epidemiological study conducted in Modesto, Fresno, and Bakersfield found a clear positive statistical correlation between daily organic carbon concentrations and emergency room admission rates for asthmatics. 11 

## That same study found no evidence of a positive correlation between elevat ed emergency room admissions and daily concentrations of ammonium nitrate, a sp ecies that composes approximately 50% of daily PM2.5 mass during winter months. Second, as noted above, the intake fraction of wood smoke emissions is an estimated order of magnitude higher in densely populated urban areas when compared to rural emissions that are diluted via transport in lowpopulation density env ironments.

Based on the cumulative evidence, it is clear that because of the relative toxicity of wood smoke related to its high levels of OC , the high level of PM0.1 particles found in wood smoke, and the high intake fraction of RWC emissions, health impacts from PM2.5 have been shown by Valley epidemiol ogical research to be concentrated in winter months when RWC emissions are highes t. To conclude, on a per unit basis each ton of RWC emissions makes a disproportionate contribution to negative health effects from PM2.5 in the Valley.

11 

### http://www.valleyair.org/Board_meetings/GB/agenda _minutes/Agenda/2014/June/ presentations/11-A.pdf

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Health Benefit Analysis September 18, 2014

D - 6 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## II. Using EPA’s BenMAP Model to Esti mate Health Benefits of Rule 4901

Reflecting the scientific factors described a bove regarding the disproportionate health benefits from reducing exposure to wood smok e, prior research sponsored by the District has shown that Rule 4901 and subsequent amendments (2003, 2008, 2014) confer substantial health benef its for residents of the Vall ey. This is particularly apparent when taking into consideration that the health benefits have continued to accumulate via each successive amendment of Rule 4901.

Baseline scientific evidence in support of this contention was generated prior to the adoption of the 2008 Amendments and focused on the health benefits of the episodic RWC curtailments established by the 2003 Amendments. This was made possible through the combined use of meteorological modeling developed by District staff and the EPA’s Environmental Benefits Mapping and Analysis Program (BenMAP). BenMAP is an EPA-developed computer model desi gned to quantify reductions in morbidity (disease) and mortality (pre-m ature death) based on an esti mated reduction in annual daily exposure to a given population. Once the reduction in annual daily exposure has been estimated based, the model then calculates (1) the num ber of reduced cases of disease-related events and pre-mature deat h for a given reduction in annual PM2.5 exposure and (2) the economic val ue of those avoided health impacts. 12 

## A more detailed explanation of how the BenMAP model works is found in Appendix E of the District’s 2012 PM2.5 Plan

. 13



## According to the results of the study conduc ted by the Central Valley Health Policy Institute and UCSF-Fresno, the signific ant winter season PM2.5 mass reductions attributable to daily RWC curtailments under Rule 4901 were equivalent to a 13.6% annual (year-round) reduction in daily PM 2. 5 exposure for Fresno, and an estimated 12.9% annual reduction for Bakersfield.

The significant increase in the number of cu rtailment days resulting from the lower 24 hour threshold adopted in the 2008 Ru le 4901 amendments from 65 μg/m 3 

## to 30 μg/m 3 

## has resulted in a proportional increase in the health benefits of the rule above and beyond that of the 2003 Amendments. Furt her significant health benefits can be expected from the proposed reduction in t he 24 hour curtailment threshold for Rule 4901 to 20 μg/m 3



## .
Our point of emphasis here is that the heal th benefits resulting from each Rule 4901 amendment are cumulative, with each revision re sulting in an additional set of health benefits. In particular, the 2003 and 2008 amendments have contributed very large health benefits that clearly exceed the health benefits of any previous District rule for PM2.5 or ozone. In addition Rule 4901 has made a disproportionate contribution to declines in daily tons per day of direct ly emitted PM2.5 over the past decade.

12 

### BenMAP can also estimate the health benefits of ozone reduction. See http://www.epa.gov/air/benmap/ for more information on BenMAP, downloading the pr ogram, and for technical documents.

13 

### See http://www.valleyair.org/Air_Quality_Plans/PM25Plans2012.htm

## SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix D: Health Benefit Analysis September 18, 2014

D - 7 Final Draft Staff Report with Appendices for Proposed Amendments to Residential Wood Burning Program 

## According to ARB’s PM2.5 inventory, RWC emissions composed 25.1% of total winter direct PM2.5 emissions in 2003 and have been reduced through the Rule amendments to 12.7% in 2014. The comparable figures for reductions in annual daily tpd from RWC is 12.2% in 2003, declining to 5.7% in 2014. Put differently, 2014 wintertime RWC emissions have declined by 64.7% since 2003, whereas total emissi ons of PM2.5 from all sources have only declined by 30% in the same time period.

Further insights can be gained fr om examining the cumulative contribution to health risk reduction from Rule 4901 in the context of the District’s use of the BenMAP model to estimate the annual health benefits from all new control measures in the 2012 PM2.5 Plan . Keeping in mind the disproportionate contribution of Rule 4901 both to overall health benefits and daily tonnage of dire ct PM2.5 discussed above, Table D-1 summarizes the substantial health benefit s based on the BenMAP analysis of the 2012 PM2.5 Plan . The health benefits in Table D-1 do not capture the already considerable health benefits of the 2003 and 2008 amendment s. And while it is difficult to quantify the health benefits of an individual rule due to the statistical limit ations of the BenMAP model, a review of all c ontrol measures in the 2012 PM2.5 Plan make it clear that the 2014 Rule 4901 amendment continues to make the largest health benefit contribution of any single control measure in the 2012 PM2.5 Plan . As emphasized above, these health benefits are incremental additions to the already substant ial benefits that have already resulted from the 2003 and 2008 amendments.SAN JOAQUIN VALLEY UNIFIED AIRPOLLUTION CONTROL DISTRICTAppendix D: Health Benefit Analysis September 18, 2014D - 8Final Draft Staff Report with Appendices forProposed Amendments to Residential Wood Burning ProgramTable D-1: BenMAP Estimates of 2019 Average Annual Reduction in Morbidity and Mortality under the 2012PM2.5 PlanHealth Endpoint TotalsFresno Kern San Joaquin Stanislaus Tulare Merced Kings MaderaAcute MyocardialInfarction9329 25 9 7 11 3 4 4HA, Asthma 0-1913156 28 9 11 13 4 4 6HA, Cardiovascular17547 51 16 14 26 6 10 5HA, Asthma 20-9924664 77 30 16 35 11 7 6ER Visits, Asthma 20-99407123 94 48 28 53 22 23 16Chronic Bronchitis595168 164 57 49 80 25 29 23ER Visits, Asthma 0-19699252 160 47 44 90 36 35 37Acute Bronchitis1,498404 406 149 127 222 72 64 54Upper RespiratorySymptoms15,5234,206 4,294 1,482 1,260 2,334 728 667 552Lower RespiratorySymptoms19,0115,093 5,207 1,887 1,595 2,829 912 807 681Asthma Exacerbation114,37631,144 31,124 11,269 9,469 17,037 5,445 4,867 4,021Work Loss Days125,13834,816 35,300 11,75210,077 16,882 5,367 6,303 4,641Pre-Mature Mortality671172 207 72 61 86 26 23 24Note: Shaded health endpoints are based on concentration response functions (CRF) derived from the 2010 Valley EpidemiologicalStudy conducted by CSU Fresno and UCSF-Fresno.

## APPENDIX E

Public Survey Repor ts

Proposed Amendments To Residential Wood Burning Program



### September 18

, 2014

### This page intentionally blank.

# Re sidential W ood Burning

, Law n

Care, and Commuting Survey

Fin al Re po rt

Feb ruary 2014

Sub mit ted t o :


# San Joa quin Val l e y Air Pollution Control District

Sub mit ted b y :


## Gomez Res ea rch Pas adena, Cal i forniaP ublic Op inio n Su r vey 2014

Go mez Re sea rc h i T AB L E O F C ONTENTS

E XE C UTIVE S UMMARY

..................................................................................... iv

I. INTRODUCTION

....................................................................................... 1

II. METHODOLOGY

....................................................................................... 1

III. FINDINGS

.................................................................................................. 3

Resi dentia l W oo d Burni ng

.......................................................................... 3
Presence of Wood-Burning Devices Use of Wood-Burning Devices Regional/Demographic Differences in Use of Wood-Burning Devices Awareness and Impact of the Check Before You Burn Program Awareness and Interest in the Burn Cleaner Rebate Program Beliefs about Wood Smoke

Residential Lawn Care

............................................................................... 9

Use of Gas-Powered Lawn and Garden Equipment Use and Frequency of Professional Lawn Service Awareness and Interest in the Clean Green Yard Machines Rebate Program

Commuting Patterns

.................................................................................. 13
Current Commuting Behavior Future Behavior Student Pick-Up and Drop-Off Beliefs about Car Idling at Schools as a Source of Air Pollution

General Beliefs and Awareness

................................................................ 17
Perceptions of Local Air Quality Awareness and Perceptions of the Air Pollution Control District

I V. C ON C LU SIONS

........................................................................................... 19

APPENDICES:
Appendix A: Survey Instrument with Weighted Frequencies

Appendix B : Demographic Profile of Residents SurveyedP ub lic Opini o n Survey 2014

Go me z Rese a rch ii List of T ab les

T ab l e 1 : Demographic Profile of Residents Surveyed Compared to Population Estimates

....... 30P ub lic Opini o n Survey 2014

Go me z Rese a rch iii List of Figures

Fi gure 1: Proportion of Residents with a Wood-Burning Fireplace, Wood Stove, Pellet Stove

.... 3
Figure 2: How Often Residents use their Fireplace/Stove in the Winter Months

..................... .... 4
Figure 3: Number of Hours Residents Reported Burning a Fire, Once Started

..................... .... 4
Figure 4: Type of Fuel Burned Among Residents Who Use Wood-Burning Devices

................... 5
Figure 5: Proportion of Residents with Wood-Burning Devices, by Region

................................ . 5
Figure 6: Awareness of the Check Before Your Burn Program, 2010 and 2014

.......................... 6
Figure 7: Residents Who Reported Reducing Wood-Burning In Response to the Check Before

You Burn Program

...................................................................................................................... 7
Figure 8: Residents Aware of the Burn Cleaner Program

........................................................... 7
Figure 9: Residents Willing to Replace Their Traditional Fireplace/Stove

................................... 8
Figure 10: Residents Who Believe Wood Smoke is a Significant Source of Air Pollution

............ 9
Figure 11: Proportion of Residents Who Use a Lawn Care Service, Respondents Overall

......... 9
Figure 12: Proportion of Residents Using Gas-Powered Lawn or Garden Equipment

............... 10
Figure 13: Types of Gas-Powered Lawn and Garden Equipment Residents Used

................... 10
Figure 14: Number of Times a Month Residents Use Lawn Service During the Summer

.......... 11
Figure 15: “ Does the Lawn Service Come as Often During Winter ?”

....................................... 11
Figure 16: Would Consider Switching to a Lawn Service with Cleaner Equipment

.................... 12
Figure 17: Residents Aware of the Clean Green Yard Machines Rebate Program

................... 12
Figure 18: How Residents Travel to Work, Respondents Overall

.............................................. 13
Figure 19: Conditions Under Which Residents Would Consider Carpooling

............................ 14
Figure 20: How Children are Transported to School

................................................................ . 15
Figure 21: Reasons Residents Do Not Allow Their Children to Walk to School

......................... 15
Figure 22: Awareness of Id ling as a Source of Air Pollution Effecting Children’s Health

........... 16
Figure 23: Public Perception of Local Air Quality, Respondents Overall, 2010 and 2014

.......... 17
Figure 24: Performance Ratings, San Joaquin Valley Air Pollution Control District

................... 18P ub lic Opini o n Survey 2014

Go me z Rese a rch iv 

## EXEC U T IVE SU MMARY

As part of its mission to bring the San Joaquin Valley into compliance with federal and state clean air standards, the San Joaquin Valley Air Pollution Control District contracted with Gomez Research, an independent research and consulting firm, to conduct a survey of residents to help evaluate residential wood burning, lawn care, and commuting patterns. The purpose of the study was to gauge residents’ activity levels as well as to document public awareness and understanding of the District’s programs. The study was designed to measure: (1) residential wood-burning frequency; (2) the use of gas-powered lawn equipment and professional lawn care services; (3) personal commuting behavior and student transportation; and (4) perceptions of the District, its programs, and the local air quality. Findings will be used to gauge the effectiveness of the District’s outreach programs, inform future outreach strategies, and provide data for estimating the emissions produced from these three

sources.

A t otal o f 1,000 telephone surveys were conducted with owners and renters of single-family homes 1 i n S an Joa quin, Stanislaus, Merced, Kings, Fresno, Madera, Tulare Counties and the Valley portion of Kern County, yielding an overall margin of error of +/-3 percent. The survey was conducted in English and Spanish and 40 percent of all telephone interviews were conducted on cell phones, ensuring that residents without landlines would be included in the study. Gomez Research used random-digit dialing (RDD) techniques whereby telephone prefixes were matched to zip codes for the San Joaquin Valley geographical area, and the remaining four digits were randomly generated. The surveys were conducted between January 3 and January 19, 2014. The average length of the survey was 9 minutes in English and 12 in Spanish. Results were weighted to ensure that the sample reflected U.S. Census data. All statements presented here refer to the region as a whole, unless otherwise indicated. In addition, all differences between demographic groups presented here are statistically significant at the 95 percent confidence level, unless otherwise noted. Key findings are presented by topic area for respondents overall, followed by any differences among sub-groups.



### Ke y Findings

R es i denti a l Wood Burning

a. N ea rl y one - t hird (32 percent) of all residents surveyed reported have a wood-burning
device in their home. Among those residents with wood-burning devices, 13 percent were identified as exempt from mandatory no-burn restrictions.

b. N ea rl y one - qu arter of residents who use their devices (23 percent) reported lighting their fireplace or stove once a week or more. Once started, fires burn for six hours on

average.

c. R es po nden t s who reported using their devices weekly reported burning fires for longer periods of time. Residents who used their devices once a week or more reported burning their fires for 8.3 hours on average compared to 3.5 hours among those who used their devices less frequently.

1 T he sa m ple is limited to single-family units to ensure that the greatest number of respondents would be able to answer questions regarding wood combustion and lawn care. Based on U.S. Census data, we estimate that more than 80 percent of housing units in the San Joaquin Valley service are single-family units. In some communities, such as Madera, nearly 90 percent of the units are single family.P ub lic Opini o n Survey 2014

Go me z Rese a rch v d. Ju st un der three-fourths of residents surveyed (71 percent) burn seasoned firewood, followed by a third (32 percent) who use manufactured logs, such as Duraflame, and 13 percent who use pellets. A total of 11 percent of residents surveyed reported that they burn trash, magazines, newspapers and/or other household materials as fuel.

e. T he study found significant differences by region in the proportion of residents with wood-burning devices in their homes. Residents in the Northern Region, including San Joaquin, Stanislaus, and Merced Counties, were more likely to own wood-burning devices compared to other residents. A total of 37 percent of residents from the Northern region reported having a wood-burning fireplace or stove in their homes, compared to 28 percent among residents in the Central region (Fresno, King, and Madera Counties) and the Southern region (Kern and Tulare Counties), a statistically significant difference.

f. E ng l ish- spe akers (defined as those who chose to conduct the survey in English) were more likely to report that they had a wood-burning fireplace or stove compared to Spanish-speakers. Specifically, 37 percent of all English-speakers reported having a wood burning device at their residence compared to 15 percent among Spanish-speakers.

g. R esi de nts ab ov e median income were also more likely to report that they had wood burning devices compared to those below-median income (41 percent compared to 26 percent, respectively). In addition, homeowners were more likely to report having a wood-burning device compared to renters.

h. R es i dents w ho are exempt from mandatory wood-burning regulations were more likely to own a wood-burning device compared to other residents ( 45 percent of exempt residents compared to 29 percent of non-exempt residents).

i. T he Che ck Before you Burn Program continues to be widely recognized by Valley
residents. There were no statistical changes in the proportion of residents who reported hearing of the program (80 percent in 2014 compared to 83 percent in 2010, statistically equivalent).

j. I n addi t ion

, more than three-fourths (78 percent) of residents with wood burning devices who had heard of the Check Before You Burn Program reported that they had reduced their wood burning as a result.
k. Less than a quarter of all residents surveyed (17) were familiar with the Burn Cleaner Program.

l. Just un der one-third (29 percent) of residents surveyed reported that they would be willing to replace their traditional wood- bur ning fireplace or stove if they could use it on some No-Burn days.

m. A t otal of 12 percent of all residents with traditional wood burning devices reported that they would be willing to make the purchase if given a 15 percent discount.P ub lic Opini o n Survey 2014

Go me z Rese a rch vi n. Findings su gges t that approximately 24 percent of residents with wood-burning devices would participate in the program if the rebate were increased to 50 percent (combined totals for residents who would participate at 15, 25, and 50 percent levels.)

o. More than half of all residents surveyed (55 percent) reported that they believe wood smoke is a significant source of air pollution in their neighborhoods. Residents living in the Central Region (Fresno, Madera, and Kings County) were more likely to report that wood smoke was a problem (63 percent) compared to residents from the Northern and Southern regions (49 percent and 53 percent, respectively).



### Re sid e ntial L awn Car e

a. T he majori t y of San Joaquin Valley residents (61 percent) tend to their own lawns rather
than hire a service. One quarter of residents use a lawn service to handle all of their yard work and another 3 percent use a lawn service for a portion of the work.

b. Nearly three-fourths of residents (73 percent) who care for their own lawns and gardens use gas-powered equipment , most frequently walk-behind lawn mowers (84 percent), lawn edgers (39 percent), string trimmers (38 percent), and leaf blowers (35 percent).

c. Most residents (54 percent) use a service four times a month during the summer followed 22 percent who use a service every other week. Fewer than 10 percent of residents use a service more than once a week. The average number of times a lawn service was used in the summer was four times. Approximately half (46 percent) of residents who use a lawn service reported that their lawn service comes as frequently during the winter months.

d. A total of 84 percent of all residents surveyed reported that they were not aware of the Clean Green Yard Machine Rebate Program. Spanish-speakers were much less likely thanEnglish-speakers to report that they had heard of the Rebate Program (5 percent of Spanishspeakers compared to 18 of English-speakers). In addition, results suggest that Spanishspeaking residents are more likely to care for their own lawns. More than two-thirds of Spanish-speakers (69 percent) reported that they or others in their household do all the yard work, compared to 58 percent among English speakers, a statistically significant difference.

C ommut i ng P atterns

a. H alf of the residents surveyed reported that they drive alone to work, followed by 30 percent who do not work outside of the home. A total of 12 percent reported that they drive in a carpool or vanpool. Only 2 percent of respondents reported that they take public transportation.

b. Approximately half of commuters surveyed reported that they would consider carpooling if their employer provided a more flexible work schedule, financial incentives, assistance with coordinating carpool partners, or free parking.P ub lic Opini o n Survey 2014

Go mez Rese a rch vii c. A m on g res i dents with school age children (42 percent of all residents surveyed) nearly half reported that they drive their children to school. Approximately one-quarter of residents reported that their children take the school bus or walk/bike to school. Less than 3 percent of all residents reported that the ir children take public transportation or carpool with
other students.

d. Th e m ost frequently cited reasons for not allowing children to walk or bike to school were distance and concerns about safety.

e. M ore t han t w o-thirds (69 percent) of residents with school-age children agreed that idling cars are a significant source of air pollution.

G en era l B eliefs and Awareness

a. Findings i ndi ca te that the majority of residents believe the air quality in the San Joaquin Valley has improved or stayed the same compared to three years ago (similar to results from the 2010 survey)

. There was, however, a 5 percentage-point decrease this year in the proportion of residents who believe the air quality has gotten “ somewhat worse ” over time.

b. A w aren ess of the District remains high among residents. A total of 57 percent of residents this year reported that they had heard of the District, unchanged from 2010.

c. M ore tha n two-thirds (68 percent) of all residents familiar with the District reported that they had a “very favorable” or “somewhat favorable” view of the District.



### Conclusions

Overall, study findings suggest that past outreach efforts have helped raise public awareness about the District and its programs, but further outreach is still needed. The Check Before You Burn Program continues to be recognized by eight-out- of -ten residents, and those residents aware of the Program report that they have reduced their wood-burning in response to the outreach. In contrast, awareness of the Burn Cleaner and Clean Green Yard Machine Rebate Programs could be improved. Less than 20 percent of residents are aware of either the Burn Cleaner or Clean Green Yard Machine Rebate Programs. Spanish-speakers, who are more likely to care for their own lawns compared to other residents, had particularly low awareness levels. In addition, findings suggest that more residents would consider carpooling to work if their employers offered a flexible schedule, financial incentives, free parking or other programs. These findings suggest that efforts to build more employer
progr ams and outreach to increase awareness of the District’s rebate programs may be helpful in promoting changes in personal behavior and improving air quality.P age 1



## I N TRODUCTION

The San Joaquin Valley Air Basin, which spans 250 miles and is home to three million residents, is unusually susceptible to air pollution. The Valley’s surrounding mountain topography, hot summers, foggy winters and frequent temperature inversions help form and retain a variety of air pollutants. While air quality in the Valley has improved significantly over the past 15 years, the Valley continues to be one of the more polluted regions in the nation.

As part of its mission to bring the San Joaquin Valley into compliance with federal and state clean air standards, the San Joaquin Valley Air Pollution Control District contracted with Gomez Research to conduct a survey of residents to help evaluate residential wood burning, lawn care, and commuting patterns. The purpose of the study was to gauge residents’ activity levels as well as to document public awareness and understanding of the District’s programs. The study was designed to measure : (1) residential wood-burning frequency; (2) the use of gas-powered lawn equipment and professional lawn care services; (3) personal commuting behavior and student transportation; and (4) perceptions of the District, its programs, and the local air quality. Findings will be used to gauge the effectiveness of the District’s outrea ch programs, inform future outreach strategies, and provide data for estimating the emissions produced from these three sources.

The remainder of this report presents the survey methodology and findings that emerged from the data analyses and is organized as follows:

 T he M et ho dology

section, which describes data collection and statistical methods;

 The Findings section, documenting awareness and behaviors;

 Conclusions ; and,

 The Appendices, which include the survey instrument, frequencies for each question, and a demographic profile of residents surveyed compared to known population estimates.



## M ETH ODOL OGY

O v erv ie w

A t otal o f 1,000 telephone surveys were conducted with owners and renters of single-family homes 2 i n S an J o aquin, Stanislaus, Merced, Kings, Fresno, Madera, and Tulare Counties and the Valley portion of Kern County

, yielding an overall margin of error of +/-3 percent. The survey was conducted in English and Spanish and 40 percent of all telephone interviews were conducted on cell phones, ensuring that residents without landlines would be included in the study. Gomez Research used random-digit dialing (RDD) techniques whereby telephone prefixes were matched to zip codes for the San Joaquin Valley geographical area, and the remaining four digits were randomly generated. All respondents were 18 years or older. (For a copy of the survey, including frequencies overall see Appendix A.)
T he survey s were conducted between January 3 and January 19, 2014 using a computer-assisted telephone interview (CATI) system in which interviewers read questions from a computer screen and typed respondents’ answers directly into a database. The average length of the survey was 9 minutes in English and 12 in Spanish.

2 The sa m ple is limited to single-family units to ensure that the greatest number of respondents would be able t o answer questions regarding wood combustion and lawn care. Based on U.S. Census data, we estimate that more than 80 percent of housing units in the San Joaquin Valley service are single-family units. In some communities, such as Madera, nearly 90 percent of the units are single family.P age 2 C av eats

I t shoul d be noted that the residential survey, like all surveys, has self-reporting bias and should be used in conjunction with results from air pollution reports to determine the extent to which residents are participating in activities that reduce air pollution. Survey research depends on respondents providing truthful and accurate reports of their activities. In addition, caution should be taken in comparing data from 2014 with responses from the 2010 survey. The 2010 survey included all residents, whereas the 2014 survey focused on residents living in single-family homes and duplexes to ensure a sufficient sample of residents with wood-burning devices and private lawns.

Wei gh t ing

T he sample was weighted to reflect the population based on the following dimensions: age, race/ethnicity, gender, telephone use, and county of residence. Data were not weighted on income due to non-response bias. Weighting target values were based on the average (population-adjusted) characteristics of the eight-county area. Characteristics were derived from the U.S. Census. Telephone use data were obtained from the U.S. Center for Disease Control. Weighting was conducted through iterative proportional fitting, also known as raking.

S t ati st i cal Comparisons

S t ati sti cal tests were conducted for all comparative analyses to identify whether observed differences among demographic groups or categories were statistically significant. 3 A l l r eported differences were statistically significant at the 95 percent confidence level unless otherwise noted.

R ep ort O rgan ization

T hi s rep or t has been organized around the following topical areas:

 Residential Wood Burning;

 Residential Lawn Care;

 Commuting Patterns; and,

 General Beliefs and Awareness.

T he nex t section of this report presents study findings.

3 A stati s tically significant difference means that the difference between years or among groups is not by chance, and that a real difference exists.P age 3



## F I NDINGS

Residential Wood Burning

A key objective of the research was to gauge the use of wood-burning devices in the San Joaquin Valley and to measure public awareness of outreach campaigns designed to reduce wood-smoke pollution. Results are presented for residents overall, followed by demographic and regional differences.

P r ese nce o f Wood Burning Devices

R esp on dents w ere first asked if they had a wo od -burning fireplace, wood stove, or pellet stove in their home. As seen in Figure 1, nearly one-third (32 percent) of all residents surveyed reported hav ing a wood-burning device in their home. Among those residents with wood-burning devices, 13 percent were identified as exempt from mandatory no -burn restrictions. 4

*Figu r e b a sed on Q2: I’d like to ask you about the heating devices you may have in your home. Do you have a wood -burning fireplace, wood stove, or pellet stove in your home?

U se of Wood-Burning Devices

R esp on dents w ho reported having a wood-burning device were asked how often they use their fireplace or stove during the winter months. Results are presented in Figure 2

. In 2014 , more than
half of all residents with a wood-burning fireplace or stove reported that they do not use their

4 E xem p t residents were defined as those living in areas where no natural gas connections are available or in cases where the wood-burning device is the sole source of heat at a residence. No Wo od

- Bu rni ng Dev i c e, 6 8% Pe ll et Sto ve, 3% W o o d Sto ve, 4% W o o d

- Bu rn i ng Fi re p la c e, 25% Fi gu re 1: Proportion of Residents with a Wood

- Burnin g Fi repla c e, Wood Stove or Pe ll e t Stov e Res po nd ents Overall (n=1,000)

No Wo o d-Bu rn ing Device Pe l l et S tove Wo o d Sto v e Wo o d -Burn i ng FireplaceP age 4 de v ices (59 percent), up from 49 percent in 2010. Despite an apparent drop in the use of woodburning devices overall

, nearly one-quarter of residents who use their devices (23 percent) reported lighting their fireplace or stove once a week or more. A total of 8 percent of residents reported using their fireplace or stove nearly every day.

*Figure based on Q5: How often do you use your fireplace/stove in the winter? Nearly every day, several days a week, once a week, les s than once a week, or not at all?

To help estimate the volume of wood-smoke produced during the winter season, residents who reported using their fireplaces or stoves were asked how many hours they typically burn a fire once
started. As seen in Figure 3, nearly two-thirds of residents ( 65 percent) burn their devices for
four hours or less. Once started, fires were burned for six hours on average (the median was four hours)

.

R espondents who reported using their devices weekly reported burning fires longer each time. Residents who used their devices once a week or more reported burning their fires for 8 .3 hours on average compared to 3.5 hours among those who used their devices less frequently (no chart).

*Figure based on Q6 : “ Once started, how many hours does your fire usually burn? ”

0% 1 0 % 2 0 % 3 0 % 4 0 % 5 0 % 6 0 % No t a t all Le s s than once a week O nc e a week S ev eral day s a week Ne arly ev eryda y

59% 17% 8% 7% 8% Fi gu re 2: How Often Residents use their Fireplace/Stove in the Winter Months, Among

Res po nd ents Who Use Their Wood

- Burnin g Dev ice (n =330)

0% 5% 1 0% 1 5% 2 0% 2 5% 3 0% 3 5% 4 0% 4 5% 2 4 h ou rs a day 7 -13 ho u rs 5 -6 h ou rs 3 -4 h ou rs 1 -2 h ou rs

10%

7% 15% 42% 24% Fi gure 3: Number of Hours Residents Reported Burning a Fire, Once Started A m on g Res po ndents Who Use Wood

- Burnin g Dev ice s (n=133)P age 5 N ex t, respondents who use their wood-burning devices were asked what type of fuel they typically
burn. As seen in Figure 4, nearly three-fourths of residents surveyed (71 percent) burn seasoned firewood, followed by a third (32 percent) who use manufacture d logs, such as Duraflame and 13 percent who use pellets. A total of 11 percent of residents surveyed reported that they burn trash, magazines, newspapers and/or other household materials.

*Figure based on Q7: “which of the following types of fuel do you typically burn?”

*Figure based on Q7: “ Which of the following types of fuel do you typically burn? ”

R eg i onal / Demographic Difference in Use of Wood Burning Devices

T he stud y found significant differences by region in the proportion of residents with wood-burning
devices in their homes

. As seen in Figure 5, residents in the Northern Region, including San Joaquin, Stanislaus, and Merced Counties, were more likely to ow n wood-burning devices compared to other residents. A total of 37 percent of residents from the Northern region reported having a wood-burning fireplace or stove in their homes, compared to 28 percent among residents in the Central region (Fresno, King, and Madera Counties) and the Southern region (Kern and Tulare Counties), a statistically significant difference

.



### * Figure based on Q2: I’d like to ask you about the heating devices you may have in your home. Do you have a wood -burning fireplace, wood stove, or pellet stove in your home? Statistically significant differences at the 95 percent confidence level are circled.

0% 5% 1 0% 1 5% 2 0% 2 5% 3 0% 3 5% 4 0% So u th (n= 3 25) Cen t ra l (n =3 05) Nort h (n =36 8 )

28% 28% 37% Fi gu re 5: Proportion of Residents with Wood

- Burnin g Dev ice s

Res pond ents Overall, by Region 0% 1 0 % 2 0 % 3 0 % 4 0 % 5 0 % 6 0 % 7 0 % 8 0 % O th e r (s p ecify) Tra s h , m a gazines, newspapers, other household... Pe l l ets Pa rti a ll y dried wood that has some moisture M a n uf a ctured logs, such as Duraflame Se a s on e d firewood, split and dried

1% 11% 13% 22% 32% 71% Fi gu re 4: Type of Fuel Burned A m on g Res po ndents Who Use Wood

- Burnin g Dev ice s (n=133)P age 6 0% 1 0% 2 0% 3 0% 4 0% 5 0% 6 0% 7 0% 8 0% 9 0% Not Sure /Refu s ed

No Ye s

4% 12% 83%

2% 18% 80% Fi gu re 6: Awareness of the Check Before You Burn Program

Res pond ents Overall, 2010 and 2014

2 01 4 (n =1 33)

2 0 1 0 (n =6 40) A dd i ti on al differences were found by language spoken, income, and other demographics. Results are presented below.

 English-dominant speakers (defined as those who chose to conduct the survey in English) were more likely to report that they had a wood-burning fireplace or stove compared to Spanish-speakers. Specifically, 37 percent of all English-speakers reported having a wood burning device at their residence compared to 15 percent among Spanish-speakers.

 Residents above median income were also more likely to report that they had wood burning devices compared to those below-median income (41 percent compared to 26 percent, respectively). Homeowners were also more likely to report having a wood-burning device compared to renters.

 Residents who are exempt from mandatory wood-burning regulations were more likely to own a wood-burning device compared to other residents ( 45 percent of exempt residents compared to 29 percent of non-exempt residents).

A w areness and I mpa c t of the Check Before you Burn Program

T hi s yea r , awareness questions regarding the Check Before You Burn Program were specifically asked of residents with wood-burning devices who are not exempt from mandatory no-burn restrictions to provide a more accurate picture of the potential impact of program awareness on ai r quality. (In previous years, all residents were asked the question, regardless of whether they had a wood-burning device or were exempt from regulations). As seen in Figure 6 , the Check Before You Burn Program continues to be widely recognized by residents. There were no statistical changes in the proportion of residents who reported hearing of the program, even though a more specific segment of the population was surveyed (80 percent in 2014 compared to 83 percent in 2010, statistically equivalent).

*Figure based on Q8: Check Before You Burn runs from November through February each year, and prohibits wood burning in fireplaces, wood or pellet stoves, and outdoor fire pits during certain days when it is determined that air quality levels will be most impacted. Have you ever heard of the Check Before You Burn program?” In 2014, only respondents who reported having a wood-burning stove and were not exempt from mandatory no -burn regulations were asked the question. In 2010, all respondents were asked.P age 7 0% 1 0 % 2 0 % 3 0 % 4 0 % 5 0 % 6 0 % 7 0 % 8 0 % 9 0 % Not Sure /Refu s ed

No Ye s

1% 82%

17% Fi gure 8 Re s idents Aware of the Burn Cleaner Program

Res po nd ents Overall (n=1,000) N ex t

, r espondents who reported that they had heard of the Check Before You Burn Program were asked if they had reduced the amount of wood they burn in response to the outreach. Results are presented in Figure 7. More than three-fourths (78 percent) of residents with wood burning devices who had heard of the Check Before You Burn Program reported that they had reduced their wood burning as a result.

*Figure based on Q9: Have you reduced the amount of wood burning you do in response to the Check Before You Burn Program? Bas e includes those respondents who have wood-burning devices, are not exempt from no-burn regulations, and have heard of the Check Before you Burn Program.

A w areness an d I n terest of the Burn Cleaner Rebate Program

I n addi t ion to measuring awareness of the Check Before You Burn Program, the study asked all respondents if they were aware of the Burn Cleaner Rebate Program which offers rebates to residents who replace their traditional fireplace or stove with a cleaner-burning device. Results are presented in Figure 8. Less than a quarter of all residents surveyed (17 percent) reported that they had heard of the Burn Cleaner Program, suggesting that more outreach is needed.

*Figure based on Q10: “ To encourage cleaner burning in the Valley, there is a grant program that offers rebates to residents who replace their traditional fireplace or stove with a cleaner-burning device such as a certified wood stove or a gas fireplace. Are you aware of this grant program, it is called Burn Cleaner ? ” 0% 1 0 % 2 0 % 3 0 % 4 0 % 5 0 % 6 0 % 7 0 % 8 0 % Don ’ t Kno w M a y be No Ye s

1% 5% 16% 78%

Fi gu re 7: Residents Who Reported Reducing Wood

- Burnin g In Res pons e to the Check

- Befo re You Burn Progra m Res po nd ents Aware of the Program (n=110)P age 8 0% 1 0 % 2 0 % 3 0 % 4 0 % 5 0 % 6 0 % Don ’ t Kno w /Refused I a l rea d y have a clean-burning device No Ye s

8%

5% 58% 29% Fi gu re 9: Residents Willing to Replace Their Traditional Fireplace/Stove Res po nd ents with Wood

- Burnin g Dev ice s (n=330) R esp on dents w ho reported that they owned a wood-burning device were asked if they would be willing to replace their current wood-burning fireplace or stove with a cleaner device if they could use it on some No-Burn days. As seen in Figure 9, just under one-third (29 percent) reported that they would be willing to switch devices if they could use it on some No-Burn days.

*Figure based on Q11: “Would you be willing to replace your current wood -burning fireplace or stove with a cleaner, less-polluting woodburning device if you could use it on some No- Burn days?”

To gauge the level of discount needed to drive residents to purchase a clean burning device

, respondents were presented with varying percentage discounts of 15, 25, and 50 percent off the totalestimated cost of $3,000 to purchase a new device. (All respondents who reported owning a woodburning device or stove were asked the question, even if they reported in the previous question that they were not interested in replacing their device.) A total of 12 percent of all residents with traditional wood burning devices reported that they would be willing to make the purchase if given a 15 percent discount.

Those respondents who reported that they would not be willing to purchase a cleaner device even if offered a 15 percent discount were asked if they would make the purchase if the discount were increased to 25 percent

. Fewer than 5 percent of respondents who refused a 15 percent discount said they would be swayed by a discount of 25 percent. Respondents who were not interested in a 15 or 25 percent discount were asked if they would replace their current device for a 50 percent rebate. An additional 16 percent said they would

.
Findings suggest that approximately 24 percent of residents with wood-burning devices would participate in the program if the rebate were increased to 50 percent (combined totals for residents who would participate at 15, 25, and 50 percent levels.)P age 9 B el i efs ab out Wood Smoke

T he last q uestion regarding residential wood burning addressed beliefs about wood smoke. As seen
in Figure 10 , more than half of all residents surveyed (55 percent) reported that they believe wood smoke is a significant source of air pollution in their neighborhoods. Residents living in the Central Region (Fresno, Madera, and Kings County) were more likely to report that wood smoke was a problem (63 percent) compared to residents from the Northern and Southern regions (49 percent and 53 percent, respectively).

*Figu r e b a sed on Q13: “Do you believe wood smoke is a significant source of air pollution in your neighborhood?”



### Res ident ial La wn Care

A no t her objective of the study was to gauge the impact of gas-powered lawn equipment on air pollution and to measure awareness of programs designed to reduce pollution from these sources. Findings are presented below.

U se of G as -Powered Lawn and Garden Equipment by Residents R esp on dents w ere first asked who usually maintains their lawns and garden areas. As seen in Figure 11, the majority of San Joaquin Valley residents (61 percent) tend to their own lawns rather than hire a service. One quarter of residents use a lawn service to handle all of their yard work and another 3 percent use a lawn service for some of the yard work.

*Figu re b a sed on Q20: “Who usually maintains your lawn, shrubs, trees or garden areas?”

0% 5% 1 0 % 1 5 % 2 0 % 2 5 % 3 0 % 3 5 % 4 0 % 4 5 % Don ’ t Kno w /Refused No Ye s
, pro b ably Ye s
, de fi nitely

5% 41% 20% 35% Fi gu re 10 : Residents Who Believe Wood Smoke is a Significant Source of Air Pollution

Res po nd ents Overall (n=1,000)

0% 1 0% 2 0% 3 0% 4 0% 5 0% 6 0% 7 0% Don ’t kn o w/Refused Don ’t ha v e a lawn/Don’t care for it A l awn se ri vice does all the yard work I or o the rs in the household do some of the yard... I or o the rs living in the household do all the yard work

2% 8% 25% 3% 61% Fi gure 11 : Proportion of Residents Who Use a Lawn Care Service

Res po nd ents Overall (n=1.000)P age 10 Reside nts who reported caring for their own lawns and gardens were asked if they use gas-powered equipment and, if so, to name the type of equipment. Results are presented in Figures 12 and 13

. Nearly three-fourths of residents (73 percent) who care for their own lawns and gardens use

gas -powered equipment, most frequently walk-behind lawn mowers (84 percent), lawn edgers (39 percent), string trimmers (38 percent), and leaf blowers (35 percent)

.

*Figure based on Q21: “Do you use any gas

- powered lawn or garden equipment at your residence?”

*Figure based on Q22: “Considering only gas

- powered lawn and garden equipment, which of the following do you use?”

0% 1 0 % 2 0 % 3 0 % 4 0 % 5 0 % 6 0 % 7 0 % 8 0 % Don ’ t kn o w/Refused

No Ye s

2% 25% 73% Fi gu re 12 : Proportion of Residents Using Gas

- Pow e red La w n or Garden Equipment

Res po nd ents Who Care for their Own Lawns (n=639)

0% 1 0 % 2 0 % 3 0 % 4 0 % 5 0 % 6 0 % 7 0 % 8 0 % 9 0 % Stu m p Grind e rs/Chippers Sn o w B l owers Sh re d de rs Wo o d Spl i tters L a w n & G arden Tractors

Ti l l ers Rid in g L awn Mowers Bru s h cu tt ers/Hedgeutters

Cha in Saws L ea f Bl o wers Stri ng Tri m mers L aw n Ed g ers Wa l k -be h ind Lawn Mowers

2% 2% 3% 4% 4% 8% 10% 18% 25% 35%

38% 39% 84% Fi gu re 13 : Types of Gas

- Pow e red La w n and Garden Equipment Residents Used

Res po nd ents Who Use Gas

- Pow e red Equ ip ment (n=459)P age 11 U se and F r eq ue ncy of Professional Lawn Service

R esi de nts w ho reported that they use a lawn service were asked how many times of month they use the service and whether that frequency varied by season. As seen in Figure 14 , most residents (54 percent) use a service four times a month during the summer, followed by 22 percent who use a service every other week. Less than 10 percent of residents use a service more than once a week. The average number of times a lawn service was used in the summer was four times.

*Figure based on Q23: “During the summer, how many times a month does the lawn service come?”

Next, residents who use a lawn service were asked if the lawn service comes as often during winter. Approximately half (46 percent) of residents who use a lawn service reported that their lawn service comes as frequently during the winter months. See Figure 15.

*Figure based on Q24: “Does the lawn service come as often during the winter?” 0% 1 0 % 2 0 % 3 0 % 4 0 % 5 0 % 6 0 %

Fo u r t im e s a month Th re e ti m es a month Twi c e a m o nth O n c e a m onth

54%

4% 22%

6% Fi gu re 14 : Number of Times a Month Residents Use Lawn Service During the Summer

A m on g Res po ndents Who Use a Lawn Care Service (n=291)

0% 1 0% 2 0% 3 0% 4 0% 5 0% 6 0% Y es , 4 6 % No, 5 1 %

Don ’ t kn o w, 3%

Fi gu re 15 : "Does the Lawn Service Come as Often During Winter?" A m on g Res po ndents Who Use a Lawn Service (n=291)P age 12 Reside nts were then asked if they would consider switching to a lawn care service that used cleaner equipment if that service cost less than their current service, the same as their current service, or more than their current service. Results are presented in Figure 16 . A total of 41 percent of respondents reported that they would not consider switching.

* Figure based on Q25: “Would you consider switching to a lawn care service that used cleaner equipment if it cost: less, the same, or more than your current service?”

A w areness and I nt eres t in the Clean Green Yard Machines Rebate Program

A s seen in Figure 17, 84 percent of all residents surveyed reported that they were not aware of the Clean Green Yard Machine Rebate Program. Spanish-speakers were much less likely than English-speakers to report that they had heard of the Rebate Program (5 percent of Spanish-speakers compared to 18 of English-speakers). In addition, results suggest that Spanish-speaking residents are more likely to care for their own lawns. More than two-thirds of Spanish-speakers (69 percent) reported that they or others in their household do all the yard work, compared to 58 percent among English speakers, a statistically significant difference.

*Figure based on Q26: “Are you aware of a grant program which offers a rebate incentive for electric lawn mowers? The progra m is called the Clean Green Yard Machines Rebate Program?” 0% 5% 1 0 % 1 5 % 2 0 % 2 5 % 3 0 % 3 5 % 4 0 % 4 5 % Don ’ t kn o w/Refused Wo u l d n ot consider Cos ts m ore t han current service Cos ts s am e as current service Cos ts l es s than current service

15% 41% 2% 16% 25% Fi gu re 16 : Would Consider Switching to Lawn Service with Cleaner Equipment

Res po nd ents Who Use a Lawn Care Service (n=291)

Don ’t kn o w, 1% Y e s , 1 5 %

No, 84 % Fi gu re 17 : Residents Aware of the Clean Green Yard Machines Rebate Program

Res pond ents Overall (n=1,000)P age 13 0% 5% 1 0 % 1 5 % 2 0 % 2 5 % 3 0 % 3 5 % 4 0 % 4 5 % 5 0 % Don ’t Kno w /Refused Wo r k at h ome one or more days a week

Us e p ub l ic transportation

Wa l k or b i ke Dri v e in c arpool or vanpool Don ’ t wo rk outside the home

Dri v e al o ne

1%

2% 2% 3% 12% 30% 50% Fi gu re 18 : How Residents Travel to Work Res po nd ents Overall (n=1,000) 

### Commut ing P a tte rns

I n addition to measuring sources of air pollution from wood-smoke and gas-powered lawn equipment, the study was designed to track commuting patterns and the circumstances under which residents would consider carpooling over driving alone. The study also measured how scho ol -age children travel to and from school. Results are presented below.

C urr en t C ommuting Patterns

R esp on dents w ere first asked how they usually get to work. Results are presented in Figure 18

. Half of the residents surveyed reported that they drive alone to work, followed by 30 percent who do not work outside of the home . A total of 12 percent reported that they drive in a carpool or vanpool. Only 2 percent reported that they take public transportation.

*Figure based on Q14: “How do you usually get to work?”P age 14 Fu t ure B eh avior

T o hel p id entify strategies for increasing the proportion of Valley residents who carpool to work, residents were read a list of employer programs and asked if they would consider carpooling instead of driving alone if the incentive were offered. Results are presented in Figure 19

. Approximately half of commuters surveyed reported that they would consider carpooling if their employer provided a more flexible work schedule, financial incentives, assistance with coordinating carpool partners, or free parking. While support for most of the programs was statistically comparable, on -site food service was less popular than a flexible work schedule or financial incentives.

*Figure based on Q15: “Please answer yes, no, or maybe to each of the following questions: I would carpool if ...?” Significant differences at the 95% confidence level are circled. On -site food service was less popular than a flexible work schedule and financial incentives. 0% 1 0 % 2 0 % 3 0 % 4 0 % 5 0 % 6 0 %

M y e mp l oyer p ro v id e d a more fl ex ib l e work

s c h ed u le M y e mp l oyer

p ro v id e d a fi na nc i al incentive I co ul d get

a s s is ta nce with fi nd in g a carpool
p a rtn er i n my

n ei gh b orhood M y e mp l oyer

p ro v id e d free d es ig n ated

c a rp oo l parking M y e mp l oyer

p ro v id e d onsite fo od se rv ice

a n d /or l unch 51% 49%

45%
43% 40% Fi gu re 19 : Conditions Under Which Residents Would Consider Carpooling

A m on g Res po ndents Who Drive Alone (n=452)P age 15 S t ud ent Pick Up and /Drop Off

I n addi t ion to assessing the problem of commuter traffic, the study examined travel to and from school. Among residents with school-age children (42 percent of all residents surveyed ) nearly half reported that they drive their children to school. O ne -quarter of all students walk or bike to school and 21 percent take the school bus

. Less than 3 percent of all residents reported that their children take public transportation or carpool with other students. See Figure 20

.

*Figure based on Q15: “Please answer yes, no, or maybe to each of the following questions: I would carpool if ...?”

*Figure based on Q16a : “ How do your children usually get to school? ”

*Figure based on Q16a : “ How do your children usually get to school? ”

Next, residents were asked why their children do not walk or bike to school. As seen in Figure 21, the primary reasons for not allowing children to walk or bike to school were distance and concerns about safety.

*Figure based on Q17: “What is the main reason you would not let your child walk to school either alone or with an adult?” 0% 5% 1 0 % 1 5 % 2 0 % 2 5 % 3 0 % 3 5 % 4 0 % 4 5 % 5 0 % Don ’ t Kno w /Refused M y c hi l dren are home schooled Carp o o l w ith other students Ta k e pu b lic transportation Dri v e th e mselves Ta k e th e school bus Wa l k or b i ke So m e on e in household drives them

0% 1% 1% 2% 4% 21% 24% 46% Fi gu re 20 : How Children are Transported to School A m on g Res po ndents with School

- A ge Chi ldren (n=381)

0% 5% 10% 15% 20% 25% 30% 35% 40% 45% Ref us ed t o answer Not e n ou g h time in the schedule No si de wal k in my neighborhood Con c e rne d about safety

To o f ar

3% 7%

2% 43% 44% Fi gu re 21 : Reasons Residents Do not Allow Their Children to Walk to School A mon g Res po ndents Whose Children Do Not Walk or Bike (n=281)P age 16 B el i efs ab out Car Idling at Schools as a Source of Air Pollution

Fi na l ly

, residents with school-age children were asked if they consider idling cars at school drop-off and pick- up lines to be a source of air pollution that affect children’s health. More than two-thirds (69 percent) of residents with school- ag e children agreed that idling cars are a significant source of air pollution, as seen in Figure 22.

*Figure based on Q19: “Do you consider idling cars at school drop -off and pick-up lines to be a significant source of air pollution that can affect children’s health? 0% 1 0 % 2 0 % 3 0 % 4 0 % 5 0 % 6 0 % 7 0 % Don ’ t kn o w/Refused

No Ye s

7% 25% 69% Fi gu re 22 : Awareness of Idling as a Source of Air Pollution Effecting Children's

A m on g Res po ndents with School

- A ge Chi ldren (n=381)P age 17



### Genera l Beliefs and Awareness

Finally, the study addressed public perceptions of local air quality and perceptions of the Air Pollution Control District. Results are presented below.

P ercept i ons o f Local Air Quality

I n 2010 and 2014

, residents were asked if they thought the air quality in their areas had gotten better,

w orse, or st ayed the same. As seen in Figure 23, most residents believe the air quality in the San Joaquin Valley has improved or stayed the same compared to three years ago (similar to results from 2010)

. There was, however, a 5 percentage-point decrease this year in the proportion of residents who believe the air quality has gotten “somewhat worse” over time.

* Fi gu r e based on Q27 : “Compared to three years ag o, would you say the air quality in your area has gotten better, gotten worse, or stayed the same? better/worse: Is that much better/worse or somewhat better/worse?) ”

*Figu re b a sed on Q27: “Compared to three years ago, would you say the air quali ty in your area has gotten better, gotten worse, or stayed the same? (If better/worse: Is that much better/worse or somewhat better/worse?)” Statistically significant changes at the 95 % confidence lev el ar e circled. 0% 1 0 % 2 0 % 3 0 % 4 0 % 5 0 % 6 0 % M u c h W o rse So me what W orse Ab o u t th e Same So m e what Be tter M u c h Be tt er

13% 20% 51% 11% 4%

14%

15% 50% 9% 4% Fi gu re 23 : Public Perception of Local Air Qualtiy Res po nd ents Overall, 2010 and 2014 (n=1,000)

2 0 1 4

2 0 1 0P age 18 A w areness and Pe rcep t ions of the Air Pollution Control District

In 20 10 and 2014

, respondents were asked whether they had heard of the San Joaquin Valley Air Pollution Control District. A total of 57 percent of residents this year reported that they had heard of the District, unchanged from 2010. (Awareness of the agency was highest among English-speakers and those with above median incomes.) Those residents familiar with the District were asked if they had a “very favorable,” “somewhat favorable,” “somewhat unfavorable

, ” or “very unfavorable” view of the agency’s performance. More than two-thirds (68 percent) of all residents familiar with the agency reported that they had a “very favorable” or “somewhat favorable” view of the District

, as seen in Figure 24.

*Figure based on Q29: “The San Joaquin Valley Air Pollution Control District is responsible for monitoring the outdoor air qu ality and implementing programs to reduce air pollution in your area. Would you say you have a very favorable, somewhat favorable, somewhat unfavorable, or very unfavorable view of the job they are doing?”

0% 5% 1 0 % 1 5 % 2 0 % 2 5 % 3 0 % 3 5 % 4 0 % 4 5 % 5 0 % Don ’ t kn o w/Refused Ve ry u nfa v orable So m e what u nfavorable So m e what f avorable Ve ry f av o rable

18% 7% 8% 46%

22% Fi gu re 24 : Perforamance Ratings, San Joaquin Valley Air Pollution Control District

A m on g Res po ndents Familar with the Agency (n=592)P age 19



## Con cl usions

Study findings suggest that past outreach efforts have helped raise public awareness about the District and its programs, but further outreach is still needed. The Check Before You Burn Program continues to be recognized by eight-out- of -ten residents, and those residents aware of the Program report that they have reduced their wood-burning in response to the outreach. In contrast, awareness of the Burn Cleaner and Clean Green Yard Machine Rebate Programs could be improved. Less than 20 percent of residents are aware of either the Burn Cleaner or Yard Machine Rebate Programs. Spanish-speakers, who are more likely to care for their own lawns compared to other residents, had
pa r t icul arly low awareness levels. In addition, findings suggest that more residents would consider carpooling to work if their employers offered a flexible schedule, financial incentives, free parking or other programs. These findings suggest that efforts to build more employer programs and outreach to increase awareness of the Distric t’s rebate programs may be helpful in promoting changes in personal behavior and improving air quality.P age 20 

## APPEN D IX A: SURVEY INSTRUMENT WITH WEIGHTED OVERALL FREQUENCIESP age 21 Valle y Air District Residential Wood Burning, Lawn Care, and Commuting Survey 2014 Overall Frequencies (n=1,000)
INT RO DUCT ION

M y nam e i s __________. We are conducting a survey with people in the area about issues affecting your community, and I want to include your opinions. We are not trying to sell you anything.
01 willing to continue
02 refusal
03 call back <at specific time>
04 call back <no specific time> 05 no answer 06 busy
07 answering machine
08 disconnected number
09 language barrier (not Spanish or English)
10 business number
11 fax machine

SCREENER QUESTIONS

La nd l ine
1. Ma y I s pe ak with the [youngest/oldest] adult at home who is 18 years or older? 1 Yes, I am that person (continue interview) 2 Yes, transferring to the person (restart intro) 3 Not available now (If person who answered is an adult, continue interview. If person who answered is under 18 arrange a call-back)
9 Refused (terminate)

Cel l P hon e

1a. S i nce you are on a cell phone, I can call you back if you are driving or doing anything else that requires your full attention. Can you talk safely and privately now, or not? 1 Yes 2 Not right now (try and arrange a time to call-back) 9 Refused (terminate)

1b. Are you 18 years or older? (n=1,000) 1 Yes 100% 2 No (terminate)

A l l Resp on d ents

1c

. W hat c ou nty do you live in? (Don’t Read) (n=1,000)
01 Fresno 23%
02 Kern 21%
03 Kings 4%
04 Madera 4%
05 Merced 6%
06 San Joaquin 18%
07 Stanislaus 13%
08 Tulare 11%
09 Other, outside of San Joaquin Valley area (terminate)
99 Don’t know/refused (terminate)

1d. What is your zip code? [Record 5 digit zip code. Zip code list to be provided. Refused = terminate]P age 22 1e. W hi ch of the following best describes the property where you live? (Read) (n=1,000) 1 House or duplex 100% 2 Apartment (terminate) 3 Condominium (terminate) 4 Townhouse (terminate) 5 Other (terminate)
9 Don’t know/Refused (terminate)

1f. Do you own or rent your home? (n=1,000) 1 Own 59% 2 Rent 39% 9 Refused 2%

W O O D COMB US TION: BEHAVIOR AND AWARENESS

2. I’ d l ik e t o ask you about the heating devices you may have in your home. Do you have a wood-burning fireplace, wood stove, or pellet stove in your home? 5 ( c hec k all that apply) (n=1,000)
1 Y es , w o od-burning fireplace 25%
2 Yes, wood stove 4%
3 Yes, pellet stove 3%
4 No (skip to Q4) 68%
9 Don’t know/Refused (skip to Q4) 0%

3. Is your sole source of heat from a wood-burning device? (n=330) 1 Yes 19% 2 No 81% 9 Refused

4. (Only ask if Q2 = 4 or 9) Does your public utility provide a natural gas connection to your home? (Skip to Q10) (n=670) 1 Yes 85% 2 No 10% 9 Don’t know/refused 4%

5. Ho w often do you use your fireplace/stove in the winter? Nearly every day, several days a week, once a week, less than once a week, or not at all? 6 ( n=3 30)
1 Nearl y ev er yday 8%
2 Several days a week 7%
3 Once a week 8%
4 Less than once a week 17%
5 Not at all (skip to Q10) 59%
9 Don’t Know/Refused (Do not read) (Skip to Q10)

6. Once started, how many hours does your fire usually burn? [record number, 2 digits; 99 don’t know/refused] (n=133) Mean= 6, Median= 4 hours. Excludes respondents who reported burning zero times. 1-2 hours = 24% 3-4 hours = 42 % 5-6 hours = 15% 7-13 hours = 7 % 24 hours a day = 10%

5 I dentical to QH on 2010 survey.

6 Sim ilar to QI on 2010 survey.P age 23 7. Whi c h of the following types of fuel do you typically burn? (Read. Check all that apply. Rotate. Yes/No punch. 9= Don’t know/refused) (n=133) 1 Seasoned firewood that has been split and dried for a year or more 71% 2 Partially dried wood that has some moisture 22%
3 Pellets 13% 4 Manufactured logs, such as Duraflame 32% 5 Trash, magazines, newspapers or other household materials 11 % 6 Other (specify) 1%

8. Check Before You Burn

runs from November through February each year, and prohibits wood burning in fireplaces, wood or pellet stoves, and outdoor fire pits during certain days when it is determined that air quality levels will be most impacted. Have you ever heard of the Check Before You Burn program? (n=133)
1 Yes 80%
2 No 18% 3 Maybe 2%
9 Don’t know 1%

9. (Only ask if Q8 was 1 & 3) Have you reduced the amount of wood burning you do in response to the Check Before You Burn Program? (n=110)

1 Yes 78%

2 No 16%

3 Maybe 5%

4 Don’t Know 1%

10. To encourage cleaner burning in the Valley, there is a grant program that offers rebates to residents who replace their traditional fireplace or stove with a cleaner-burning device such as a certified wood stove or a gas fireplace. Are you aware of this grant program, it is called Burn Cleaner ? (n=1,000)

1 Yes 17%
2 No 82% 9 Not Sure/Refused 1%

11. (ASK only if Q2= 1, 2, 3 otherwise skip to Q13) Would you be willing to replace your current woodburning fireplace or stove with a cleaner, less-polluting wood-burning device if you could use it on some
No -Burn days? (n=330)

1 Yes 29%
2 No 58%
3 I already have a clean- burning device (don’t read) ( skip to Q13 ) 5% 9 Don’t know/Refused (don’t read) 8%

12. Assuming a clean wood-burning device costs about $3,000, would you upgrade from your current fireplace or stove if you could get a 15% rebate on your purchase? (n=314) 1 Yes ( Skip to Q13 ) 12%
2 No 67% 3 I would purchase it without a rebate/incentive (do not read) ( Skip to Q13 ) 1% 4 Not interested/no discount would be enough (do not read) ( Skip to Q13 ) 14% 9 Don’t know 6%P age 24 12a. Ho w about a 25% rebate? (n=276) 1 Yes ( Skip to Q13 ) 3%
2 No 73% 3 I would purchase it without a rebate/incentive (do not read) ( Skip to Q13 ) <1% 4 Not interested/no discount would be enough (do not read) ( Skip to Q13 ) 2% 9 Don’t know 6%

12b. How about a 50% rebate? (n=222) 1 Yes 16%
2 No 71% 3 I would purchase it without a rebate/incentive (do not read) 0% 4 Not interested/no discount would be enough (do not read) 2% 9 Don’t know 9%

13. Do you believe wood smoke is a significant source of air pollution in your neighborhood? (n=1,000) 1 Yes, definitely 35% 2 Yes, probably 20% 3 No 41% 9 Don’t know/Refused 5%

CO MM UT ING B E HAVIOR AND AWARENESS

14. Ho w d o y ou usually get to work? (Do not read.) (n=1,000)

1 Drive alone 50%

2 Drive in carpool or vanpool 12%

3 Use public transportation 2%

4 Walk or bike 3%

5 Work at home one or more days a week 2%

6 Don’t work outside the home 30%

9 Don’t know/refused 1%

15. (Ask only if Q14=1) Please answer yes, no, or maybe to each of the following questions: I would carpool if ... (9=don’t know) (n=452)
1 My employer provided a financial incentive. 49%

2 I could get assistance with finding a carpool partner in my neighborhood. 45%

3 My employer provided onsite food service and/or lunch. 40%

4 My employer provided a more flexible work schedule. 51%

5 My employee provided free designated carpool parking. 43%

16. Do you have school-age children who live with you? (n=1,000)
1 Yes 42% 2 No (Skip to Q20) 58% 9 Don’t know/Refused (Skip to Q20) 0%

16a. How do your children usually get to school? ( Do Not Read ) (n=381) 1 Do they take the school bus? 21% 2 Do you or someone else in your household drive them? 46% 3 Do they drive themselves? 4% 4 Do they take public transportation? 2% 5 Do they walk or bike? 24% 6 Do they carpool with other students? 1% 7 My children are home schooled (Do not read) 1%
9 Don’t Know/Refused (Do not read) 0%P age 25 17. (A s k only if Q16a = 1, 2, 3, 4, 6. Others skip to Q19) What is the main reason you would not let your child
walk to school either alone or with an adult? (n=281)

1 Too far 44%

2 Concerned about safety 43%

3 No sidewalk in my neighborhood 2%

4 Not enough time in the schedule 7%

9 Refused to answer 3%
18. ( A sk on ly if Q16a = 6. Others skip to Q19) Which of the following best describes the main reason you
de c i ded t o use a carpool to get your children to school? (Check one. Rotate first three stems.) (n=6) Due

to th e extr em ely small sample of respondents who responded to this question, results could not be analyzed statistically.

1 It i s con v enient or it worked with our schedule mentioned

2 To save money on gas mentioned

3 To help reduce air pollution mentioned

4 Other specify (Do not read) 0%
9 Don’t know/Refused (Do not read) 0%

19. Do you consider idling cars at school drop-off and pick-up lines to be a significant source of air pollution
that can affect children’s health? (n=381)
1 Yes 69%
2 No 25%
9 Don’t know/Refused 7%

L A W N CARE : B EHAVIOR AND AWARENESS
20. W h o us ua lly maintains your lawn, shrubs, trees or garden areas? 7 ( Do n ot r e ad) (n=1,000)
1 I o r ot h ers living in the household do all the yard work 61% 2 I or others in the household do some of the yard work and a lawn service does the rest 3% 3 A lawn service does all the yard work (skip to Q23) 25%
4 Don’t have a lawn/ Don’t care for it (skip to Q26) 8% 9 Don’t know/Refused (skip to Q26) 2%

21. Do y ou us e any gas-powered lawn or garden equipment at your residence? 8 ( n= 63 9)
1 Y es 73 % 2 No (skip to prompt above Q26) 25% 9 Don’t Know/Refused (skip to prompt above Q26) 2%

22. Cons i derin g o nly gas-powered lawn and garden equipment, which of the following do you use? 9 ( y es/no

pu nch. 99 = don’t know) (n=459)

01 W al k- be hind Lawn Mowers 84%

02 String Trimmers 38%

03 Chain Saws 25%

04 Leaf Blowers 35%

05 Lawn Edgers 39%

06 Brushcutters/Hedgecutters 18%

07 Riding Lawn Mowers 10%

08 Tillers 8%

09 Lawn & Garden Tractors 4%

10 Wood Splitters 4%

11 Shredders 3%

7 Id entical w ording to Q70 from the ARB survey.

8 Si milar w ording to Q80 from the ARB survey.

9 Id entical lis t to Q89 from the ARB survey.P age 26 12 Sno w B lowers 2%

13 Stump Grinders/Chippers 2%

( O nl y as k Q23 through Q26 if Q20 = 2 or 3. Otherwise skip to Q26)

23. Dur i ng t h e summer, how many times a month does the lawn service come? [record number 2 digits] [99= Don’t know/Refused] (n=291) Mean 4, Median 4 Once a month 6% Twice a month 22% Three times a month 4% Four times a month 54% More than once a week 9% Don’t know 5%

24. Does the lawn service come as often during the winter? [record number 3 digits] [99= Don’t know/Refused] (n=291)
1 Yes 46% 2 No 51% 9 Don’t know/Refused 3%

25. Would you consider switching to lawn care service that used cleaner equipment if it cost: (n=291)

1 Less than your current service 25%

2 The same as your current service 16%

3 More than your current service 2%

4 Would not consider (do not read) 41%

9 Don’t know/refused 15%

26. Are you aware of a grant program which offers a rebate incentive for electric lawn mowers? The program is called the Clean Green Yard Machines Rebate Program? (n=1,000)
1 Yes 15%
2 No 84%
9 Don’t know/Refused 1%

G ENE RA L BELIEFS AND AWARENESS

27. Compa red to three years ago, would you say the air quality in your area has gotten better, gotten worse, or stayed the same? 10 ( If bette r /worse: Is that much better/worse or somewhat better/worse?) (n=1,000)
1 Mu ch B etter 4% 2 Somewhat Better 9% 3 About the Same 50% 4 Somewhat Worse 15% 5 Much Worse 14% 6 I haven’t lived here long enough to say (Don’t read) 3% 9 Don’t know/Refused (Don’t read) 4%

28. Have yo u heard of the San Joaquin Valley Air Pollution Control District? 11 ( n=1 ,000)
1 Y es 57 % 2 No ( skip to Q30 ) 40% 9 Not sure/Refused ( skip to Q30 ) 2%

10 Si milar w ording to Q5 from 2010 survey. The time interval has been changed from 5 to 3 years.

11 Sim ilar w ording to Q11 from 2010 survey. “Maybe” has been excluded from the options.P age 27 29. The S an Joaquin Valley Air Pollution Control District is responsible for monitoring the outdoor air quality and implementing programs to reduce air pollution in your area. Would you say you have a very favorable, somewhat favorable, somewhat unfavorable, or very unfavorable view of the job they are doing? (n=592) 1 Very favorable 22% 2 Somewhat favorable 46% 3 Somewhat unfavorable 8% 4 Very unfavorable 7% 9 Don’t know/refused 18%

DE MO G RA P HICS F i na ll y , I’d like to ask you a few general questions for research purposes. Your answers are confidential.

30. What year were you born? ______ ______ ______ ______ (n=1,000)
18

- 29 16% 30

- 49 36% 50

- 64 29% 65+ 14%

31. Would you please tell me what ethnic group you identify with? Are you Hispanic/Latino, Black/African American, Asian, Caucasian, or of some other ethnic or racial background? (n=1,000)

1 Hispanic/Latino 49%

2 Black/African American 5%

3 Asian-American 8%

4 White/Caucasian 35%

5 Other (specify) 1%

9 Refused (Don’t Read) 2%

32. How many people live in your household? ___________ (

33. [Asked of cell phones only] Do you have a landline telephone? (n=400)
1 Yes 45%
2 No 51%
9 Refused 5%

33. [Asked of landline phones only] Do you have a cell phone? (n=600)
1 Yes 77%
2 No 19%
9 Refused 4%

34. [Asked of everyone] Does your household primarily use cell phones or land line phones? (n=1,000)
1 Cell 60%
2 Landline 32%
9 Refused 8%P age 28 35. I am going to read some categories of household income. Please stop me when I reach the category of your total 2013 annual household income, before taxes: (n=1,000)

1 Less than $15,000 12% 2 $15,000 to less than $35,000 20% 3 $35,000 to less than $50,000 1 2% 4 $50,000 to less than $75,000 9% 5 $75,000 to less than $100,000 5% 6 $100,000 to less than $150,000 6% 7 $150,000 to less than $200,000 2% 8 More than $200,000 1% 9 Refused (DON’T READ) 34%

36. (GENDER BY OBSERVATION

-- DON’T READ) (n=1,000)
1 Male 50%
2 Female 50%

37. Note Language (n=1,000) (English 73% or Spanish 27%)

That concludes our survey. Thank you very much for your time.P age 29 

## APPEN D IX B : DEMOGRAPHIC PROFILE OF RESIDENTS SURVEYED COMPARED TO

POPULATION ESTIMATESP age 30 Table 1 : Demo g raphic Profile of Residents Surveyed Compared to Population Estimates

P o p ulatio n Ch ar a cteristic U.S . C ensu s P o p ulatio n ( A c ro ss 8 County

Regio n ) Un w eigh ted

S amp le W eigh t ed Samp l e

F r es no 23.4% 23.8% 23.1%

K ern 21.2% 18.7% 21.2%

K i n gs 3.7% 3.7% 3.8%

Ma de r a 3.8% 4.2% 3.7%

Me r c ed 6.5% 7.9% 6.5%

S an J oaq ui n 17.4% 17.7% 17.8%

S tan i sl a us 12.9% 9.6% 12.6%

T ul are 11.2% 14.4% 11.5%

Cel l on ly 32.6% 37.0% 31.6%

Ma l e 50.4% 44.8% 50.0%

F em al e 49.6% 55.2% 50.0%

W hi te 35.6% 40.4% 34.6%

B l ac k 5.5% 3.4% 5.3%

Hi s pa ni c 49.6% 42.7% 49.2%

A s i an 8.1% 4.7% 7.8%

A ge <6 5 85.3% 78.1% 85.3%

A ge 65+ 14.7% 21.9% 14.7%

# Commun ity Stak eholder

Int erviews

Final Report

February 2014

Submitted to: 

# San Joaquin Valley Air

Pollution Control District

insert logo

Submitted by:



## Gomez Researc h

Pasadena, California

## T A B LE O F C ONTENTS

EXECUTIVE SUMMARY

................................................................... 2

I. INTRODUCTION

............................................................... 5

II. METHODOLOGY

............................................................... 5

II . FINDINGS

.......................................................................... 5

Perception of Air Quality

............................................................. 5

Rating of Current Air Quality

Impact of Air Quality and Air Quality Regulations

Strategies for Improving Air Quality/ Reducing Emissions



### Awareness and Perceptions of District Programs

................... 11

Healthy Air Living

Check Before You Burn and Burn Cleaner Rebate Program



### Per ceptions of the District and Air Quality Policies

.................. 16

Balance Between Public Health and Economic Prosperity

Regulatory, Voluntary, and Incentive-Based Policies

Suggestions for Additional District Action



## APPENDICES:

Appendix A: Interview Guide

## EXEC U T IVE SU MMARY

The San Joaquin Valley Air Pollution Control District contracted with Gomez Research to conduct a series of one- on -one telephone interviews with community stakeholders in the San Joaquin Valley. The research was designed to complement a public opinion survey conducted with 1,000 San Joaquin Valley residents addressing similar questions regarding local air quality, programs implemented by the District, and perceptions of the District and air quality policies. A total of 40 interviews were conducted by telephone between December 9, 2013 and February 7, 2014. Participants were recruited randomly from a list provided by the District including Citizen Advisory Committee members, members of the District’s Environmental Justice Advisory Group (EJAG), Commercial Lawn and Garden representatives, Drive Clean Program representatives, the San Joaquin Valley Air Pollution Control District Governing Board members, and other District Stakeholders. Study results were qualitative in nature and do not represent a statistical sample.

K ey fi nd ings from the study are presented below.

a. Using a 5-point scale where five is “excellent” and one is “poor,” respondents gave local air quality an average rating of 3, suggesting that stakeholders believe the air quality is fair but could be improved. When asked if the air quality had improved over the last five years, 28 out of the 40 individuals interviewed reported that they believe the air quality has “gotten bette r, ” followed by eight who believe the air quality has stayed the same and three who believe the air quality has worsened (one individual declined to answer the question). Several respondents cited the particularly poor air experienced this year due, in part, to severe drought conditions.

b. When asked how poor air quality and/or air regulations have impacted their constituents and communities

, the majority of stakeholders more frequently cited economic impacts rather than health concerns. In addition, when discussing the health impacts of air pollution, respondents tended to focus on daily, short-term problems such as asthma and curtailed outdoor exercise, rather than more severe conditions such as cancer.

c. When discussing how to reduce emissions, stakeholders most frequently cited the need to reduce diesel truck emissions, followed by suggestions for encouraging carpooling, biking, public transportation and other alternatives to single- occupant vehicles.

d. The majority of stakeholders were familiar with the Healthy Air Living Program (31 out of 40 ), although a minority of respondents were unclear about the details of the program.

e. When asked if they had a favorable or unfavorable view of the Healthy Air Living Program, nearly all respondents reported that they had a “very favorable” or “somewhat favorable” view of the Program

. When asked why they gave a favorable rating, respondents most frequently reported that they believe the Program has been helpful in educating the public about air pollution and providing specific, cumulative actions that residents can take to improve the air quality. The most frequently cited reason for lower ratings was the belief that the program does not tackle the biggest causes of air pollution, notably diesel truck emissions.

f. All stakeholders who participated in the study, with the exception of one individual, had heard of the Check Before You Burn Program.g. T he most f requently cited suggestions for increasing participation in the Burn Cleaner Program were increasing incentives to make the Program more affordable, followed by additional outreach to ensure that residents are aware of the program. Some respondents suggested that the District continue to work closely with businesses that sell hearth and heating equipment.

h. Overall, findings suggest that the majority of respondents believe the District i s doing a good job balancing public health and economic interests even though some stakeholders believe more or less regulation is needed. Although many respondents expressed concern that the District does not do enough to protect business interests, the majorit y of stakeholders described the District’s policies as reasonable given California requirements and local economic considerations. Commercial stakeholders were more concerned about compliance requirements imposed on businesses than were citizen advisory committee members and other District stakeholders.

i. The most frequently cited areas for additional District action were school-site idling and drive-through services followed by gas-powered lawn care equipment.
j. When asked what type of policies they would recommend to address these areas

, respondents most often suggested incentive-based programs over regulatory and volunteer approaches.

k. When asked if they had any other suggestions, many stakeholders recommend that the District increase its interaction with constituents, including face- to -face opportunities to explain programs, gather feedback, and increase visibility . Other suggests included multi-lingual materials and an increased budget for public outreach.

## I N T ROD U CTION

In 2014, as part of a larger effort to continue to improve local air quality, the San Joaquin Valley Air Pollution Control District contracted with Gomez Research to conduct a series of one- on

- one telephone interviews with community stakeholders in the San Joaquin Valley. The research was designed to complement a public opinion survey conducted with 1,000 San Joaquin Valley residents addressing similar questions regarding local air quality, programs implemented by the District, and perceptions of the District and air quality policies.



## METHODOLOGY

A total of 40 interviews were conducted by telephone between December 9, 2013 and February
12 , 2014. Each interview lasted approximately 15 to 20 minutes. Participants were recruited randomly from a list provided by the District including Citizen Advisory Committee members

, members of the District’s Environmental Justice Advisory Group (EJAG), Commercial Lawn and Garden representatives, Drive Clean Program representatives, and San Joaquin Valley Air Pollution Control District Governing Board members, and other District Stakeholders.

Of the 40 stakeholders interviewed:

 16 were Citizen Advisory Committee and/or EJAG members

 9 were District Board members

 7 were commercial lawn and garden representativ es

 6 were other District stakeholders

 2 were from the Drive Clean Program



## Caveats

Due in part the small sample size, the study was qualitative in nature and cannot be analyzed statistically. Results reflect the opinions of the individuals included in the study and cannot be extrapolated to the population as a whole.



## FINDINGS

Perception of Air Quality

R ating o f C urrent Air Quality

O ne obj ec ti ve of the research was to gauge stakeholders’ perception of the air quality in the San Joaquin Valley basin compared to five years ago. Using a 5-point scale, where five is “ excellent ”
and one is “ poor
, ” stakeholders were asked how they would rate air quality in the San Joaquin Valley overall. Respondents gave the local air quality an average rating of 3, suggesting that they believe the air quality is fair but could be improved. When asked if the air quality had improved over the last five years, 28 out of the 40 individuals interviewed reported that they believe the air quality has “gotten better

, ” followed by eight who believe the air quality has stayed the same and three who believe the air quality has worsened

. (One individual declined to answer the question.) Several respondents cited the particularly poor air experienced this year
due to drought conditions.I m pa ct of Air Quality and Air Quality Regulations

R esp on dents w ere asked to describe how the air quality and the air quality regulations in the area have impacted their customers, employees, constituents, or family members. When asked how they have been impacted by poor air quality and air regulations, respondents most frequently mentioned health-related problems such as asthma and cost-related impacts on businesses trying to purchase cleaner equipment

. Stakeholders generally expressed more concern regarding the economic impacts of poor air quality and air regulations than on the health impacts of air pollutio n. Moreover, when discussing the health impacts of air pollution, respondents tended to focus on daily, short-term problems such as asthma and curtailed outdoor exercise, rather than more serious, long-term conditions such as cancer.

Results from the open-ended responses are presented below, grouped by comments regarding health impacts of air pollution followed by comments regarding policy and regulations.

Q: C ou l d you d escrib e how the air quality and/or air quality regulations i n t his area have i m pa cted your [customers, employees, constituents, members, family], if at all?

Comments Regarding Health Impacts:

 Well, it impacts different people differently. Obviously, if you are in a sensitive group, the air quality is going to be a part of your everyday life. Your daily life is dictated by what you can or cannot do.

 I think the regulations that we are trying to develop to clean our air ha ve actually improved the quality of life of people that I know.

 My customers are students so they are affected by not being able to go outside and play or participate in sports.

 I don’t know anybody with health issues related to the air quality. We haven’t had any employees with asthma, miss work or anything like that, that I’m aware of.

 In terms of air quality itself, I have known people who have physically moved from the area due to their children’s health issues, like asthma.

 There is a lot more asthma, really serious cases that are made worse by the pollution.

 Mostly, I hear about health-related issues, things like asthma and allergies that are being contributed to by air pollution, but I don’t know anyone who has go tt en cancer or lung disease because of air pollution.

 I think the air quality has gotten better in the last few years. Obviously relating air quality to health impacts is important...there is a direct corre lation between the air and the health of my constituents. The only thing I hear is that we under-regulate air pollution sources.

 I think the poor air quality prohibits old people from going out because they can’t breathe when they are out there. I think the awareness about the Valley air quality is so much greater than it has ever been.

 It’s a drain on our economy because we pay for all the hospital visits for asthma. Kids are missing days of school because of asthma and other health-related issu es. It’s really a drain on our society and economy.

 I think the biggest problem is allergies. I have it myself.Com m en ts Reg ardi ng Business Impacts:

 The air quality doesn’t seem to be a big issue

, but the regulations have been detrimental to em pl oyee s ... it’s more expensive to do business here.

 The air quality problem has not been addressed. Our employees do not want to move families to this region. People are not moving into the District.

 Air quality has had little impact on me personally and the people I know. I know people who have trucking operations and they are going to be severely impacted by the new laws if they can’t get financing for new vehicles.

 [The reg ulations

] have been very detrimental businesswise. Unfortunately the [Air District] only has the authority to try to reduce emissions from stationary sources. They don’t have the ability to go after automobiles, which I’m pretty sure is one of the biggest problems. Going after the stationary sources has been very detrimental to businesses throughout the Central Valley and I also think it has been unfair. It chases business away. If I could take my business and move it to another state, I would do it in a heartbeat. I can’t because I grow trees here and they won’t grow in another state.

 Rule 4570 [Confined Animal Facilities] was by far the most expensive rule that has been put on ...and it

absolutely affects our community. We are the only state in the world that I know of that is under such expensive regulatory requirements.

 We have been really fortunate at the School District. We’ve been able to replace five of our older units and have been able to update five other ones. A lot of smaller organizations and business es

have not been able to make it because of financial costs...That’s what I hear from people, especially in the trucking industry and construction, that the laws that are coming are hitting them pretty hard economically.

 It’s harmed the business side enormously and has kept bus inesses away from the San Joaquin Valley. It has increased the cost and it’s basically created a barrier of entry.

 The EPA put a 29 million dollar fine on us. It was outrageous. Financially it cost every driver in the valley.

 Regulations have affected [air quality]. I don’t think it has direct connections to my own family or friends that I can think of. But I can say in general the way regulations have affected people is that in some cases it has meant loss of employment. I know of businesses that have closed their doors. I can’t say it’s the price of regulatory compliance, but it would certainly be a contributing factor.

 Given that I work for a manufacturer, the air regulations impact us dramatically, both in terms of cost and operational complexity. Cost has gone up dramatically since 2007, a few hundred thousand in

additional fees.

 A lot of requirements have been imposed on industry, which makes life difficult on businesses. Residents in the Valley have to abide by regulations that more fortunate areas do not have to abide by. It’s not the fault of the Air District , it’s where we live in that traps ozone and pollution.

 Obviously, the agriculture industry has been tremendously affected through this and AG has been a willing partner towards cleaning up the air. Trying to help reach those standards has been costly for agriculture.

 Regulatory impacts have put a financial burden on stationary sources.

 Air quality has not been an issue with the people I work with or my family. Other than comments from time to time, we are definitely a winner with the lack of rain and where we live. I wish the air was a little cleaner. You can see the smog just hanging down. There has not been a lot of conversation. T he r e hav e b een times when the rules did not make sense and the people administering those rules were not even following their own rule book. That has given very poor feelings or thoughts about the [California] Air Quality Resources Board. They truly believe they are autonomous and are not held accountable.

 The thing that most people complain about is that it has cost too much to clean the air. Smog and diesel trucks have to be replaced, all we can do is suggest it, set a rule and enforce what we can. It’s like a cop, you can’t have a cop out there in the street for every person to stop the violating.

 Air regulations have cost me a lot of money. I’m in the oil business and of course it has impacted our business. These regulations, you don’t put them on for free.

 I’m up in the mountains. It [poor air quality] doesn’t impact us as much. They’ve reduced the cost of controlled burns, and that helps. The controlled burns have helped prevent catastrophic fires.

 [The air quality and regulations] have impacted everyone in the community. When we fall out of compliance with EPA regulations, the EPA requires a penalty to be assessed over the citizens of the air District and the last time around what basically happened was the penalty came around to approximately 41 million dollars, of which 29 million went directly against tax payers, the citizens, the population of the area and that was done through an additional fee. And it hurts the environmental justice areas, people who cannot afford an additional fee.

 Well, I think that it’s probably definitely hampered business and some expansion plans, but a lot of it has probably been necessary. I would say much of it has been necessary and the reason for any improvement we have seen, it’s definitely had a negat ive impact on the economy even though we have had a fairly decent economy in the valley.

 [The District] really has the most stringent boiler rules. When that was passed 5 or 7 years ago... they said it was going to cost $25 million dollars. They really have strict source rules, even more stringent that South Coast in some instances. Stationary sources have put in a lot of money. The state is putting millions of dollars into passenger vehicles, which is good, but that doesn’t impact emissions in the San Joaquin Valley.

 The company I work for sells outdoor power equipment and one of those is chain saws. People that I know cut wood to burn for heat. One impact [of regulations] is that people are not burning as much wood as they did years ago.

S t r ateg i es for Improving Air Quality/Reducing Emissions

R esp on dents w ere asked what could be done to improve the local air quality and reduce emissions. Open-ended responses are presented below. When discussing how to reduce emissions, stakeholders most frequently cited the need to reduce diesel truck emissions, followed by suggestions for encouraging carpooling, biking, public transportation and other alternatives to single-occupant vehicles.

Q : Looki ng forward, what can be done in the Valley to reduce emissions further?

Comments Regarding Diesel Trucks:

 Trucks come to our valley from outside and, except for state and federal regulations, we have no say over their emissions and they are the biggest polluters.

 All the companies are doing their part. Mobile trucks seem to be the biggest problem

.

 They need to tackle the heavy duty trucks. The stationary sources is what [the District] is able to regulate, so they have squeezed them very hard but [the District] doesn’tne c es saril y have the authority to regulate mobile sources like trucks. Vehicles are now 80 percent of the emissions inventory, particularly heavy-duty, diesel trucks. The state sets the standards for engines and the most recent one was in 2010 but there are engines that are much cleaner than those standards. They aren’t diesel, they are natural gas or maybe natural gas hybrids. There is a lot of technology out there, but [the trucking industry] need to be incentivized to get the cleaner engines. We have local money as well as state money to provide that. People have replaced older diesel trucks with cleaner diesel trucks but it’s still no t enough.

 Dealing with diesel needs to be corrected and we need to reorient the community away from automobiles, engage in activities like mass transit, walking, and biking.

 Do something with the traffic on the I-5 and 99

 The biggest problem we have are all the trucks on the road.

 I think it has to do with mobile source, I do have some first-hand information about what causes pollution and I have been involved with air issues for a long time. Mobile sources ha ve to be controlled and tamed. The exhaust system for bigger trucks has to get better.

 Well, some of it will be technology driven, but some of it is just a turnover of automobiles

, but the big thing is the turnover of truck fleets.

 We obviously need to deal with mobile sources, reducing the vehicle miles traveled, we need to stop diesel trucks, especially the origin and destination in here. We have lots of truck traffic, diesel that is just travelling through the Valley . It’s almost criminal when you think of the asthma rates. We definitely need to manage interstate and intrastate transportation.

 There has to be a focus and an emphasis on mobile sources of pollution, such as diesel trucks.

 Right now 85% of our emissions would be from diesel trucks. We have 15,000 diesel trucks that are owned by small, either single unit operators or small companies. They were not included originally in any of the incentive programs until October 21st of last year, and literally there was only a month to let them know to get in line in for incentive funds. I would say the number one thing to clean up the air in the Valley would be put high-speed rail on hold and take those funds and take them from providing more surface water storage an d use it to replace the semi-trucks on the road wit h new trucks that are much more energy efficient.

Comments Regarding Local Vehicle Traffic and Alternative Modes of Transportation:

 Our whole land use in the Valley is pretty much sprawl, and in Fresno they are trying to adopt a plan that is more walking, biking and transit. Compact development is smarter and more sustainable. That would help air quality.

 I think a lot of things can be done. The biggest concern is automobile and truck traffic. The NOx emissions should be reduced when the new law is implemented in January, but internal combustion engines will still be a concern. The trend toward electric and hybrid vehicles will reduce emissions in the long run, but we will need more charging stations.

 Well we need the public to participate even more than they are and they need to realize that their contribution makes a difference. Really it’s through education. We need more education, more money dedicated to the different groups... we really don’t spend enough money to get the message out to as many groups as we can on a big scale.

 Get people to park their cars and ride mass transit. I think the cars are the problem; we need to limit automobile travel. We c an not c on tinue to put the burden of living in the Central Valley on the backs of business. We all need to be smarter on how we travel.

 I think somehow we need to get more ways to move people from point A to point B without using automobiles. And we need to get the older automobiles off the road and incentivize people to buy new, cleaner vehicles. I think with the tune-up program that we have, we are taking a lot of those vehicles off the road by getting repaired, but we need to somehow get some kind of transportation going in the Central Valley, like ridesharing off the 99 corridor, like commuting from Fresno to Madera, Madera to Fresno, and Mader a to Merced that there is more ride sharing. We can find funding to do that.

 I think a lot of it has to do with mobile sources, a.k.a

. cars. I think a lot of it is getting older

c ars of f the r oa d. Just when you look at the emission factors, these new late models versus cars from more than 10 years ago, the differences are tremendous.

 [The District] really ha s to sit down and have meetings with people to really brainstorm ideas.

 More rapid transit or public transportation. More incentives for electric vehicles or low emission vehicles.

 Automobile and truck traffic seem to be contributing major sources of pollution in the Valley that the District has little control over. I would hate to mandate the elimination of vehicle travel, but you could say it’s the law that everyone would have to walk or ride a bike, but that wouldn’t do enough for the regional economy, so I think the District is kind of in a hard spot.

 The citizens out there have to do the cleaning up. It seems that everyone wants to blame the Air Board , they don’t want to blame themselves for it and they are the ones creatin g the pollution.

 Automobiles are 90-95% [of the problem]. I think the biggest culprit is automobiles and what can you say about that, that’s the state of California. We can only focus here on mobile sources.

Comments Regarding Agriculture:

 I think having more programs to help replace older equipment has helped make a difference, such as programs to help purchase [low-emissions] trucks and tractors.

 Probably working with agriculture on the almond harvest and almond harvestin g techniques. Almond harvest has increased over the years and the Air District is not addressing the almond harvest at all. The technology is there, it just has not been deployed by the agriculture industry and so the Air District should be working with th em and as opposed to regulating them they should be using their war chest to invest in their technology held during the almond harvest.

 Improve the rules and regulations on everything that includes agriculture and berry industries. In addition to incentive programs for limiting development that increases vehicle trips.

Additional Comments (No Burn Days/Gas-Powered Lawn Equipment):

 Order rain more often [joke]. I don’t think there is much more they can do. The only area that I think has room to grow is consumer gas products like lawn mowers and blowers. I would say it is in the consumer market that needs room for improvement.

 I believe we should ban leaf blowers. And ban fireplaces. Just flat ban them.

 [To further reduce emissions] we should look toward tightening the rules on burning

-- including in the foothill areas

— which have been exempt in the past. F i x the B ay Area. They are not held to the same standards. They are lax in their required emissions. It’s all directed at the Val ley where we import their air. Their air is invading us.

 Do more of the same. Encourage people not to use their wood-burning stoves for those key time periods.



## Awareness and Perceptions of District Programs

H ea l thy Air Living Program

I n addi t ion to gathering feedback on general issues related to air quality and air regulation policies, the study asked respondents about their awareness and perceptions of the Healthy Air Living Program, designed to improve air quality on a daily basis. The majority of respondents participating in the study were familiar with the Healthy Air Living Program (31 out of 40 ), although a minority of respondents were unclear about the details of the program.

Next, respondents were asked if they had a favorable or unfavorable opinion of the program. Nearly all stakeholders surveyed (3 5 out of 40 ) had a “ very favorable ” or “ somewhat favorable ” view of the program. Results are presented in Table 1 , below.

Table 1: Perceptions of the Healthy Air Living Program.

S ca l e S co re V ery Fav orabl e 2 3 r esp on den t s S omew ha t Fa vorable 12 r esp on den t s S omew ha t U nfavorable N o r esp onde n ts V ery Unf av orable 2 r esp on den t s N ot S ure/ R efused 3 r espon den t s

R esp on dents w ere asked to explain the reasons behind their ratings. Open-ended responses, organized by positive and negative comments, are presented below. When asked why they had a favorable view of the Program, respondents most frequently reported that they believe the Program has been helpful in educating the public about air pollution and providing specific, cumulative actions that residents can take to improve the air quality

. The most frequently cited reason for lower ratings was the belief that the program does not tackle the biggest causes of air pollution, notably diesel truck emissions. A minority of respondents reported that the District should increase its efforts to educate the public.

Q : Why did you give that rating of the program?

Reasons for High Rating of the Healthy Air Living Program:

 I think they are doing a lot of things that will really have an impact [on air quality]. They’ve gotten kids involved in the lower grades [through Health Air Living]. They are making sure the younger generation is acutely aware of what’s going on.

 Anything that could help educate consumers on how they can reduce their sources of pollution is a good idea.

 [The Program] gives people specific things that they can do to improve. First of all it helps them understand why air quality is bad, and once you understand why it is bad then you know what you can do, you’re in a role to improve it. It gives very specific tools and techniques and tells people exactly what they can do to help. W el l I th i nk that everybody should do their part, and getting the word out through your program is going to help. A lot of people do not know about those things.

 Good to know what’s going on. It’s a reminder that the air quality is not as good as it possibly could be. There have been days where I walk instead of driving my car or ride my bike.

 People are now realizing we have to do something and its being talked about on radio, television and newspapers. People are taking an interest.

 The District is trying to encourage education and reasonable action without hardcore regulations.

 It’s helping us do what we are supposed to be doing. Making the rules and trying to get the air clean and trying to get the people to work with us.

 I think it is going in the right direction, but they can do more. Like, instead of asking people to make one change they should ask people to make huge changes.

 Well because of the mass advertising and commercials that they do. Promoting during the different seasons during the year —“make on e change, ” “thank you for not burning your wood stove, ” I think the mass communication and advertising that they have on the radio, TV, and on the billboards

— I believe it has had an impact on people wanting to make that one change and do what is good for the environment. It has brought more awareness to the District.

 I think education is very important and it [puts] the burden on the Valley residents to take charge and make change first hand and to do something about air quality. I think that would be the ultimate solution when everyone gets involved with the Valley

.

 It empowers people to make their own decision based on the information given by the District.

 I think it’s a very effective tool for the District to communicate to the right stakeholder. It’s the right mechanism to get the information out there for people to take aggressive actions when necessary.

 I think it’s important to educate the public and encourage them to do things that impact air quality as individuals. I think it’s OK to share the burden of air quality with the community. I think [the program] has done a lot to bring air quality to the ground level.

 Because anything that gets public participation and awareness, and helps to get people aware of what’s going on, on a day- to -day basis, with air quality will help to really lessen the effects of bad days, because people know, for example people should know when to stay indoors when the air is bad. We want people to be aware of our air situation which is only going to get worse when population increases.

 Because no matter how bad the situation is, turning a blind eye to it and saying there is nothing we can do doesn’t help . We still have to do something every day so that it makes it better.

 Because they are getting the word out to people to do something about their fireplaces, take fewer trips and they are getting the word out for people to respond to it.

Reasons for Lower Ratings of the Healthy Air Living Program:

 The message of the current campaign is “ Do One Thing. ” The normal people who live in the San Joaquin Valley don’t know much about air pollution and there are other things that we can all do to reduce it. That’s absolutely important but it’s going to have to go beyond “one thing.” You have to start somewhere but they need to move beyond that initial message. They try and get business partners and maybe they could do more to get those partners. You can always use more outreach to businesses. For example, apa c k ing plant...they have hundreds of workers and they can set up carpool programs. Maybe they should have some brainstorming sessions or focus groups and invite people to discuss additional strategies.

 Not many businesses are promoting the program.

 Well I think it’s a good program to try to encourage residents to do what they can, but [there are] limitations for what residents can do. So many programs are outside of their control. [There are] very few exceptions, like burning wood fires and how they use air blowers, how long they idle their cars. There are a few things like that [that] each of us can do to help, even if we all did everything we could as individuals. The problems go way beyond that. There are no silver bullets to solve that problem, but if you only had one silver bullet, use it on diesel trucks.

 I think they are trying to do good things, their programs and communications are good. I would like to see more policing, for example, on the “No Light Tonight Program.” I have a neighbor that religiously burns on no -burn days, but he waits till after dark so there is no way he is going to get caught. I don’t agree with that, I think it’s terrible. So things I would want to see in conjunction with that is more enforcing.

 [The Healthy Air Living Program] is a good start. But we are agriculturally based and travel is almost necessary for jobs. By penalizing people [for emissions] you are really penalizing the poor, working class [residents] because they have to live in cheap areas and their jobs may be in areas where they can get work. So, you have to look at the broader picture.

 More education, more and better outreach.

 It’s useless, voluntary measures get no scores— boy cott is infective and requires incentives.

 I think that it’s politically motivated. I think its fluff and not addressing the real issues.



### Che ck B e fore Y o u Burn/Burn Cleaner Program

I n addi t ion to gauging awareness and perceptions of the Healthy Air Living Program,
resp ondents were asked if they had heard of the Air District’s Check Before You Burn Program. All stakeholders who participated in the study, with the exception of one individual, had heard of Check Before You Burn. Next, respondents were asked how the District might encourage more people to take advantage of its incentive and rebate programs to purchase cleaner devices. Open-ended results are presented below. The most frequently cited suggestions for increasing participation in the Burn Cleaner Program were increasing incentives to make the program more affordable, followed by additional outreach to ensure that residents are aware of the program. Some respondents also suggested that the District continue to work closely with businesses that sell hearth and heating equipment.

Q : H ow can the District encourage more people to take advantage of its i nc en t ive and r ebate
progra ms to pu r

chase cleaner wood

- burning devices (Burn Cleaner Program)?

 Make [the incentive] available to vendors as well. For those in homes with wood-burning devices there needs to be an increased incentive amount. For lower income the incentive is not high enough.

 They can do better with advertising, giving financial incentive so people can have an economic benefit to make the switch. T he y nee d t o get a good outreach program and make sure people are aware of the incentives. I think there are a lot of people who don’t know [what is available]. They need get the word out on local media, through advertising, and on television.

 I think we have to continue to get the word out. Right now most people get their information through tablets, laptops, mobile devices and television. I think you have to do more to get the message out from those media devices. I would think that the easier way is to offer a financial incentive, whether it be free or a much reduced price to get people to switch over.

 Well, you know they can make the program available to more people by offering it to more people, I think the way it works now is that it is only available certain times a year, very limited on how much they can do. Encouraging to people who actually sell these products, to help make it more widespread. Make it more affordable and have merchandisers to advertise it as well.

 Just more advertising of the availability of those incentives. I personally see those incentives and I think they do a good job. Advertise that in the newspapers . O rdinary people who have fireplaces in their homes need to see those opportunities. So they n eed to get it out and in front of people more and I think newspaper is the way to do it. I know they do it on the radio and I don’t listen to any kind of radi o that has advertising on it. The other idea I have is they should advertise more with the vendors that sell those cleaner burning fireplace apparatus because they will push the heck out of it because they got a stake in it to sell me and replace my fireplace.

 I would say continue doing outreach, I think one of the largest things that I see in the “ EJ ” community that I live in is a lot of the Hispanic communities do a lot of outdoor burnings, especially on the weekends when they are having gatherings, and it’s o pen pits and they are barbecuing turkeys and having big bonfires. I think that would be a good area to educate folks on.

 It is very difficu

lt now because of the recession. Let’s say a device cost $1000 bucks and they only give you $200; they only cover 80% and people just don’t have the money.

 Advertise more. A lot of people don’t know of the programs that are available.

 Issue vouchers to residents that want to turn them in so people know there is X amount of dollars available, if they choose to retrofit their house.

 I think they are doing the maximum they can at this point. They are doing everything they can through newspapers, television and specific areas with advertising

. I don’t think they

c an do mo r e.

 I think closer partnerships with retailers. It would provide retailers or give retailers more incentives for more advertising on cleaner burning equipment and they would advertise more if those rebates were available to them or their customers.

 I think just getting the word out to the different communities, whether that be through television or radio. Somehow we just need to get the word out on websites. We just need to get the word out, maybe attending fairs or maybe attending farmers markets, just making people aware that there are funds out there to change their wood-burning stoves.

 [The District] does quite a bit of outreach and advertising. I guess I would say I like the incentive approach to the extent that we can provide more funding to make contributions to help offset the cost of people putting in EPA approved wood burning devices and stoves to replace open-hearth burning. I like that approach versus the regulatory approach.

 I don’t know if there’s public information [going] out to folks about grant opportunities. Frankly there are more incentives for folks to move to cleaner wood burning devices. I think it’s just more information that needs to be [given] to the community because I know that people are more sensitive to the check before you burn and folks burning fireplacesor wood bu r ni n g stoves than they used to be, so part of that is air quality issues and also the message that has been provided to the community. So I think more information.

 Ban wood burning ; honestly, if you ban it and this is the only alternative, people, I think, would look toward it. If it was ever to go out of place, wood burning, I think it is still important to have the inventive in place. Not to take the incentives away now that it is mandatory.

 Well, I’m not familiar with the incentives for that program, so I can’t say whether they should be increased, but I do know, for example, on the clean lawn mower situation when the District was supplementing the cost, so we traded in my gas mower for an electric mower. They paid about $200 of the $300 in the cost. I paid about $150. That was very enticing for me to get that benefit.

 I know several people that I have recommended that they convert and they have. The problem is that they have a lot of folks that do not have the financial ability to do so.

 G et the me s sage out during the season when people are buying those items.

 There are already restrictions and building codes requiring new homes to be built with cleaner burning fireplaces. I figured it was already taken care of with those existing regulations. If you’re talking about trying to get people to replace [their existing devices]

, that’s tougher. I don’t know how you would do that. Do you think people are aware of the incentives? I would think so.

 Well I believe that many wood burners burn wood because of their economic status, they are trying to get low-cost heating for their space. They are not likely to spend $3,000 or more for the installation of a clean fuel device because they do not have those kinds of funds. So, I think the incentive the District offers for $500 is insufficient to attract those individuals to change their dirty burning devices to a clean burning device. Bottom line is they are going to have to increase their incentives if they want more participation.

 Well, I think they had a program where they had at one time a program: trade in your old fireplace or upgraded and you would get an incentive. I’ve heard now new houses are being built without fireplaces in the home.

 More education. People d

on’t know about it [the incentive programs]. A lot of people don’t read the papers. We are a very poor county so a lot of them don’t have TVs and many don’t speak English.

 One of the things that I have tried to be involved in and I really think is important and as a result, what we are looking at doing is make the program available for property owners, for example landlords can actually participate in the programs, they need to be able to participate in programs. That can be done through an educational process, through local entities like real estate boards and things like that. If we want to get people to stop burning wood we need to get the landlords newer and cleaner devices and we need to incentivize that.

 I think that they should do what PG &E does when they wanted to move people towards using less electricity

—they gave rebates. That’s effective when people are looking to spend less money, and when you hit that you will get a better response.

 Outreach through community benefit groups, organizations and non-profits.

 Right now it’s only when a house switches hands that they have to upgrade. Also, people who are exempt maybe shouldn’t be exempt.

## Per cep t io n s of the District and Air Quality Policies

B al an ce Betwee n Pub lic Health and Economic Prosperity

R esp on dents w ere asked how well they think the District balances public health with economic interests. Overall, the majority of respondents reported that District was doing a good job balancing public health and economic interests even though some stakeholders believe more or less regulation is needed. Although many respondents expressed concern that the Di strict does not do enough to protect business interests, the majority of stakeholders described the District’s policies as reasonable given California requirements and local economic concerns. Commercial stakeholders were more concerned about compliance requirements imposed on business than were citizen advisory committee members and other District stakeholders.

Q : H ow wel l do you think the District balances protecting public health through regulation and he l pi ng t o ensure the Valley’s economic prosperity?

 I believe the District does a really good job. I think they do a balancing act. I have been very impressed with the outreach they have done. Everybody thinks the Air District is heavy handed. People don’t understand that we are trying to meet federal regulations in order to be able to put more money into our grants programs to help people to change out their wood stoves or purchase cleaner burning lawn mowers, or help tune up their cars so there isn’t any bad stuff going into the air.

 It’s a tough balance we are always keeping our economy in mind and the economy in the Valley is always a bigger challenge when the new regulations are being imposed. I would say we have done a good job to keep balance and we have always thought out new incentive programs and grants that we can get for the federal governments.

 The Valley Air District has done a tremendous service for our valley and our community; it’s a model for the nation, other people are looking at we do. All we have to do is look at people in China who are walking around with masks

-- that’s what zero regulation is. And so once more people realize what they are doing makes a difference, people can make a small sacrifice to improve air quality.

 I just think the Air District is doing a great job. I think that we, as Valley residents, live in a fish bowl and unless we can do something about the cartography of the mountains surrounding us, the District is doing all that they can with the air.

 I think the District does an excellent job at that [balance protecting public health]. That’s the hallmark of the District, achieving measurable and significant air quality, while working closely with stakeholders who are impacted by regulatory decisions to attempt to work in better ways so they are able to stay in business.

 I think they are doing well in a very difficult circumstance.

 I think the board is very much in tune with their constituents on what they can and can’t do. What they do very well is they have the industry help write these rules. If I am in industry I am more apt to follow a rule that I helped write than dictated to. I think the board does an excellent job on how they are regulating the rules right now. Everyone has to give and compromise.

 It can improve. I recall during conversations and meetings with the District the focus is on not hurting business and jobs, but the focus and improvement should be on other [economic prosperity]. It should not be one or the other.

 [The District is] heavily weighted on money and not enough on air quality. Define short term horizon, how is it going to [encourage] businesses and people to live and move to the area in the next 10-15 years. The economic viewpoint has to be long term, not short
term. I ’ m not s ure what regulations the District has in place, but there has to be a fine line [between public health and regulation] so that the economy doesn’t tank. The Valley’s economy is agriculturally based and that produces a lot of pollution.

 I give them a failing grade at this point. I think they are abusive and hard on the Valley businesses. I think they would like to do better by the businesses, but I think they are being sued by the environmental groups. I think they are caught in the middle. I think the businesses have the least amount of dollars to sue back so the environmental group is winning at this game. I think it’s more than a game, it’s very serious , but I feel sorry for the air board because I know they are caught in between environmental activist and the EPA. And I don’t know where the air board goes next quite frankly, their goals are unattainable. I know their goals are unattainable because the air board told me the goals the EPA and environmental groups are unattainable.

 I think they have our health at the forefront.

 I think there is a very thin line the District has to balance. I think first and foremost the District is a public health agency and their job is to protect public health. I sometimes wonder whether trying to protect the most sensitive groups is sometimes fruitless at the same time a token... I think they do an outstanding job to protect the overall majority. In the end it’s obvious in my opinion, I mean I come up on top of the overpass every day and can have a clear view of the Sierras and the Coastal Range and that is proof in the pudding that the rules that the District has has really good effects.

 I would say 3.5, favorable, [but] not doing enough. That’s my personal opinion.

 I don’t think they are too strict. I think they do a good job.

 I think there is a total disconnect

. I think it’s a terrible relationship. I think the D i s tri c t is catering to CARB and EPA and I think that it has totally forgotten their constituents of the Valley. I think they are harming the people of the Valley

.

 I th ink they are doing a very good job.

 I think they do a reasonably good job. I think there is more room to improve that. I think it’s in the way for incentives and grants for small businesses to comply.

 I think the District works hard to try to maintain that balance. Because the District is public health focused organization and is also trying to do so in geographic constraints that we operate under, as well as the economic circumstances the Valley faces. The District and board tries to make that balance every time we face those decisions.

 They have done a very decent job. The administration and staff at the District, in my opinion, have done a good job outreaching towards those individuals that will be affected to try and come up with economic incentives or different ways of obtaining goals that are more realistic. They try to work with the stakeholders to reach the goal while taking into account the business community.

 Wow, that’s a complicated bal ance. I think they try really hard so I would say they are doing a good job.

 Well, as far as I know, it has been fairly balanced. I would be more aggressive on supporting local government and adopting and maintaining a simple growth plan that would reduce all vehicles travelled.

 I think the District does as much as they possibility can as far as information is concerned and the California Air Board and they dictate what we can and cannot do. The District has some flexibility, but most regulations come out of Sacramento and Washington DC from the EPA. I believe that most people in this area, the San Joaquin Valley, are very aware what we are trying to do and what other people need to do to clean the air. Not we l l . It’ s not working because of greater problems [are at] the State level. The regulations have just become so exhaustive that businesses just can’t afford to be here. Those that are left, pass on the cost to consumers.

 You have to tag the problems to individual [segments] in the industry, not across the board. The fuel industry and the farm industry, they all deal with different components of the ag-industry. A tree farm is not going to be the same as a cow farm, a cow farm is not going to be the same as a cotton farm. So when you are looking at the ag-industries you have to break them down and do a needs assessment as opposed to applying a blanket policy. The industry does not fit into one box.

 San Joaquin Valley Air Pollution Control District is exceptional at that [balance]. They do a really good job and that is partly why they are so successful. They understand that there are limits to what they can mandate and still have people stay in business...The problems come from the State and Feds in their ivory towers. [The State and Fed] don’t really care what the effect is on the individual.

 I think at this state of this game, or at least until old timers get older and die off, the District is always going to be blamed for the loss of jobs. They have done some strict pollution regulations that have been imposed on industry and stationary sources that have added a lot on the perception that regulatory climate in Southern California is not business friendly. I believe the District needs to try and maintain a balance, but the early regulations may have crippled businesses that may be gone now.

 Well, the economic prosperity is we help the programs help and people don’t want to take advantage of it and then again that goes back to the people.

 Well, the standards are set to public health and that’s their goal, continuously their goal is to meet the...the standard is set through the EPA and CARB to protect health. That’s a kicker, they are trying, the board itself takes into consideration the economics and to have a healthy business c

limate that is constantly on their mind, so that’s always what we start when we are making the rule making process.

 It’s a delicate balance. It’s very, very important that the public understands that this [the regulations] are for their health. A lo t of people don’t realize the connection between what they do and air pollution. They don’t get it.

 It’s a tough thing but I think the District does as well as it can. [The District] has to be mindful of the decisions that it makes and how they will impact businesses. I think they do a really good job of balancing that.

 I think they are doing a really good job, the District has a really good program through industry and agricultural through the different associations and entities that represent different segments of those entities. Working with them has been very cognitive, give and take, accomplishing the goals the District needs to take to get the air cleaned up. I would say they have done a fantastic job.

 I think they are trying, but I don’t think they are doing a good job.

 They do a fair job ... but I think they need to do more.

 I think they do as well as they can. They try very hard.

R eg ul ator y , Voluntary, and Incentive-Based Policies

Fi nal l y
, respondents were asked if there were any unregulated consumer activities that they thought were appropriate for additional District action and, if so, whether they would recommend regulatory, voluntary or incentive-based policies. The most frequently cited areas foradditional action were school-site idling and drive-through services followed by gaspowered lawn care equipment. When asked what type of policies they would recommend, respondents most often recommend ed incentive programs. Stakeholders were evenly spliti n t he ir support of regulatory and voluntary measures. Many respondents recommended all three approaches

. As one respondent explained, “ It’s not one or the other. You have to use those [regulatory, voluntary, and incentive-based policies] all in concert. Some things have to be regulated and there has to be some incentives. Obviously we need to get people to voluntarily do some things. They don’t work in isolation of each other.” Selected comments regarding regulatory, voluntary, and incentive-based programs are presented in Table 2 , followed by comments regarding the activities that the District should consider addressing.

Table 2: Selected Comments Regulatory, Voluntary, and Incentive-Based Policies (Multi-Response Question, Respondents Could Recommend More Than One Approach)

R eg ulat ory ( 13 Respondents) Le af bl ow ers should be regulated, you can’t de pe nd on volunteer measures.

Y ou have t o make some things mandatory to
ge t peop l e’s attention. When we hold town

ha l l m ee tings, if it’s about regulations we ha ve 200 peop l

e
, i f it ’ s about education we
ge t 60 pe op l

e. Th o se regulations are

con t r over si al but you have to make it matter
t o peop l e

. V oluntary (13 Respondents) W e shoul d start with voluntary measures

an d see ho w t

hat works.

Y ou can ge t a lot done with volunteer efforts.

S cho ol i dl ing must be voluntary, bu t

r eg ul ator or incentive programs are i mpo rt an t to address other questions.

I ncen ti v es ( 18 Res po ndents) I t hink in cen tives and education are more eff ec t ive. I really hate to see rules and

r egul ations co m e down to the kind of detail t he r e i s now... There i

s a po i nt where you

are no t go i ng to get the bang for the buck for
t he kind of disturbance you are causing in
pe op l e’ s lives.

I nce ntive s w

ork best for lawn equipment and carpool i ng

. I t hink [ i ncentives] work. There are a lot of
op ti ons, including financia l

i ncentive s.

Th ey should be

i nce ntive based

. R eg ul ations ar e ha r d to enforce and would pl ace a burde n

on one class of

pe opl e
, bu t i f
you can i nce ntivize t hat w ou ld be be tt er t han

a m an da te.Q : Ar e there any unregulated consumer activities (e.g. lawn care, drive

- t h r ough services, or scho ol

- si t e idl i ng) that are appropriate for additional District action? Please explain.

 Leaf blower

s, especially since the District covers a big landscaping industry. Especially summer and fall. Idling at school, it is so hard to enforce this behavior, but it should be regulated. Also, the carpool lane should create more outreach and be more enticing. We should give incentives based on tracking how many miles you drive in the car pool lane.

 Lawn care needs to be incentive based. Politically, lawn service people are poor. And for idling , it needs to be much easier to walk or bike to school, it’s a feder al -state problem, encourage walking and biking. There is always an excuse for parents to pick up their children but in the long term they are hurting the lungs of their kids. Society is very short term focused.

 There has been a lot of discussion of cars idling in fast food lines and at schools. I’m not sure how much needs to be done in terms of regulation

. I think the issue is awareness. P eo pl e do n ’t know [the impact of idling.]

 I don’t know, I think a lot of those things would be hard to regulate first of all, so like drivethrough idling, how do you regulate that ? Lawn care, it has to be balanced between what you can do to reduce emission, but at the same time making it so that the people who are performing those services are not impacted financially . I think it’s a balancing act.

 Well, you know it gets back to what business can and cannot do again. The whole debate about drive-through and whether those are harmful have been debated. Just look at the number one fast food in the country, Subway, and they don’t offer drive through services. Fast food companies say it’s for their business, so it can’t be just that. Educating the parents and schools, I think more can be done there. Once parents realize that they are sitting there idling is way more harmful. Getting more people to walk to school or riding their bikes. A lot more can be done with educating people.

 I get really frustrated when you drive through town and there are numerous lawn folks who have their leaf blowers and they are blowing leaves, dust and dirt onto the street and the vehicles are blowing it right back on the sidewalk. I tend to wonder what they are accomplishing... it seems to be a continual cycle never getting anywhere.

 Those are all for just attention, they don’t address the true issue. The true issue is that 80% of the pollution in the valley is from mobile sources.

 We need to approach the school district and somehow make people more aware of how idling effects the bad air we have. I think we can do more education through the District. [It] is the only thing that I can see.

 I think school idling is a big issue

. We have told parents to turn off their engine when wai t ing ...i n hot w eather they like to keep it on. I think regulation may be a good idea.

 A lot of folks are opposed to drive-throughs, but the analysis shows that unless you are going to be sitting in a drive-through for an extended period of time, you actually may have more emissions from turning off your car than turning it back [on]. We have to avoid reacting to people’s intuition and rely on sound science.

 Lawn care, may be one area of fo cus, but it’s relatively small compared to mobile source emissions

 Just make people aware, don’t regulate. If you start with education and reasoning , most people are going to comply. That’s how recycling first got started in Fresno in the
1970s

— through education and voluntary actions. People are regulated to death.

 Some cities have [placed] bans on drive-throughs, which I think is a big source of idling cars. I know they have changed the procedures at schools so you’re not encouraged to sit there and have your car running. W el l nob od y wants their activity to be regulated, so by encouraging innovation and technology is to improve quality of equipment or reduction of emissions from that type of equipment, to increase education, and to try and continue to teach principles to

co mmunity members of their importance or their work or their actions contributing to their reduction of air pollution. Their services to be best provided.

 All we can do is suggest that they kill the engines when they are waiting for the kids. And we’ve done that, we had the flag program where they can wait to pick up their children near the flags, and they don’t realize what the flag is all about. We advertised the flag program and now we have spots on TV where all board members get on there and suggest something. What else can we do?

 There needs to be more regulations on drive-throughs and trucks.

 We have to be careful not to cross that line between regulations and infringements on civil rights. So, to tell someone for example that they can try to shut down drive-throughs at restaurants, but I don’t think legally we can do that and the impact on businesses would end up costing thousands of dollars.

 I think the dairy and AG industries are an even more important target.

 School- site idling is huge. Our son rides his bike to school and it’s less than a mile and a half. I understand that people are nervous about kids on the street, but we really need to get back to the culture when kids walked. Get parents to chaperone neighborhood kids. It’s promotes a healthy lifestyle.

S ug g est i ons for Additional District Action

La st l y, respondents were asked if they had any other suggestions for the District. Open-ended responses are presented below. Many stakeholders recommended that the District increase its interaction with its constituents, including face- to -face opportunities to explain programs, gather feedback, and increase visibility. Other suggestions included multi-lingual materials and an increased budget for public outreach.

I f you co uld you could give the Air Pollution Control District one suggestion, what would it be?

 They should have more materials in different languages. There should be more robust campaigns for multi-languages, other than English and Spanish.

 Be more aggressive, and don’t have a political agenda.

 Make sure you know the word is being disseminated to everyone. Not only is it necessary to conduct outreach, but also follow-up to see if the outreach is working and how it could be improved.

 Continue on with the zero emission program where it is incentive based where consumers and homeowners in general have the opportunity to purchase things that are cleaner. Give consumers an incentive to switch over to cleaner or zero based emission.

 They need to increase their outreach budget. Because right now the way they take those dollars and split them

.. . It just ne eds to be out there more than it is. It’s a function of cost, they onl y have so many dollars.

 I think they need to pause, they have done really good. They need to let us all get a breath of air and we will strive for something cleaner burning in our next phase. We need a little breathing room.

 I’ve had the pleasure with working with them now for a decade, and I’ve said this in many public meetings, if other [regulatory(s)] would follow the paradigm of San Joaquin Valley, my job as environmental director would be so much easier. [The A i r P ollution Control District should] make it easier for people to take advantage of their programs. Make it friendlier. Send more people out in person to explain the benefits to individuals, organizations a nd businesses. Let people know, “ Hey, here we are and this is what we are trying to do. ” Some of these people don’t have access to the Internet and computers. Start implementing pilot programs and show results. That will encourage more people to make changes. Give people a chance to use a vehicle or equipment for a year. Test it and see what it does. I think that would work.

 Stop catering to CARB and EPA; remember who they work for.

 I think they are doing an excellent job so I don’t have any objections.

 To continue to be user friendly and market [their programs]. Do more marketing so that they aren’t perceived as a regulatory agency and more as an agency for the people.

 Continue doing the great things that they are doing.

 Be more visible in the community.

 Probably working as aggressive as possible with California [Air] Resource Board on trying to reduce mobile sources.

 I think they are doing a really good job given the difficult circumstances, unfortunately if God had wanted to create the perfect location he would have done better than the San Joaquin Valley

. We’re plagued by the fact that we are the east/west [corridor] for transporting goods. We have so many kinds of diesel trucks that make no contributions to the Valley. They are just passing through and leaving the pollution to be cleaned up.

 I would just say, continue the efforts in terms of public information and education because I think the more informed our Valley constituents are about air role and impact of air quality and the challenged regarding air quality the better they are making decisions about that.

 I’m an environmental manager for a plant so I deal with them regularly and they have been very supportive, flexible and have done what they can to help me. And other times they are not very flexible, I guess the only comment I can make there is within the guidelines be a little more flexible. I’m not complaining like I said, they have helped me lots of times.

 Probably investing in demonstration projects that would increase walking, biking andtransit throughout the Valley so helping to finance the infill development and transitoriented development in cities like Fresno and other cities that are trying to offer some alternatives to low density sprawl.

 [I recommend] having a summit with people with life experience and enthusiasm and combine that with those with education to better understand the situation. All of that needs to be part of the component. You are dealing with people’s lives and their livelihood.

 They seem to do things in a coherent way, thoughtfully. I have no suggestions.

 Well I think the rules they have established are pretty complex, it’s really hard for individuals who do not have significant training in those areas to try and even to be able to decipher and determine what the requirements are, so they often find themselves on the end enforcement action by the Air District, which makes people to cooperate less.

 Continue working the way we are working. Try to get the people to work with us because if they don’t want to work with us there is nothing else we can do.

 I would probably want to make sure that all decisions are scientific, are good science. No regulations are not based on good science.

 I think that we should ask what people think about how to regulate traffic and drivethroughs. Those are the big problems we’re facing. Cont i nu e to tak e a proactive stance in not only keeping the air clean, but proactive politically and to not be afraid to actually litigate against the EPA or the ARB as necessary, don’t be afraid to go after them.

 To be more bold in their rule creation and rule enforcement.

 I would say to keep doing what they are doing with one respect, I think they are maintaining a balance on health and on the impacts on their recommendations or decisions on the economy. Maintain that balance.

 I really think they need to more about the particulate. We’ve had horrible episodes in the last year. For planning purposes, they [the District] don’t have to c ount these really bad episodes. It’s allowed by the EPA as an “ exceptional event. ” The air quality will get marginally better after one of these events and then they [the District] will lift the no -burn restrictions, which doesn’t make sense.

 Look back at the Remove Program, might be other worthwhile programs. Look at the highest dollars vs. reduction of air pollution. Do not limit based on budget because there can be great programs that can help eliminate air pollution, but can’t make the cut.

 I just think the board and the Air District need to take a serious review of their allegiance to CARB and the EPA versus the economic damage that has been [done] to the Valley.

 It seems like to me they are trying to find ways around this thing instead of going towards and through the people.

### A P P END IX A:

INTERVIEW GUIDEV all e y A ir District Residential Wood Burning, Lawn Care, and Commuting Study 2014 Community Stakeholder Interview Guide

INT RO DUCT ION

Hel l o, my name is ______________ and I’m calling on behalf of the San Joaquin Valley Air Pollution Control District. Is this ___________ [confirm name of individual being interviewed]. I have you schedul ed for a brief interview. Is this still a good time? [Reschedule if necessary]

We are speaking with various community stakeholders about their perceptions of the air quality in the San Joaquin Valley and the various programs that have been implemented to reduce air pollution.

I. Perception of Air Quality

1. Us i ng a 5 -point scale, where 5 is Excellent and 1 is poor, how would you rate air quality in the San Joaquin Valley overall?

5 4 3 2 1 Not sure/Refused

2. Thinking back over the last 5 years, would you say the air quality in this area has gotten better, gotten worse, or stayed about the same?

Gotten Better Gotten Worse Stayed the Same Not sure/Refused

3. Looking forward, what can be done in the Valley to reduce emissions further?

4. Could you describe how the air quality and/or air quality regulations in this area have impacted your [customers, employees, constituents, members, family], if at all?

II. Awareness and Perceptions of Healthy Air Living /Check Before Your Burn Programs

5. Have you ever heard of the Valley Air District’s Healthy Air Living program? Yes (go to modified Q7) No (go to Q6 & Q7) Not Sure/Refused

6. Healthy Air Living

is a program designed to improve air quality on a daily basis. This includes reducing the number of miles driven each day; reducing pollution created by equipment such as leaf blowers and lawnmowers; and encouraging development of cleaner energy sources. The program provides specific information and incentives so San Joaquin Valley residents can voluntarily reduce air pollution.7. No w that y ou have some/more information about Healthy Air Living , [do you have a favorable or unfavorable opinion about the program? (Is that very or somewhat?)] (Ask only second part if response to Q5 is Yes)

Very Favorable Somewhat Favorable Somewhat Unfavorable Very Unfavorable Not Sure/Refused

8. Why is that? [rating of Healthy Air Living program]

9. Have you ever heard of the Valley Air District’s Check Before You Burn program? (Explain if needed)

10. How can the District encourage more people to take advantage of its incentive and rebate programs to purchase cleaner wood-burning devices ( Burn Cleaner Program )?

III. Perceptions of the District and Air Quality Policies

11. How well do you think the District balances protecting public health through regulation and helping to ensure the Valley’s economic prosperity?

12. Are there any unregulated consumer activities (e.g. lawn care, drive-through services, or schoolsite idling) that are appropriate for additional District action? Please explain.

13. If you recommend action on Q12, should that action be regulatory, voluntary, incentive-based, or other.

Regulatory Voluntary Incentive-based Other (explain)

14. If you could you could give the Air Pollution Control District one suggestion, what would it be?

“They seem to do things in a coherent way, thoughtfully. I have no suggestions.”

15. Those are all the questions I have. Is there anything you would like to add?

Thank you for your time

# APPENDIX F

EPA list of Certified and Exempt Wood Burning Heaters

Proposed Amendments to Residential Wood Burning P rogram

September 18 , 2014

### This page intentionally blank.

### EPA Certified and Exempt Devices

Pursuant to rule language devices purchased and/or installed on or before March 31, 2015 that qualify to be register ed with the District to be used during Level 1 Episodic Curtailments must be EPA Phase II certified or exempt pursu ant to requirements in the Code of Federal Regulations, Part 60, Titl e 40, Subpart AAA at the time of purchase and/or installation. The following two lists are maintained by EPA on their website at: http://www.epa.gov/Compliance/resources/public ations/monitoring/caa/woodstoves/certi fiedwood.pdf and at http://www.epa.gov/compliance/resources/pub lications/monitoring/caa/woodstoves/exe mptwood.pdf

.
The list of exempt devices is not an all-incl usive list. Many pellet stoves were exempt pursuant to subpart AAA language and are not in cluded in this list. Therefore, with regards to pellet stoves, the list of exempt devices is for reference only, with the understanding that additional pellet stoves in stalled/purchased on or before March 31, 2015 may be exempt.

Additionally, rule language requires t hat wood burning heat ers purchased and/or installed on or before March 31, 2015 be Phase II Certified; t herefore, devices that are wood burning heaters that are included in the list of exempt devices are not considered clean burning devices and would not qualify to be registered with the District.

### This page intentionally blank.

# List of E PA Certified Wood Stoves
December 2013

EPA Wo od Heater Program



### Enclosed is the list of wood stoves certified by the United States Environmental Protection Agency (EPA). The EPA Certified Wood Stoves list contains information about wood stoves or wood heating appliances that have been certified by the EPA along with its
manuf ac tur er name, model name, emission rate (g/hr), heat output (btu/hr), efficiency (actual measured and estimated), and type of

a ppli a nce. It also indicates whether the appliance is still being manufactured. An EPA certified wood stove or wood heating

a pplia nc e has been independently tested by an accredited laboratory to determine whether it meets the particulate emissions limit of
7.5* gr a ms per hour for non-catalytic wood stoves and 4.1* grams per hour for catalytic wood stoves. All wood heating appliances that are offered or advertised for sale in the United States are subject to the New Source Performance Standard (N SPS) for New Residential Wood Heaters under the Clean Air Act and are required to meet these emission limits.

A n EPA ce rtifie d wood heater can be identified by a temporary paper label attached to the front of the wood stove and a permanent metal label affixed to the back or side of the wood stove (see examples below). If you have questions regarding a particular model line or manufacturer, please contact Rafael Sanchez at 202-564-7028 or via e-mail at S anc he z.rafael@epa.gov

.* 

### T e mporary Wood Stove Label Permanent Wood Stove Label

Wood stoves offered for sale in the state of Washington must meet a particulate emissions limit of 4.5 grams per hour for non catalytic wood stoves and 2.5 grams per hour for catalytic wood stoves.List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type
A. J. Wells and Sons LTD Cove 2 SR 4.4 9256 - 32,557 63 Non Catalytic

x Alladin Hearth Products Sunburst II Model 2208 4.4 11500- 36300 63 Non Catalytic

x American Road Equipment Company Erik SW II Catalytic Environmentalist SSW-1000 1.2 9800-46900 72 Catalytic

Amesti LTDA N380 5.16 10671 - 27842 63 Non Catalytic
Amesti LTDA Rondo 450 4 11,842-24,288 63 Non Catalytic Appalachian Stove & Fabricators, Inc. Model 32-BW 2.5 10400-24500 72 Catalytic Appalachian Stove & Fabricators, Inc. Model 360-CR 2.8 10600-29100 72 Catalytic Appalachian Stove & Fabricators, Inc. Model 36 BW 3.3 10600-30200 72 Catalytic Appalachian Stove & Fabricators, Inc. Trailmaster Model 4N1-XL II 3.4 10100-26900 72 Catalytic Appalachian Stove & Fabricators, Inc. Model 30-CD 3.7 8500-21400 72 Catalytic Appalachian Stove & Fabricators, Inc. 36-BW-1988 3.9 9500-19300 72 Catalytic Appalachian Stove & Fabricators, Inc. 32-BW-XL-88, Gemini-XLB 1989 4 8400-19800 72 Catalytic Appalachian Stove & Fabricators, Inc. Model 52 WXL 1988 4.2 10500-15400 72 Catalytic Appalachian Stove & Fabricators, Inc. Heritage Classic A, T16, Cast heat & Catskill 4.4 10,300-31,200 63 Non Catalytic Appalachian Stove & Fabricators, Inc. 28 CD 4.5 9500-16300 72 Catalytic Appalachian Stove & Fabricators, Inc. Trailmaster 4N1-XL 4.7 9600-19600 72 Catalytic Appalachian Stove & Fabricators, Inc. Heritage Classic;Model Numbers T16 & VT16 6.81 11057-31327 63 Non Catalytic Archgard Industries, Ltd. Optima PS1 0.87 10,196-29,581 63 Non Catalytic Archgard Industries, Ltd. Chalet 1600 and Chalet 1600 Insert 2.88 10,611-29,181 63 Non Catalytic Archgard Industries, Ltd. Chalet 1800 3.62 10,700-35,500 63 Non Catalytic
Austroflamm Industries Inc. Integra C1121, II 2.7 9300-31100 78 Pellet
Austroflamm Industries Inc. Esprit Wood 119.1 6.3 11400-43600 63 Non Catalytic
Austroflamm Industries Inc. Irony M 6.6 11800-46800 78 Pellet Avalon by Travis Industries, Inc. Spokane 1250 4.4 11600-38500 63 Non Catalytic

x Avalon by Travis Industries, Inc Perfect-Fit insert 4.1 11,300-33,400 63 Non Catalytic

Avalon by Travis Industries, Inc. Avalon Spokane 1750 1.94 9300-42200 63 Non Catalytic Avalon by Travis Industries, Inc. Rainier, Rainier insert 2 11200-40000 63 Non Catalytic Avalon by Travis Industries, Inc. Arbor 2.4 10,700-33,900 63 Non Catalytic Avalon by Travis Industries, Inc. Olympic, Olympic insert 2.6 12000-45100 63 Non Catalytic Avalon by Travis Industries, Inc. Pendleton, Pendleton insert 3 8700-44400 63 Non Catalytic Barbeques Galore/Pricotech Rosewood 2.7 11600-36200 63 Non Catalytic Blaze King Industries, Inc. Chinook /Sirocco/Ashford 30 0.97 11,200- 27,280 75 72 Catalytic Blaze King Industries, Inc. Blaze King KEJ 1107 1.76 9100-39800 82 72 Catalytic Blaze King Industries, Inc. Blaze King, King Catalytic KEJ-1101 1.9 9000-35300 72 Catalytic Blaze King Industries, Inc. Princess Insert Model PI 1010A 2 7,200-29,500 80 72 Catalytic Blaze King Industries, Inc. Chinook / Sirocco/Ashford 20 1.3 11,400 - 22,700 77 72 Catalytic Blaze King Industries, Inc. Heat Pro C210 2.1 10700-43300 72 Catalytic Blaze King Industries, Inc. Blaze King, King Catalytic Insert KEI-1300 2.2 10100-34500 72 Catalytic Blaze King Industries, Inc. Princess PEJ 1006 2.4 12000-35600 81 72 Catalytic Blaze King Industries, Inc. Blaze King, Auto Light PAL-4000 2.5 12200-33700 78 Pellet Blaze King Industries, Inc. Blaze King, Royal Heir RHT-2200, 2250 2.5 7700-31100 72 Catalytic Blaze King Industries, Inc. Blaze King Princess Insert Model PI 1010 2.8 9,300-31,200 80 72 Catalytic Blaze King Industries, Inc. Heat Pro C110 2.8 9600-32400 72 Catalytic Blaze King Industries, Inc. Blaze King, Royal Heir RHT-2100 3 6800-57100 72 Catalytic Blaze King Industries, Inc. Blaze King PEJ 1003 2.4 10300-41600 72 Catalytic Blaze King Industries, Inc. Briarwood II/90 3.5 10600-36000 71.4 63 Non Catalytic Blaze King Industries, Inc. Blaze King, Princess Catalytic PEJ-1002 3.7 8400-35400 72 Catalytic Blaze King Industries, Inc. Blaze King KEJ-1102 3.9 7900-42600 72 Catalytic Blaze King Industries, Inc. Eagle/Pioneer E90, PZ-90, Briarwood XE-90, XEI-90 5.2 13500-38000 63 Non Catalytic Blaze King of Montana Blaze King Royal Guardian, RGT-3001 5.8 9400-39800 71.1 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 1List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type Boru Stove Company Carraig Mor BCMUS 3.9 12,878 - 28,846 73.2 63 Non Catalytic Bosca Chile S.A. (Ingeniera De Combustion) Spirit 500, Classic 500 1.2 8,700-21,700 78 Pellet

Bosca Chile S.A. (Ingeniera De Combustion) Soul Pellet Stove Insert, Soul 700 free standing, Soul 700 Insert 2.2 6,100-30,000 78 Pellet Bosca Chile S.A. (Ingeniera De Combustion) Spirit 550, Limit 450 and Classic 450, Spirit 500 3.6 11,359-26,100 63 Non Catalytic Bosca Chile S.A. (Ingeniera De Combustion) Gold 400 4.4 11,800-26,800 63 Non Catalytic Bosca Chile S.A. (Ingeniera De Combustion) Miner 33 4.3 11,756 - 35,388 63 Non Catalytic

Ceramiche Savio di Elio & C. s.n.c. Catellante di Castellante and Real Castillo di Ague Model CS1 5.1 11200-40800 63 Non Catalytic
Ceramiche Savio di Elio & C. s.n.c. Real Castelllo di Moncaueri/Castllo Della Venaria 5.6 10100-24200 63 Non Catalytic CFM Corporation DutchWest Large 2479 1.31 11,300-26,500 63 Non Catalytic CFM Corporation DutchWest Small Model 1.41 7,800-25,100 63 Non Catalytic CFM Corporation DutchWest Medium 2478 1.5 10,600-25,300 63 Non Catalytic CFM Corporation Model EWF 36A 2.4 11,300-75,500 72 Catalytic CFM Corporation Vermont Castings Defiant 1610 2.9 10,000-30,000 63 Non Catalytic CFM Corporation EWF 30 3.5 11,100-40,500 63 Non Catalytic CFM Corporation Aspen 1920 & Plymouth HWS10 4.3 9100-18000 63 Non Catalytic

CFM Corporation CW2500X00, CW2500X02, JW2500X00,CJW2500X02,
DW2500 and JW2500X10 4.7 9500-57800 63 Non Catalytic CFM Corporation FW247001 to FE247004 and JW1000PF1 5 11500-18900 63 Non Catalytic

CFM Corporation (Jacuzzi Leisure Products, Inc.) Campbell/Jacuzzi CJW2000L02, JW2000L10, DW2000XXX and
JW2000P10 4.4 12000-55100 63 Non Catalytic

CFM Corporation (Jacuzzi Leisure Products, Inc.) Campbell/Jacuzzi FW300005-FW300009 & FW300019- FW300027, 4.4 12000-55100 63 Non Catalytic CFM Corporation (Jacuzzi Leisure Products, Inc.) JW1500P10, FW1500, DW1500, JW1500L10 4.4 10300-29200 63 Non Catalytic CFM Corporation (Jacuzzi Leisure Products, Inc.) S27X/S28X & FW27 Series, CJW1500L02 4.4 10300-29200 63 Non Catalytic CFM Corporation (Vermont Castings, Inc.) Defiant Encore 0.6 6200-32900 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Encore 1450 N/C 0.7 10,600-24050 63 Non Catalytic CFM Corporation (Vermont Castings, Inc.) Defiant 1910 & 1945 0.8 10600-44400 72 Catalytic CFM Corporation (Vermont Castings, Inc.) 2370 1 5700-18300 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Century/Dutchmaster FW and CDW 1 11,800-32,300 63 Non Catalytic CFM Corporation (Vermont Castings, Inc.) Dutchwest Small Convection Heater #2460 1.1 6600-27300 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Dutchwest Extra Large Convection 2462 1.3 8300-28000 72 Catalytic CFM Corporation (Vermont Castings, Inc.) FA455 1.3 10400-26500 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Dutchwest Large Convection Heater (Model 2461) 1.41 10700-29500 72 Catalytic CFM Corporation (Vermont Castings, Inc.) C.D. Lg. Fed. Convection Heater FA264CCL, FA264CCR 1.6 6600-26700 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Defiant Encore 2550 (Formerly 2190) 1.6 8700-41700 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Defiant Encore 2140 1.8 9000-41300 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Intrepid II Model 1990 2.1 8300-26700 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Model 2170 2.1 9400-22800 72 Catalytic CFM Corporation (Vermont Castings, Inc.) WinterWarm Fireplace Insert Model 1280 2.1 10300-30000 72 Catalytic CFM Corporation (Vermont Castings, Inc.) WinterWarm Small Insert Model 2080 2.1 8700-31100 72 Catalytic CFM Corporation (Vermont Castings, Inc.) FA264 2.2 9500-31700 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Intrepid II Model 2070 2.4 9200-19300 72 Catalytic CFM Corporation (Vermont Castings, Inc.) C.D. Extra-Lg. Federal Convection Heater FA288CCL 2.6 8400-38700 72 Catalytic CFM Corporation (Vermont Castings, Inc.) EWF36 2.7 11,800-68,600 72 Catalytic CFM Corporation (Vermont Castings, Inc.) C.D. Small Federal Convection Heater FA224CCL 2.8 7000-30600 72 Catalytic CFM Corporation (Vermont Castings, Inc.) C.D. Rocky Mountain Heater FA211CL 2.9 6800-27800 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Montpelier 2.9 10,094-27,550 63 Non Catalytic CFM Corporation (Vermont Castings, Inc.) 2370 3 10.094-27,550 72 Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 2List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type CFM Corporation (Vermont Castings, Inc.) FA224 3.1 9100-34800 72 Catalytic CFM Corporation (Vermont Castings, Inc.) FA288 3.1 7800-29300 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Intrepid II 1308 3.1 10200-22500 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Intrepid Model 1640 3.3 8200-19500 63 Non Catalytic CFM Corporation (Vermont Castings, Inc.) Madison Model 1655 3.3 11,300-39,700 63 Non Catalytic CFM Corporation (Vermont Castings, Inc.) Resolute Acclaim (Model Number 2490) & TLWS1 3.4 9500-33900 63 Non Catalytic CFM Corporation (Vermont Castings, Inc.) C.D. Federal "A Plus" FA224ACL 3.5 7200-30000 72 Catalytic CFM Corporation (Vermont Castings, Inc.) C.D. Sequoia FA455 3.6 8700-60300 72 Catalytic CFM Corporation (Vermont Castings, Inc.) C.D. Adirondack Wood Heater FA267CL 3.7 8400-40000 72 Catalytic CFM Corporation (Vermont Castings, Inc.) WinterWarm Small Insert (model 2370) 4 9250-21500 72 Catalytic CFM Corporation (Vermont Castings, Inc.) C.D. Large Federal Box Heater FA209CL 4.3 9000-25600 72 Catalytic CFM Corporation (Vermont Castings, Inc.) C.D. Small Federal Box Heater FA207CL 4.3 6200-28000 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Seville 1635 and 1600 Insert 4.5 9,900-30,800 63 Non Catalytic CFM Corporation (Vermont Castings, Inc.) Resolute Acclaim 0041 5.1 8700-30900 72 Catalytic CFM Corporation (Vermont Castings, Inc.) Madison 1650 5.5 11400-31000 63 Non Catalytic CFM Corporation (Vermont Castings, Inc.) Seville Insert 5.5 10200-27400 63 Non Catalytic CFM Corporation (Vermont Castings, Inc.) Aspen Model 1920 6.3 10100-26400 63 Non Catalytic CFM Corporation (Vermont Castings, Inc.) Seville 1630 6.3 12000-27300 63 Non Catalytic Consuming Fire, Inc. Perfect Hearth 3.4 11,700-38,100 63 Non Catalytic

x Country Flame Technologies, Inc. R/90 1.5 10600-46800 72 Catalytic

x Country Flame Technologies, Inc. E-1/90 1.7 9600-37800 72 Catalytic

x Country Flame Technologies, Inc. B/A 2 10400-55500 72 Catalytic

x Country Flame Technologies, Inc. O-2 2.5 8000-30000 72 Catalytic

x Country Flame Technologies, Inc. OV-3000 2.9 11800-34000 63 Non Catalytic

x Country Flame Technologies, Inc. BBF 3 10500-51400 72 Catalytic

x Country Flame Technologies, Inc. BBF-6, BBF-I 3 9500-48600 72 Catalytic

x Country Flame Technologies, Inc. O-2/90 3 10800-34100 72 Catalytic

x Country Flame Technologies, Inc. E-2 3.3 13000-34400 72 Catalytic

x Country Flame Technologies, Inc. R-6 3.3 13800-50700 72 Catalytic

x Country Flame Technologies, Inc. OV-2600 3.5 11500-33600 63 Non Catalytic

x Country Flame Technologies, Inc. SBF/A 3.6 8700-33600 72 Catalytic

x Country Flame Technologies, Inc. E1-6, E1-I 3.7 12400-55300 72 Catalytic

x Country Flame Technologies, Inc. OV-26BF-I 3.7 11400-41300 63 Non Catalytic

x Country Flame Technologies, Inc. OV-2100 4.1 11700-32700 63 Non Catalytic

x Country Flame Technologies, Inc. OV-21 4.2 11700-42200 63 Non Catalytic

x Country Flame Technologies, Inc. Inglenook INGW-02 4.4 11,600-38,000 63 Non Catalytic

x Country Flame Technologies, Inc. B-6, B-I 4.6 9600-48200 72 Catalytic

x Country Flame Technologies, Inc. NC-6D 4.7 11700-54900 63 Non Catalytic

x Country Flame Technologies, Inc. S-6, S-I 6.5 13100-48900 72 Catalytic

x Country Flame Technologies, Inc. Patriot 6.9 11300-34000 63 Non Catalytic

x Country Flame Technologies, Inc. Combo AirOC 7 9300-46400 63 Non Catalytic

Country Stoves, Inc. Winslow PS40 and PI40 1.14 7,476-21,343 78 Pellet Country Stoves, Inc. Striker S160 and C160 1.6 12500-41200 63 Non Catalytic Country Stoves, Inc. Canyon S310 3.2 11400-34900 63 Non Catalytic Country Stoves, Inc. Canyon ST310, C310, E310 3.5 11600-38800 63 Non Catalytic Country Stoves, Inc. Alpine 3.53 11,455-42,445 63 Non Catalytic Country Stoves, Inc. Converter C-30, C-35 4 8000-49200 72 Catalytic Country Stoves, Inc. Legacy S260, C260, and E260 4.11 11800-48000 63 Non Catalytic Country Stoves, Inc. Performer S210, SS210, ST210, C210 & E210 4.2 9500-36100 63 Non Catalytic Country Stoves, Inc. T-TOP S 240 4.9 11300-42700 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 3List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type Country Stoves, Inc. C-240 and E-240 5.1 11500-36700 63 Non Catalytic Country Stoves, Inc. STRIKER S130, C-50L, C130, CA-50, CA-50L, CA-55 5.6 9300-43600 63 Non Catalytic Country Stoves, Inc. T-Top C-40, C-45, C-46 5.7 10700-40900 63 Non Catalytic Country Stoves, Inc. Performer S180, C180, E180 6.6 11400-38700 63 Non Catalytic Country Stoves, Inc. Starlite C-20, C-21 9.6 7700-43500 63 Non Catalytic Country Stoves, Inc. Starlite C-20, C-21 9.6 7700-43500 63 Non Catalytic

x CRD Precision Fabricators Inc. (Chippewa) Energy King Legacy 2150 2.9 11800-34000 63 Non Catalytic

x CRD Precision Fabricators Inc. (Chippewa) Energy King Legacy 2100 3.2 11000-31100 63 Non Catalytic

x CRD Precision Fabricators Inc. (Chippewa) Energy King Legacy 1650 3.7 11400-41300 63 Non Catalytic

x CRD Precision Fabricators Inc. (Chippewa) Energy King Legacy 950 4.2 11700-42200 63 Non Catalytic

x CRD Precision Fabricators Inc. (Chippewa) Energy King Legacy 900 6.5 10200-30800 63 Non Catalytic

x CRD Precision Fabricators Inc. (Chippewa) Energy King Legacy 1600 7 11700-23100 63 Non Catalytic

x Dansons Incorporated Model HR-2 0.9 10500-33400 78 Pellet

x Dansons, Incorporated Eclipse 1 7800-33100 78 Pellet

x Dell Point Technologies DC 2000, Europa 0.6 10400-24100 78 Pellet

x Derco, Inc./Grizzly Stoves Super Achiever FPI-2-LEX 2.4 9800-34200 72 Catalytic

x Derco, Inc./Grizzly Stoves Little Blazer FP-20 4.7 7200-28400 72 Catalytic

x Derco, Inc./Grizzly Stoves Little Blazer FP-20 4.7 7200-28400 72 Catalytic

x Deville Deville 7794 - Comfort 6.9 11,300-35,100 63 Non Catalytic

x Dovre, Inc. Horizon 500 CC 2.9 10300-33800 72 Catalytic

x Dovre, Inc. Horizon 500 CC 3.6 8300-28000 72 Catalytic

x Dovre, Inc. Heirloom 300 HC 4.5 11600-45100 72 Catalytic

x Dovre, Incorporated Heirloom 390 2.8 9100-31800 72 Catalytic

England's Stove Works, Inc. 25-EP, 55-TRPEP, 55SHPEP 1.43 10,700-25,100 78 Pellet England's Stove Works, Inc. 10-CPM, 49-TRCPM, 49-SHCPM 1.6 10,455-24,566 78 Pellet England's Stove Works, Inc. 30-NC, 50-TNC30L, 50-TNC30G 1.63 11,950-28,337 63 Non Catalytic England's Stove Works, Inc. Model 18M-H 2 7800-26900 72 Catalytic England's Stove Works, Inc. 17-VL 4.3 11,875 - 19238 63 Non Catalytic England's Stove Works, Inc. Summers Heat Model 50-SHW20Englander Model 24JC 2.1 7200-28600 72 Catalytic England's Stove Works, Inc. Model 18 PC 2.2 8700-26400 72 Catalytic England's Stove Works, Inc. 13-NCMH, 50-SNC13, 2.35 11,579-32,017 63 Non Catalytic England's Stove Works, Inc. Englander Freestanding Radiant 24FC 2.4 7200-35600 72 Catalytic England's Stove Works, Inc. Summers Heat Model 50-SHW25Englander Model 24ICD 2.4 5400-17400 72 Catalytic England's Stove Works, Inc. Englander Front Loading Fireplace 28IC 2.5 8200-24400 72 Catalytic England's Stove Works, Inc. 50-TNC Timber Ridge 13-NCI/50-TNC131 (Insert) 2.6 10,000-29,200 63 Non Catalytic England's Stove Works, Inc. Englander 13-NC Summers Heat,50-snc Golden Eagle 2.6 10,000-29,200 63 Non Catalytic

England's Stove Works, Inc. Englander 25-PDV, Summers Heat 55SHP22, and Timber Ridge
55TRP22 Pellet 2.6 10,700-24,500 78 Pellet England's Stove Works, Inc. Model 24IC 2.6 10200-27100 72 Catalytic England's Stove Works, Inc. 24 ACD 2.7 9000-20100 72 Catalytic England's Stove Works, Inc. Englander Front Loading Space Saver 28CC 2.7 7900-25500 72 Catalytic

England's Stove Works, Inc. Pellet Fuel Burning Room Heater Model 25-PDCV/55-
SHP10/55-TRP10 3.1 8200-22400 78 Pellet England's Stove Works, Inc. Englander Econo Radiant 18PC 3.6 8500-31000 72 Catalytic

England's Stove Works, Inc. Summers Heat Model 50-SHW22Englander Model 24-AC/FC 3.8 9100-25400 72 Catalytic England's Stove Works, Inc. 17-VL 4.3 12,791- 43,520 63 Non Catalytic England's Stove Works, Inc. Englander Fireplace Insert 28JC 4.4 8400-29100 72 Catalytic England's Stove Works, Inc. 22 PIC 5.1 9000-30200 72 Catalytic

x Eureka Heating PTY Limited Emerald 4.4 11000-35500 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 4List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type

x Evergreen Marketing, Inc. Mohawk 60A 3.8 4700-14300 72 Catalytic

x Evergreen Metal Products Inc. Schrader Pelletmiser 905-P 1 11000-32700 78 Pellet

x F. Huemer Ges. M.B.H. Austroflamm Wega II 1.3 8500-42000 78 Pellet

Fireplace Products International Limited F1100S, I1100S I1200S , HI200, CS1200, CI1200, CI1250 Small
Wood Stove & Insert 3 10600-34700 63 Non Catalytic

Fireplace Products International Limited F2400M, I2400M, S2400, HI300, CC75, CS2400 Medium Wood
Stove & Insert 3.44 12000- 36800 63 Non Catalytic Fireplace Products International Limited H2100M Hearth Heater 3.5 10800-46900 63 Non Catalytic Fireplace Products International Limited FP90, EX90, R90 Wood Fireplace 3.78 11,700-42,300 63 Non Catalytic Fireplace Products International Limited F1100S, I1100S, F1100S-1 Small Wood Stove & Insert 3.8 09400-38700 63 Non Catalytic Fireplace Products International Limited F2100M, I2100M Medium Wood Stove & insert 3.8 11700-38700 63 Non Catalytic Fireplace Products International Limited F2100MI 3.9 11,300-38,800 63 Non Catalytic Fireplace Products International Limited H200 Cast Wood Stove 3.9 10,900 - 19,400 63 Non Catalytic Fireplace Products International Limited R6,RA6,RA8 Wood Stoves 3.9 11500-59000 63 Non Catalytic Fireplace Products International Limited F3100L, I3100L, S3100L, Large Wood Stove & Insert 4.19 11900-42900 63 Non Catalytic Fireplace Products International Limited H300 Cast Wood Stove 4.2 10,600-28,500 63 Non Catalytic Fireplace Products International Limited R3, RA3, R9 Wood Stove 4.2 11200-35500 63 Non Catalytic Fireplace Products International Limited I2000M14 Wood Insert 4.5 11200-42700 63 Non Catalytic Fireplace Products International Limited R14-2 5 11500-37500 63 Non Catalytic Fireplace Products International Limited Z2500L Wood Fireplace 5.2 10600-39700 63 Non Catalytic Fireplace Products International Limited R-16 Wood Insert 6.6 11100-32900 63 Non Catalytic Fireplace Products International Limited F2000M Medium Wood Stove 7.1 11800-34200 63 Non Catalytic Fireplace Products International Limited R7, RA7, R5 Small Wood Stove 8.3 5900-33500 63 Non Catalytic Fireplace Products International Limited F5100 1.46 11,738 - 41,982 79.08 72 Catalytic Fireplace Products International Limited GF55, GFI55 Regency Greenfire Pellet Stove & Insert 1.96 6,500-40,000 78 Pellet Fireplace Products International Limited GC60, GCI60 Hampton Cast Pellet Stove & Insert 2 9,363 - 45,478 78 Pellet Fireplace Xtrodinair (FPX) by Travis Industries, Inc. 36 Elite 2.3 11900-47100 72 Catalytic Fireplace Xtrodinair (FPX) by Travis Industries, Inc. 44 Elite 2.5 11000-45300 72 Catalytic Fireplace Xtrodinair (FPX) by Travis Industries, Inc 33 Elite 4.1 11,300-33,400 63 Non Catalytic
Foundries du Lion S.A. Efel Symphony 390.74 1.8 10700-33000 72 Catalytic
Foundries du Lion S.A. Harmony IIIB 2.7 11,200-57,300 63 Non Catalytic
Foundries du Lion S.A. Model S-33,S-83,H33,R33,X33 3.3 8,600-37,300 63 Non Catalytic
Foundries du Lion S.A. Efel Harmony 386.75 3.8 7100-51000 72 Catalytic
Foundries du Lion S.A. Harmony I 4.4 11800-55000 63 Non Catalytic
Foundries du Lion S.A. Efel Symphony 387.74 5.1 10600-49700 72 Catalytic Foyers Supreme Incorporated Supreme Plus 7 9,600-16,300 63 Non Catalytic Foyers Supreme Incorporated Volcano Plus 4.3 11,310-25,189 63 Non Catalytic Foyers Supreme Incorporated Galaxy 3.5 12,833 - 27,093 63 Non Catalytic Foyers Supreme Incorporated Superme 2 Face Plus, Opus 5 10,213-30,163 63 Non Catalytic

x Frantech, Inc. Seefire 2100 S 3.2 11000-31100 63 Non Catalytic

x Frantech, Inc. Seefire 900 S 6.5 10200-30800 63 Non Catalytic

x Frantech, Inc. Seefire 1600 S 7 11700-23100 63 Non Catalytic

GHP Group Pleasant Hearth HWS-224172MH-B; Pleasant Hearth HWS224172MH-BCA 5.1 11,638 - 22,444 63 Non Catalytic

GHP Group Pleasant Hearth LWS-127201-B; Pleasant Hearth LWS-127201-
BCA 4.3 9,238 - 16,744 63 Non Catalytic

GHP Group Pleasant Hearth LWS-130291-B; Pleasant Hearth LWS-130291-
BCA 3.6 12,084 - 37580 63 Non Catalytic

x Gibraltar Stoves, Inc. LCC, MCC, SCC, CFS, CFI & DDI 2.75 8400-28700 72 Catalytic

x GLG Australia Pearl Bay 3.8 11,300-35,300 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 5List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type Glo King/Pierce Engineered Products Inc. GK 100 HT 3.2 10600-61400 63 Non Catalytic Glo King/Pierce Engineered Products Inc. GK-500HT 6.4 10000-22400 63 Non Catalytic Glo King/Pierce Engineered Products Inc. 400HT 7 10000-40200 63 Non Catalytic Glo King/Pierce Engineered Products Inc. GK-300HT 7 11000-31000 63 Non Catalytic Glow Boy Model HR-2 0.9 10500-33400 78 Pellet Godin Imports, Inc. Nouvelle Epoque 3137 3.9 10500-20700 72 Catalytic Gruppo Piazzetta S.P.A. P960, P961, P962 1.98 10,000 - 38,500 78 Pellet Gruppo Piazzetta S.P.A. P955, P956, and P957 2.28 9,000 - 29,700 78 Pellet Gruppo Piazzetta S.P.A. Model 905 6.8 11600-30300 63 Non Catalytic Gruppo Piazzetta S.P.A. Sabrina, Sveva, Samanta, Siria 2.305 9,912 - 37,169 78 Pellet Gruppo Piazzetta S.P.A. Monia, Marcella, Marcella, Mia, Maira 2.15 9,912 - 37,169 78 Pellet Gruppo Piazzetta S.P.A. 904 7.5 6700-28300 63 Non Catalytic H.M.F. Forlong and Maisey Ltd. Merlin "3", M 3000 6.1 12300-37000 63 Non Catalytic Hajduk Prima MR-51 3.8 11,636-35,246 63 Non Catalytic Harman Stove Company TL 2.0 2.6 9,619 - 31,825 63 Harman Stove Company TL 2.6 3.7 11,281 - 32,657 63 Non Catalytic Harman Stove Company TL 300 1.1 11,238-34921 63 Non Catalytic Harman Stove Company Invincible RS 1.53 6200-32800 78 Pellet Harman Stove Company Oakwood 2.3 10,900-30,500 63 Non Catalytic Harman Stove Company Treemont TAC-340C 2.8 7400-33800 72 Catalytic Harman Stove Company CW30 3.6 10000-34000 63 Non Catalytic Harman Stove Company Treemont TAC-260C,TAC-260CF 3.9 8400-40700 72 Catalytic Harman Stove Company Model Exception TL200 4.4 11000-42400 63 Non Catalytic Harman Stove Company Treemont TAC-520C 5.2 12000-37300 72 Catalytic
Hase Kaminofenbau Lima 8150 3.57 11,805-31,653 63 Non Catalytic
Hase Kaminofenbau Bari, Lima 3.57 11,805-31,653 63 Non Catalytic

x Hawke Manufacturing Company, Inc. HMI 28II 2.6 6100-39600 72 Catalytic

Hearth and Home Technologies 5100I ACC 4.2 10,491 - 27,854 63 Non Catalytic Hearth and Home Technologies 4100I ACC 4.3 11696 - 25,925 63 Non Catalytic Hearth and Home Technologies Quadra-Fire 3100 ACC 1.1 11900-43200 63 Non Catalytic Hearth and Home Technologies Quadra Fire 4300 ACT 1.2 11900-58500 63 Non Catalytic Hearth and Home Technologies Quadra-Fire 3100 ACT & 3100I ACT 1.3 11400-46900 63 Non Catalytic Hearth and Home Technologies Quadra-Fire 5100 I ACT B 2 11,900-50,600 63 Non Catalytic Hearth and Home Technologies 2100 ACC 2.1 12000-28000 63 Non Catalytic Hearth and Home Technologies Quadra-Fire 3100F, 3100 I 2.1 11900-43200 63 Non Catalytic Hearth and Home Technologies Quadra-Fire 4300 2.1 11900-39900 63 Non Catalytic Hearth and Home Technologies Quadra-Fire 1900 2.2 11500-32200 63 Non Catalytic Hearth and Home Technologies Quadra-Fire Cape Cod 2.2 11500-43000 63 Non Catalytic Hearth and Home Technologies Quadra-Fire 5100-I Fireplace Insert 2.7 11800-49900 63 Non Catalytic Hearth and Home Technologies Yosemite 2.7 10900-28600 63 Non Catalytic Hearth and Home Technologies Quadra-Fire Isle Royale 2.9 10400-46800 63 Non Catalytic Hearth and Home Technologies Arrow 55 3 9900-37500 72 Catalytic Hearth and Home Technologies Quadra-Fire 7100 3.1 13,800-67,300 63 Non Catalytic Hearth and Home Technologies Heat N Glo Number FT-300 3.3 10,000-41,000 63 Non Catalytic Hearth and Home Technologies Northstar/Constitution 3.3 11,300-51,200 63 Non Catalytic Hearth and Home Technologies Quadra-Fire Cumberland Gap 3.4 11,200-44,300 63 Non Catalytic Hearth and Home Technologies Quadra-Fire 2100, 2100 I 3.6 9300-39300 63 Non Catalytic Hearth and Home Technologies Arrow S12 (Stove) & I12 (Insert) 3.7 9900-32100 63 Non Catalytic Hearth and Home Technologies Heat-N-Glo FT-210 3.9 9,800-36,600 63 Non Catalytic Hearth and Home Technologies Arrow 14, 20 4 14000-36100 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 6List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type Hearth and Home Technologies Quadra-Fire 4100 4 11700-50500 63 Non Catalytic Hearth and Home Technologies S-22 & S-22I 4 12000-36900 63 Non Catalytic Hearth and Home Technologies 5700 ACT/ Step Top 4.2 11800-45900 63 Non Catalytic Hearth and Home Technologies Model 2700I 4.2 11200-35900 63 Non Catalytic Hearth and Home Technologies Arrow S32 & I32 4.24 10800-47500 63 Non Catalytic Hearth and Home Technologies Arrow Fireplace Insert 25 4.7 11300-55000 72 Catalytic Hearth and Home Technologies Heatilator 11, 12 5.1 12400-36100 63 Non Catalytic Hearth and Home Technologies Quadra-Fire 1800 5.1 10600-31300 63 Non Catalytic Hearth and Home Technologies S10 and I10 5.9 11200-40600 63 Non Catalytic

Hearth and Home Technologies Heatilator 1190/Arrow 1490(S20)Heatilator 1290/Arrow 2090(I20) 6.1 10500-44500 63 Non Catalytic Hearth and Home Technologies Quadra-Fire 2000, 2000-I 6.1 7400-43700 63 Non Catalytic Hearth and Home Technologies Quadra-Fire 3000F, 3000 I 6.5 9000-44700 63 Non Catalytic Hearth and Home Technologies Arrow 18 7.2 14500-34400 63 Non Catalytic Hearth and Home Technologies 4300ACC 1.1 11,842-38,305 63 Non Catalytic Hearth and Home Technologies Heatilator ECO ADV WS22 2.7 11,733 - 26,957 63 Non Catalytic Hearth and Home Technologies Quadra Fire 5700 ACC 2.3 11,17 - 40,359 63 Non Catalytic Hearth and Home Technologies Voyageur 4.12 11,163 - 23,513 63 Non Catalytic Hearth and Home Technologies Quadra Fire 2100 Millinnium & 2100 ACT 2 10900- 37200 63 Non Catalytic Hearth and Home Technologies Summit Insert 3.15 10,732 - 25,578 63 Non Catalytic Hearth and Home Technologies Model 400 2.9 8700-2200 63 Non Catalytic Hearth and Home Technologies Quadra-Fire Model 4100I and Bodega Bay 3.1 9,000-41,800 63 Non Catalytic Hearth and Home Technologies Model 2590 3.8 9900-34300 72 Catalytic Hearth and Home Technologies Aurora Model 700 4.3 11800-30900 63 Non Catalytic Hearth and Home Technologies Quadra-Fire 1800 I 4.9 10000-33200 63 Non Catalytic Hearth and Home Technologies PH35PS 0.28 9,555 - 25,081 78 Pellet Hearth and Home Technologies PH50PS 0.74 9,256 - 32,396 78 Pellet Hearth and Home Technologies Heatilator ECO ADV WS18 2.6 10,925 -22,563 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Homestead 8570 1.9 10500-33600 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Shelburne 1 Model 8371 2.1 11,800-32,400 63 Non Catalytic

x Hearthstone Quality Home Heating Products Inc. Shelburne Model 8370 2.1 11,800-32,400 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Heritage 8090, Manchester 8330 1.3 15,320 - 31,200 78 Pellet Hearthstone Quality Home Heating Products Inc. Heritage 2.3 10700-29400 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Phoenix 8612 2.4 10500-41500 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Tula 2.55 11,455 - 29,301 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Heritage I, Model 8021 2.7 11,700-32,800 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Tribute Model 8040 3 10,600-28,300 63 Non Catalytic

x Hearthstone Quality Home Heating Products Inc. Craftsbury 8390 3.08 10,973-25,563 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Craftsbury 1 8391 3.08 10,973-25,563 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Clydesdale Model 8490, 8491 3.1 11,900-33,100 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Equinox 8000 3.1 12,000-37,900 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Bennington 3.6 11900-32600 63 Non Catalytic

` Hearthstone Quality Home Heating Products Inc. Starlet 3.6 9200-25400 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Mansfield 2 8012 2.9 11,370 -28, 940 63 Non Catalytic

x Hearthstone Quality Home Heating Products Inc. Mansfield 2.9 11,370 -28, 940 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Morgan model 8470 4.3 10500-29300 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Castleton 2.71 11,395 - 24,569 63 Non Catalytic Hearthstone Quality Home Heating Products Inc. Manchester 8360 3.01 11,335 - 47,509 63 Non Catalytic

x Heat Tech Industries No. 26 GM 4 11300-35800 63 Non Catalytic

x Heatilator, Inc. Heatilator LE 4.46 11500-44400 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 7List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type

x Heatilator, Inc. 1890(S30) 5.7 11200-42700 78 Pellet

x Heating Energy Systems, Inc. Trailblazer Genesis 1600/1800 3 11400-36400 63 Non Catalytic

x Heating Energy Systems, Inc. Trailblazer Genesis 2000-C 3.1 10600-37500 72 Catalytic

x Heating Energy Systems, Inc. Trailblazer Classic 1300/1306 3.2 11300-32400 72 Catalytic

x Heating Energy Systems, Inc. Trailblazer 1700/1706 4.6 11000-32400 63 Non Catalytic

x Heating Energy Systems, Inc. Trailblazer Classic 1500/1700 4.9 9500-36600 63 Non Catalytic

x Heating Energy Systems, Inc. Trailblazer Genesis 1600, Classic 1500 8.2 12100-28100 63 Non Catalytic

x Heat-N-Glo Fireplace Products, Inc. CBS-41 3.9 10000-30300 63 Non Catalytic

x HeatWorx LLC Independence 3.6 11,370 - 34,260 63 Non Catalytic

Henan Hi-Flame Horse Flame 737 4.9 11,200 - 37,500 63 Non Catalytic
Henan Hi-Flame Hi-Flame 4.9 10,500 - 30,501 63 Non Catalytic

x Heritage Stoves Inc. Bostonian 2500 C (Insert) 3.8 10600-22300 72 Catalytic

x Heritage Stoves Inc. American 2000C 5.5 13600-33800 72 Catalytic

x Heritage Stoves Inc. Bostonian 2500C 6.8 9600-37300 72 Catalytic

Hestia Heating Products Model HHP 1 2.89 7,900-30,200 78 Pellet Hestia Heating Products Model HHP 2 4.1 12,084-25,496 78 Pellet High Energy Manufacturing, Limited J1000 Pellet Stove 2.1 13,000 - 21,800 78 Pellet High Sierra Stoves, Ltd. Evolution 8000TE 2.2 7900-40500 72 Catalytic High Sierra Stoves, Ltd. Ambassador 4700TE 2.5 10100-37600 72 Catalytic High Sierra Stoves, Ltd. Sweet Home Catalytic Fir AK-18 3.1 8800-29500 72 Catalytic High Sierra Stoves, Ltd. Cricket MHCR 5200 3.5 6800-27600 72 Catalytic High Sierra Stoves, Ltd. Evolution 7000TE,7000C 4 11200-43000 72 Catalytic High Sierra Stoves, Ltd. Sweet Home Solitaire PFA 2000 4 9700-28200 78 Pellet High Sierra Stoves, Ltd. Diplomat 4300 TE 5.1 10400-53400 72 Catalytic High Sierra Stoves, Ltd. Sierra Classic 1500B 6.9 8600-34700 63 Non Catalytic High Sierra Stoves, Ltd. Sweet Home NFX-HT 7.8 14500-33200 63 Non Catalytic

x High Valley Construction & Maintenance Corp. Model 1600 2.7 11800-40400 63 Non Catalytic

x High Valley Construction & Maintenance Corp. High Valley Bay 2500 3.1 7700-40900 72 Catalytic

x High Valley Construction & Maintenance Corp. High Valley Model 1500 3.4 9400-34200 72 Catalytic

x High Valley Construction & Maintenance Corp. High Valley 2000, Craft Stove 2000 3.3 10800-43100 72 Catalytic

Hijos de Bartolome Fajardo S.L. Ronda 6.6 10,978 - 29,301 63 Non Catalytic Hijos de Bartolome Fajardo S.L. Antartida 5.5 11938 - 34,245 63 Non Catalytic
Hi-Teck Stoves Hi Teck H 2000C 3.6 12600-41400 72 Catalytic Hitzer, Inc. Glo King 500SD 6.4 10000-22400 63 Non Catalytic Hitzer, Inc. Glo King 300HT 7 11000-31000 63 Non Catalytic Hitzer, Inc. Glo King 400HT 7 10000-40200 63 Non Catalytic

x Horizon Research Inc. Model HR-2 0.9 10500-33400 78 Pellet

x Horizon Research Inc. Eclipse 1 7800-33100 78 Pellet

x Horizon Research Inc. Eclipse 1 7800-33100 78 Pellet

Horse Flame Metal USA, Inc. 517 HF 3.6 8.585-24,358 63 Non Catalytic Horse Flame Metal USA, Inc. 717 HF 6.6 11,400-28,857 63 Non Catalytic Horse Flame Metal USA, Inc. HF577DU 6.8 10,754-43,138 63 Non Catalytic Horse Flame Metal USA, Inc. 917HF, HF917UA 7.2 11842-30330 63 Non Catalytic
Hudson River Stove Works HR1-M, Hudson River Medium 7 11,900-19,700 63 Non Catalytic Hussong Manufacturin Company, Inc.(Kozy Heat) Olivia, Model Number OVL-PC 2.5 8,100-21,400 63 Non Catalytic Hussong Manufacturing Company, Inc. Kozy Heat Z 42 3.3 11500-35100 63 Non Catalytic

x Hutch Manufacturing Company DWI-42C-2 (EPA) 1.5 10700-52800 72 Catalytic

x Hutch Manufacturing Company DWI-42C 1.6 9800-54600 72 Catalytic

x Hutch Manufacturing Company HRD-27C Catalytic Freestanding 2.5 10300-56200 72 Catalytic

x Hutch Manufacturing Company HRS-18C Small Freestanding 2.9 10300-38400 72 Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 8List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type

x Hutch Manufacturing Company HRD-18C 4.5 9300-39100 72 Catalytic

HWAM Heat Design A/S Monet 3.4 10,996-26,221 63 Non Catalytic HWAM Heat Design A/S 3055 4.09 10,996-26,221 63 Non Catalytic J. A. Roby Mystere 6 12,900-24,200 63 Non Catalytic J. A. Roby Vulcain 6.09 9,501.-29180 63 Non Catalytic J. A. Roby Atmosphere 6.9 9,043 - 28,675 63 Non Catalytic J. A. Roby Evolution 6.9 9,043 - 28,675 63 Non Catalytic J. A. Roby Ultimate 7.1 9,501.-29180 63 Non Catalytic

x Jacuzzi Leisure Products, Inc. Gordon Elite S18XE 3 11300-31200 63 Non Catalytic

x Jacuzzi Leisure Products, Inc. Fraser Elite I, S407E, S408E, S409E 3.4 10000-37900 63 Non Catalytic

x Jacuzzi Leisure Products, Inc. Cabot Elite S17XE 4.5 11300-34400 63 Non Catalytic

x Jacuzzi Leisure Products, Inc. Campbell Elite S14XE 5.1 11000-31100 63 Non Catalytic

x Jacuzzi Leisure Products, Inc. JW1000L10, JW1000P10, DW1000, FW2400, S24 5.3 10600-26100 63 Non Catalytic

x Jacuzzi Leisure Products, Inc. Model Campbell II Elite S-24X & FW24 Series, CJW1000L02, 5.3 10600-26100 63 Non Catalytic

x Jacuzzi Leisure Products, Inc. Douglas Elite S131E, S132E; Mini Elite S111E,S112E 7.1 10400-22200 63 Non Catalytic

x Jayline Heating Ltd. Amzed Jayline Ukal U-12 2.9 9900-28200 63 Non Catalytic

x Jayline Heating Ltd. AMZED JAYLINE 1B AND FS 5.4 9500-40400 63 Non Catalytic

Jotul North America (Jotul U.S.A., Inc.) F602 CB 3.4 11,998 - 47,713 70.7 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) Firelight 12 2.4 10500-32100 72 Catalytic Jotul North America (Jotul U.S.A., Inc.) F370 2.58 10,978-29,048 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) F100 Nordic QT 3 7,700- 27,400 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) Jotul Oslo F-500 3 10900-35000 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) Alpha 350132 3.1 10100-33000 72 Catalytic Jotul North America (Jotul U.S.A., Inc.) Model Series 8 3.1 12600-33000 72 Catalytic Jotul North America (Jotul U.S.A., Inc.) F500 3.2 12000-34700 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) F118 CB 3.5 12,000-23,500 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) Model 3 TDIC-2 3.6 10900-30600 72 Catalytic Jotul North America (Jotul U.S.A., Inc.) Castine F400 3.8 11300-27800 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) F3CBII 3.8 11400-43500 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) Model 8 TDIC 3.8 10900-35100 72 Catalytic Jotul North America (Jotul U.S.A., Inc.) American Fireplace Stove 3TDC 4 8800-31700 72 Catalytic Jotul North America (Jotul U.S.A., Inc.) Model C350 4 11,500-34,200 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) Jotul F600 4.1 11,600-32,500 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) Firelight 12CB 4.4 13500-45900 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) C450, Tamarack 4.42 11,900-36,100 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) C550 CB 4.47 11,696-35933 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) Jotul Petite 4.52 10500-39900 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) Jotul Model 602 CB Classic 5.2 9700-42100 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) Model 3 CB 5.8 11900-58300 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) C550 7.14 12,034-36,669 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) F55 3.5 11,576 - 30,399 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) F45 2.31 11,576 -26,528 63 Non Catalytic Jotul North America (Jotul U.S.A., Inc.) 50TL 2.84 11,696 - 32,919 63 Non Catalytic JR Home Heating Products WPS 30 4.5 12,791 - 43,520 78 Pellet

Jydepejsan A/S Trendline, Soft Line, Fine Line, Zeus, Athene, Troja, Hera,
Avanti 3.9 11300- 28100 63 Non Catalytic Jydepejsan A/S H530 6.8 11,100-28,800 63 Non Catalytic Kalvin International and Company (HK) KWS1-M 7 11,900-19,700 63 Non Catalytic

x Kent Heating Limited Rose Bay KTXRB 3.6 10300 - 37500 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 9List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type

x Kent Heating Limited Catalytic Tile Fire 2 5900-24500 72 Catalytic

x Kent Heating Limited Ultima 2000S 4.5 11000-23000 63 Non Catalytic

x Kent Heating Limited Log Fire LPE 5.9 8900-28200 63 Non Catalytic

x Kent Heating Limited Tile Fire L.E.M. TLE-1 5.9 8500-38600 63 Non Catalytic

x Kent Heating Limited Tile Fire 2000, Ultima 2000 6.3 12500-21700 63 Non Catalytic

x Kent Heating Limited Sherwood L.E.M. XLE-1 6.5 9600-33400 63 Non Catalytic

x Kent Heating Limited Log Fire 2000 7 11200-23700 63 Non Catalytic

x Kent Heating Limited Sherwood 2000 8.1 13000-26600 63 Non Catalytic

Krog Iversen & Co. A/S DSA 4 1.1 10,500-27,900 63 Non Catalytic Krog Iversen & Co. A/S Basic 1 & 3 2.17 10032-17906 63 Non Catalytic Krog Iversen & Co. A/S Basic 4 2.2 10000-22100 63 Non Catalytic Krog Iversen & Co. A/S Andersen 8 2.9 11900-30100 63 Non Catalytic Krog Iversen & Co. A/S Scan 24 2.9 11300-22500 63 Non Catalytic Krog Iversen & Co. A/S Scan 47.2 3.1 10400 - 30900 63 Non Catalytic Krog Iversen & Co. A/S Scan 4.5 3.3 9,500-31,000 63 Non Catalytic Krog Iversen & Co. A/S Andersen 8.2 3.5 7,600-28,800 63 Non Catalytic Krog Iversen & Co. A/S Scan 60 3.97 8,700-27,430 63 Non Catalytic Krog Iversen & Co. A/S Scan 5.2 4.2 11800-26500 63 Non Catalytic Krog Iversen & Co. A/S Scan 10-A 4.4 11,600-37,700 63 Non Catalytic Krog Iversen & Co. A/S Model Scan 61 4.5 10,600-29,300 63 Non Catalytic Krog Iversen & Co. A/S Scan 20 5.1 9900-19000 63 Non Catalytic
Kuma Stove And Iron Works Aspen 4.1 11,689 - 24206 63 Non Catalytic
Kuma Stove And Iron Works Model Kuma 100/300/400 2.2 10100-52100 72 Catalytic
Kuma Stove And Iron Works Kuma K-300/K-400, K-100B 2.8 12100-65200 72 Catalytic
Kuma Stove and Iron Works Kuma Wood Classic Model HT-2 3.2 11300-48000 63 Non Catalytic
Kuma Stove and Iron Works Ashwood 3.3 11300-48000 63 Non Catalytic
Kuma Stove And Iron Works Tamarack 3.3 11300 -48000 73.5 63 Non Catalytic
Kuma Stove And Iron Works KTAM 4.42 11708 -24418 63 Non Catalytic
Kuma Stove And Iron Works Kuma Scott HT-1 3.5 11700-29800 63 Non Catalytic
Lennox Hearth Products Whitfield Fireplace/Hearth Stove 1 11000-35700 78 Pellet
Lennox Hearth Products Whitfield WP-1, III T, II-T, II-TC, Advantage Series 1 9100-37800 78 Pellet
Lennox Hearth Products WP-2 III T, II-TC, Advantage Series 1 9100-37800 78 Pellet
Lennox Hearth Products BELLA 1.01 11,202-25,925 78 Pellet
Lennox Hearth Products WINSLOW PS40 and PI40 1.14 7,476-21,343 78 Pellet
Lennox Hearth Products Whitfield Advantage WP-2 1.3 10900-35100 78 Pellet
Lennox Hearth Products STRIKER S160 and C160 1.6 12500-41200 63 Non Catalytic
Lennox Hearth Products Bayview II, 2000C,BV4000C, BV4000C-2 1.9 6600-40900 72 Catalytic

Lennox Hearth Products Traditions T300HT & T3000HTThe Earth Stove 1600HT,
1900HT-M 2.6 10700-37400 63 Non Catalytic
Lennox Hearth Products Bayview BV450C/BV400C-2 3 11000-48100 72 Catalytic
Lennox Hearth Products Bayview II BV4000 3.1 9200-42300 72 Catalytic
Lennox Hearth Products Model T200C 3.2 8500-34900 72 Catalytic
Lennox Hearth Products CANYON ST310, C310 3.5 11600-38800 63 Non Catalytic
Lennox Hearth Products 1003-C 3.7 11700-36800 72 Catalytic
Lennox Hearth Products Traditions T-100 3.8 8300-43800 72 Catalytic
Lennox Hearth Products MONTAGE 4.03 6,270-29,784 78 Pellet
Lennox Hearth Products Traditions T150C, T100SC 4.1 6500-35300 72 Catalytic
Lennox Hearth Products LEGACY S260, C260, and E260 4.11 11800-48000 63 Non Catalytic
Lennox Hearth Products PERFORMER SS210, ST210 and C210 4.2 9500-36100 63 Non Catalytic
Lennox Hearth Products 2800HT 4.5 11500-46700 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 10List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type
Lennox Hearth Products Brass Flame KS-805 5.3 9300-49800 63 Non Catalytic
Lennox Hearth Products Bayview BV400, BV450 5.5 11000-53700 72 Catalytic
Lennox Hearth Products Brass Flame KS-1005, KS-2000I 6 11800-44000 63 Non Catalytic
Lennox Hearth Products Brass Flame KS-805 6 9300-49800 63 Non Catalytic
Lennox Hearth Products KS-1005, SV-14; KS-2000, FI-15 6 9500-41100 63 Non Catalytic
Lennox Hearth Products Grandview 300 3.1 10,249-29,181 63 Non Catalytic
Lennox Hearth Products Grand View 230, Montake 230 3.6 11,214 - 28,216 63 Non Catalytic
Lennox Hearth Products Earth Stove c-1002, and Ranger 1500HT, 1400HT 6.6 11700-37000 63 Non Catalytic
Lennox Hearth Products 1000HT, 1100HT, 2000HT, 2200HT 8.3 6600-32200 63 Non Catalytic
Lennox Hearth Products ES2100 3.05 10,491 -30,387 63 Non Catalytic

x Lexington Forge SSI 30 3.47 11,000-30,600 63 Non Catalytic

x Lexington Forge SSW 30FTPB, SSW30FTAL, SSW30FTAPB 3.5 11,000-30,600 63 Non Catalytic

x Lexington Forge SSW30STAL, SSW30STAPB Savannah 3.5 11,000-30,600 63 Non Catalytic

x Lexington Forge Savannah SSW 20 and Windsor WCS20 3.76 11,000-45000 63 Non Catalytic

x Lexington Forge SSW40 4.3 11,963-35767 63 Non Catalytic

x Long Agribusiness Silent Flame Model 2058A 2.3 9600-30600 72 Catalytic

x Long Agribusiness Silent Flame Model 2062 2.4 9900-32600 72 Catalytic

x Long Agribusiness 2062 Catalytic freestanding/insert 3.3 10600-20700 72 Catalytic

x Long Agribusiness Silent Flame 2058 5.3 9000-27100 72 Catalytic

LOPI by Travis Industries, Inc Declaration, Walden insert 4.1 11,300-33,400 63 Non Catalytic LOPI by Travis Industries, Inc. Republic 1750, Endeavor and Revere Insert 1.94 9300-42200 63 Non Catalytic LOPI by Travis Industries, Inc. Leyden 2.4 10,700-33,900 63 Non Catalytic LOPI by Travis Industries, Inc. Liberty, Freedom Bay insert 2.6 12000-45100 63 Non Catalytic LOPI by Travis Industries, Inc. Freedom 3.6 11800-47500 63 Non Catalytic

LOPI by Travis Industries, Inc. ANSWER, ANSER insert, Republic1250 and Avalon Spokane 4.4 11600-38500 63 Non Catalytic

x Luap Associates, Inc. Eagle 2001 2.6 8400-55200 78 Pellet

Lucky Distributing Integra 3.6 10,024-31,268 78 Pellet Lucky Distributing Esprit, Viva and Taurus 4.4 11,817-32,263 63 Non Catalytic M. Texeira International, Incorporated Bef 520 H 6.4 11,721-25,859 63 Non Catalytic

x Martin Industries, Inc. C-92 2.4 7200-29500 72 Catalytic

x Martin Industries, Inc. Ashley APC2,APC2C; King KC2,KC2B; Atlanta AC2,AC2B 3 9700-27900 72 Catalytic

x Martin Industries, Inc. C-92 3 13900-35700 72 Catalytic

x Martin Industries, Inc. Ashley 3.8 5700-35300 72 Catalytic

x Martin Industries, Inc. Ashley APS5,APS5B; King KC5,KC5B; Atlanta AC5,AC5B 3.8 9400-35400 72 Catalytic

x Martin Industries, Inc. Ashley CAHF,CAHFB; King MCF,MCFB; Atlanta ACF,ACFB 4.8 9900-30000 72 Catalytic

x Martin Industries, Inc. C-92 5.3 5200-33200 72 Catalytic

Max Blank GmbH Florenz K0 2, Volterra, Padua, Atlanta BF 3.1 11,842-34,680 63 Non Catalytic
Max Blank GmbH Atlanta K02, Siena, Monza, Davos, Ravenna, Heidelberg 4.5 11,479-36,009 63 Non Catalytic
Max Blank GmbH Solero, Toulouse, Zitro, Rio, Memphis, Niagara, Fisco 4.5 11,479-36,009 63 Non Catalytic
Max Blank GmbH Mega K 03 5.14 10,500-33,000 63 Non Catalytic
Max Blank GmbH Bordeaux 5.6 10,129-34,342 63 Non Catalytic MCZ S.p.a. Cubic, Cosmo 1.3 7,428 - 27,053 78

MCZ S.p.a. Trendline, Soft Line, Fine Line, Zeus, Athene, Troja, Hera,
Avanti 1.3 7,428 - 27,053 78 MCZ S.p.a. Musa Air, Suite Air, Club Air, Sagar Air 1.3 7,428 - 27,053 78 Pellet MCZ S.p.a. Star Air, Ego, Air, Toba Air, Sagar Air 1.4 8,233-24,533 78 Pellet MCZ S.p.a. Nima Comfort Air, Club Comfort 1.8 9,704 - 31,758 78 MCZ S.p.a. Musa Comfort Air, Suite Comfrot Air 1.8 9,704 - 31,758 78 Pellet
Metal M.D.R. Inc. Model HE-1400, XE-1400, & XTD-1.5 4.3 10,800-34,000 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 11List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type
Metal M.D.R. Inc. XVR-III, XLT-III 7.5 11,900-35,000 63 Non Catalytic Monessan Hearth Systems Century/Dutchmaster FW and CDW 1 11,800-32,300 63 Non Catalytic Monessan Hearth Systems Merrimack, Essex 3.6 10,554 - 31,780 63 Non Catalytic Monessan Hearth Systems CJW2500X02, DW2500 and JW2500X10 4.7 9500-57800 63 Non Catalytic Monessan Hearth Systems CW2500X00, CW2500X02, JW2500X00, 4.7 9500-57800 63 Non Catalytic Monessan Hearth Systems Defiant 1975 2.3 9,600 - 26,600 63 Non Catalytic Monessan Hearth Systems FW247001 to FE247004 and JW1000PF1 5 11500-18900 63 Non Catalytic Monessan Hearth Systems JW1000L10 and JW1000P10, DW1000, FW2400, S24 5.3 10600-26100 63 Non Catalytic

Monessan Hearth Systems Model Campbell II Elite S-24X & FW24 Series, CJW1000L02, 5.3 10600-26100 63 Non Catalytic
Morso Jernstaberi A/S 2B Classic 3.9 10900 -23600 63 Non Catalytic
Morso Jernstoberi A/S 3112 and 3142 3.1 9,300-28,500 63 Non Catalytic
Morso Jernstoberi A/S Model 4600 3.2 11,100-25,600 63 Non Catalytic
Morso Jernstoberi A/S Squirrel 1410 ,1420,1440 3.3 9600-22000 63 Non Catalytic
Morso Jernstoberi A/S Owl 3410/3440 & 3450 3.5 8400-23600 63 Non Catalytic
Morso Jernstoberi A/S 7600 Series 3.6 10,000 - 21,300 63 Non Catalytic
Morso Jernstoberi A/S Model 4650 (Soapstone) 3.7 10,900-25,700 63 Non Catalytic
Morso Jernstoberi A/S Model 2040 3.8 11,100-40,100 63 Non Catalytic
Morso Jernstoberi A/S Model 7110 3.8 10,700-27,900 63 Non Catalytic
Morso Jernstoberi A/S 6100 4.1 11,117-22,000 63 Non Catalytic
Morso Jernstoberi A/S Model 2B 4.1 9,300-30,700 63 Non Catalytic
Morso Jernstoberi A/S Model 5660, 4.3 8,998- 50,078 63 Non Catalytic
Morso Jernstoberi A/S Panther Model 2110B 4.3 8,600-42,100 63 Non Catalytic
Morso Jernstoberi A/S Morso 1710 4.4 12,000-39,800 63 Non Catalytic
Morso Jernstoberi A/S 8140, 8142, 8147, 8151 and 8150 4.5 10,864-25,370 63 Non Catalytic
Morso Jernstoberi A/S Panther 2110 4.7 10300-60500 63 Non Catalytic
Morso Jernstoberi A/S Morso 7900 (7940, 7943, 7948, 7970, 7990) 4 11,600-26,705 63 Non Catalytic
Morso Jernstoberi A/S 8180 5.1 9,300-28,500 63 Non Catalytic
Morso Jernstoberi A/S 3600 Series 5.2 11,400-49,500 63 Non Catalytic

x National Steelcrafters of Oregon Breckwell W3000FS/W3000I 2.3 11600-33700 63 Non Catalytic

x National Steelcrafters of Oregon Craft Stove CB-4830 3.1 11600-41100 72 Catalytic

x National Steelcrafters of Oregon Craft Stove CB-4830, CB-300 3.1 11600-41100 72 Catalytic

x National Steelcrafters of Oregon Craft CB-4830 Insert 3.4 9100-22400 72 Catalytic

x National Steelcrafters of Oregon Craft Stove CB-4426 3.9 12100-35600 72 Catalytic

x National Steelcrafters of Oregon Craft Stove CB-4426, CB-26, CAT 44-1 3.9 12100-35600 72 Catalytic

x National Steelcrafters of Oregon Chateau NC24 5.4 14500-51000 63 Non Catalytic

x Navigator Stove Works, Inc. NSW-1 Sardine 3.5 11,400-19,400 63 Non Catalytic

Navigator Stove Works, Inc. Navigator NSW2 3.6 10500-28200 63 Non Catalytic New Buck Corporation (Buck Stove Corp.) Buck Bay Model 91 1.2 8,800-51,200 72 Catalytic New Buck Corporation (Buck Stove Corp.) New Buck/Carolina Model 17 1.2 8100-27900 72 Catalytic New Buck Corporation (Buck Stove Corp.) 94NC 3.81 11,390 - 42,200 63 Non Catalytic New Buck Corporation (Buck Stove Corp.) Buck Master 2.1 10,800-49,800 72 Catalytic New Buck Corporation (Buck Stove Corp.) 50PCV, 50PBay, 50CV, 50CBay, 50CD, 50BCV, 50BBay 2.5 10100-38000 72 Catalytic New Buck Corporation (Buck Stove Corp.) 41BCV, BBay, CD, CS, CV, CBAY, PCV, PCBAY 2.6 6900-27800 72 Catalytic New Buck Corporation (Buck Stove Corp.) MODEL XL-80 2.7 9200-40500 72 Catalytic New Buck Corporation (Buck Stove Corp.) Model 261 2.92 10271-32263 63 Non Catalytic New Buck Corporation (Buck Stove Corp.) Model 18 3.1 10000-22400 63 Non Catalytic New Buck Corporation (Buck Stove Corp.) Model 20, catalytic 3.2 10800-37500 72 Catalytic New Buck Corporation (Buck Stove Corp.) Bay Model 91 3.5 10400-50400 72 Catalytic New Buck Corporation (Buck Stove Corp.) Buck/Tharrington 74/T-74 3.6 11,600-41,400 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 12List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type New Buck Corporation (Buck Stove Corp.) Model 71 Freestanding/Insert Catalytic 3.6 13100-40200 72 Catalytic New Buck Corporation (Buck Stove Corp.) Regular Buck 27000-C 3.8 14700-25100 72 Catalytic New Buck Corporation (Buck Stove Corp.) Little Buck 26000-C 4 6800-38700 72 Catalytic New Buck Corporation (Buck Stove Corp.) Model 81/85 4.3 11900-45400 63 Non Catalytic New Buck Corporation (Buck Stove Corp.) Model 21 4.4 12,000-444,000 63 Non Catalytic New Buck Corporation (Buck Stove Corp.) Big Buck 28000-C 4.7 8500-39100 72 Catalytic New Buck Corporation (Buck Stove Corp.) Regular Buck 27000-CR 4.8 14700-30800 72 Catalytic New Buck Corporation (Buck Stove Corp.) Model 70 5 9800-31300 72 Catalytic New Buck Corporation (Buck Stove Corp.) Model 26 5.4 11900-42600 63 Non Catalytic New Buck Corporation (Buck Stove Corp.) Townsend III 6.2 11400-41200 63 Non Catalytic New Buck Corporation (Buck Stove Corp.) Buck Carolina/Tharington 51/T-51 6.7 11800-40900 63 Non Catalytic Newmac Manufacturing Incorporated Classic II Model NCM 120 3.04 10,700-27,000 63 Non Catalytic Newmac Manufacturing Incorporated Classic 1 EPA NC 100 E 4 10,632-26,986 63 Non Catalytic Newmac Manufacturing Incorporated WFA 70 2.72 11852 - 15922 63 Non Catalytic Newmac Manufacturing Incorporated Status EPA Model NS220 E 4.97 11,600-27,400 63 Non Catalytic

x NHC Inc. Model 3-C 2 7900-15000 72 Catalytic

x NHC Inc. Harvest A-HII catalytic 2.5 10500-36400 72 Catalytic

x NHC Inc. Mansfield I 2.9 13600-45300 63 Non Catalytic

x NHC Inc. Mansfield 3.2 10200-27900 63 Non Catalytic

x NHC Inc. Phoenix (Version 2) 3.4 10400-35200 63 Non Catalytic

x NHC Inc. Harvest HII 3.8 8800-28900 72 Catalytic

x NHC Inc. Phoenix 4.94 10300-43000 63 Non Catalytic

Nordpeis A/S Saturn A 6 10,100-25,000 63 Non Catalytic NU-TEC/Upland Distributors, Inc. Brenden BR-60 1.43 11000-29400 72 Catalytic NU-TEC/Upland Distributors, Inc. Upland Amity AM-40 2.6 10600-23600 72 Catalytic NU-TEC/Upland Distributors, Inc. Townsend Woodstove TN-25 2.7 10200-27500 72 Catalytic
NYSERDA XEOOS 2.4 11,519 - 27,432 63 Non Catalytic

x OK Doke, Ltd. Sweethearth Presidential 800/800XL 3.6 9900-20000 72 Catalytic

x Olsberg Hermann Everken, Gmbh Bristol OH-L 2.1 11,800-32,200 63 Non Catalytic

x Olsberg Hermann Everken, Gmbh Bristol OH-M 2.7 11,000-33,200 63 Non Catalytic

x Oregon Woodstoves, Inc. Model OS/1 1.4 7800-40000 72 Catalytic

x Oregon Woodstoves, Inc. #1, Design 01 2.7 9600-49700 72 Catalytic

x Orley's Manufacturing Company, Inc. Cougar G-225 2.7 9100-36200 72 Catalytic

x Orley's Manufacturing Company, Inc. Leopard U245,U246,UO245,UO246; Panther F245,F246 3.5 9100-39000 72 Catalytic

x Orrville Products, Inc. COUNTRY COMFORT CC160 2.9 11900-47800 63 Non Catalytic

x Orrville Products, Inc. CC250 3.5 13200-29800 72 Catalytic

x Orrville Products, Inc. Country Comfort CC325 3.5 18600-60600 72 Catalytic

x Orrville Products, Inc. CC 350 3.8 13700-68900 72 Catalytic

x Orrville Products, Inc. CC-185I and 165I 3.8 11500-48600 63 Non Catalytic

x Orrville Products, Inc. CC180 3.9 10700-57600 63 Non Catalytic

x Orrville Products, Inc. Country Comfort CC350 4.3 11200-29100 72 Catalytic

x Orrville Products, Inc. CC175 and CC155 4.4 10900-39200 63 Non Catalytic

x Orrville Products, Inc. Country Comfort CC160 5.25 11600-36500 63 Non Catalytic

x Orrville Products, Inc. CC185 and CC165 5.3 11300-46100 63 Non Catalytic

x Orrville Products, Inc. Country Comfort CC150, CC1000, CC150H 7.5 7200-23900 63 Non Catalytic

x Orrville Products, Inc. Country Comfort CC100 8.5 8700-33400 63 Non Catalytic

x Orrville Products, Inc. Country Comfort CC125 9.5 12300-27600 63 Non Catalytic

Osburn Manufacturing, Inc. Imperial 2000 4.6 9000-33000 63 Non Catalytic Osburn Manufacturing, Inc. 2200 5.7 10400-41500 63 Non Catalytic Osburn Manufacturing, Inc. 1050 6.9 10600-42900 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 13List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type Osburn Manufacturing, Inc. Imperial MKII, MKII Insert, Goldenaire 7 10700-51600 63 Non Catalytic Pacific Energy Fireplace Products Limited Neo 1.6 3.9 9161-34810 75 63 Non Catalytic

Pacific Energy Fireplace Products Limited Vista Series C, Vista Classic, Vista Artisan, Vista Insert, and
Alderlea T4 2.92 12400-26300 63 Non Catalytic Pacific Energy Fireplace Products Limited Alderlea T5, Super 27 Design D, Spectrum, Step D1 3.4 11000-34600 63 Non Catalytic

Pacific Energy Fireplace Products Limited Standard, Pacific Ins, Spectrum Classic and Fusion, ALT5INS, Super Insert 3.4 11000-34600 63 Non Catalytic

Pacific Energy Fireplace Products Limited Summit Series A, Summit Insert, Summit Classic and Alderlea
T6 3.6 10300-37500 63 Non Catalytic Pacific Energy Fireplace Products Limited S-27, Spectrum, Standard, Pacific 6.4 10600-36400 63 Non Catalytic Pacific Energy Fireplace Products Limited True North TN19 4.1 10,652 - 32923 63 Non Catalytic Pacific Energy Fireplace Products Limited FP30 2.68 11829-38556 63 Non Catalytic
Panda Wood Stoves UMF-400 5 7600-38300 72 Catalytic
Pellefier Inc. Venturi PVI-87 0.5 9000-31800 78 Pellet

x Polar Fireplaces Woodchief 300 E 4.8 11600-43700 63 Non Catalytic

x Polar Fireplaces Woodchief 400 E 5.1 11500-59000 63 Non Catalytic

x Precision Gas Technologies WS-250 4 11700-50500 63 Non Catalytic

PSG Distribution Inc. Caddy (duct furnace) 6.6 12000-52900 63 Non Catalytic Quality Craft QCPS - 28000 2.37 13,119 - 14,759 78 Pellet
Rais A/S Gabo Pina Vola 2.1 12,000-26,700 63 Non Catalytic
Rais A/S Malta, Bando and Bora 4.3 11400-32900 63 Non Catalytic
RAIS A/S Rondo, Mino II Steel and Mino II SST 4.3 11,431-22,561 63 Non Catalytic
RAIS A/S OPUS 5.7 11,479-21,630 63 Non Catalytic
Rais A/S Rais 60-A Insert 7.2 11600-51300 63 Non Catalytic
Ravelli /EcoTeck Laura / Veronica 3.87 8,500 - 44,000 78 Pellet
Ravelli /EcoTeck Sofia / Silvia 1.65 8,500 - 50,000 78 Pellet
Ravelli /EcoTeck Monica / Francesca 1.45 8,500 - 35,000 78 Pellet
Ravelli /EcoTeck Ilaria / Serena 4.4 8,500 - 44,000 78 Pellet

x Renfyre Stove Co./ Maco Enterprises, Inc. Fireview 2300 7 11700-27500 63 Non Catalytic

x Renfyre Stove Co./Maco Enterprises Inc. 5000 Combination Range Design #50001 5.5 13600-21600 63 Non Catalytic

x Renfyre Stove Co./Maco Enterprises, Inc 2800 3.4 11900-23700 63 Non Catalytic

x Renfyre Stove Co./Maco Enterprises, Inc Fireview Insert 2700 3.8 9400-27500 63 Non Catalytic

x Reverso Manufacturing, Ltd. Challenger MMX 2.6 11200-33800 63 Non Catalytic

x Riteway-Dominion Manufacturing Company, Inc. Dominion 005 4.5 7000-29100 72 Catalytic

x RJM Manufacturing, Inc Achiever FPI-1-LEX 2 7900-26700 72 Catalytic

x RJM Manufacturing, Inc. FPI-2-LEX/90 1.6 10300-36500 72 Catalytic

x RJM Manufacturing, Inc. Energy King Bay 2000C 2.5 11400-34600 72 Catalytic

x RJM Manufacturing, Inc. Energy King 2500C 3 16100-39800 72 Catalytic

x RJM Manufacturing, Inc. Model Silhouette 2850C 3.2 8100-34700 72 Catalytic

RSF / Industrial Chimney Company, Incorporated Opel 2000C, OPEL AP 3.7 10600-49700 72 Catalytic RSF / Industrial Chimney Company, Incorporated TOPAZ/CHAMELEON (Without Fan), TOPAZ, Chameleon 4 11100-25700 63 Non Catalytic RSF / Industrial Chimney Company, Incorporated HT (Onyx), ONYX AP 4.5 11800-35600 63 Non Catalytic RSF / Industrial Chimney Company, Incorporated TOPAZ/CHAEMELON (With Fan) 5.5 9500-25800 63 Non Catalytic RSF / Industrial Chimney Company, Incorporated Ardent HF 40 9.9 6400-30600 63 Non Catalytic Russo Products, Inc. W-25C 2.4 8400-31300 72 Catalytic Russo Products, Inc. GV-30S 2.5 9500-38700 72 Catalytic Russo Products, Inc. Russo Glassview GV-21 2.9 10200-29600 72 Catalytic Russo Products, Inc. GV-30C 3.1 10300-39400 72 Catalytic Russo Products, Inc. W-18C 6.2 7900-40900 72 Catalytic Salvo Machinery, Inc. Model Citation 2.4 9600-33500 72 Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 14List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type

x Salvo Machinery, Inc. Citation Classic W45NC/WI45NC 7.1 11800-32200 63 Non Catalytic

x Sarratt Agencies Limited Merlin 3 FS-15, IS-15 6.1 9800-21100 63 Non Catalytic

x Saxon Wood Heaters Pty, Ltd. Rosewood 2.7 11600-36200 63 Non Catalytic

Security Chimneys International Ltd. BIS Ultima, Brentwood, BIS Tradition CE, and Montecito 3.692 10,442-27,746 63 Non Catalytic Security Chimneys International Ltd. BIS Panorama, Villa Vista 4.1 10900-35,600 72 Catalytic Security Chimneys International Ltd. BIS Nova, Ladera 4.8 8,700-25,700 63 Non Catalytic Security Chimneys International Ltd. BIS Ultra 5.1 11033-46700 63 Non Catalytic Security Chimneys International Ltd. BIS II 5.3 11300-41500 63 Non Catalytic Security Chimneys International Ltd. BIS Design No. 1.2 5.5 14200-55800 63 Non Catalytic Security Chimneys International Ltd. BIS Tradition and Montecito Estate 7.3 11,500-39-300 63 Non Catalytic

x Selkirk Canada Corporation Model: HE36 0.97 6,668-15,290 63 Non Catalytic

x Selkirk Canada Corporation Model HE40 5.7 11,383-45,459 63 Non Catalytic

Seraph Industries Genesis 106 2.1 11,100 - 45,100 83.2 78 Pellet Seraph Industries Genesis 108 2.1 11,100 - 45,100 83.2 78 Pellet Sherwood Industries, Ltd. CH-77, CH-84 3.1 8000-33800 72 Catalytic

Sherwood Industries, Ltd. Envirofire EF2, EF2i, FS and FPI, Hudson River Davenport
FS/FPI 1.25 6,500-34,000 78 Pellet Sherwood Industries, Ltd. Boston 1700 4.5 8000- 65000 63 Sherwood Industries, Ltd. Boston 1200 3.3 6500- 74000 63 Sherwood Industries, Ltd. Mini 1.6 22,585-30,113 78 Pellet Sherwood Industries, Ltd. Empress FS 1.86 27,827-35,675 78 Pellet Sherwood Industries, Ltd. EMPRESS FPI, Milan FPI 1.88 25,709-30,058 78 Pellet

Sherwood Industries, Ltd. Envirofire - EF3 FS, FPI, EF3Bi FS, Vista Flame VF100 FS 1.96 6,500-40,000 78 Pellet Sherwood Industries, Ltd. Envirofire - Meridian FS & FPI 1.96 6,500-40,000 78 Pellet Sherwood Industries, Ltd. Greenfire GF55, GFI55 1.96 6,500-40,000 78 Pellet Sherwood Industries, Ltd. EF 3, Meridian and VF 100 2 6,500-40,000 78 Pellet Sherwood Industries, Ltd. M55, M55C, V55 2 9,263-45,478 78 Pellet Sherwood Industries, Ltd. Meridian 2.24 32,566-42,963 78 Pellet Sherwood Industries, Ltd. Vista Flame 2100 FS, Envirofire 2100 FS 2.9 11800-34000 63 Non Catalytic Sherwood Industries, Ltd. osburn 3.18 52,453-60,992 78 Pellet Sherwood Industries, Ltd. Vista Flame Envirofire 2000 3.2 11000-31100 63 Non Catalytic Sherwood Industries, Ltd. Enviro 1200, 1200I, Vista Flame 1200, 1200I, 1200 Venice 3.3 11,500-34,200 63 Non Catalytic

Sherwood Industries, Ltd. Vista Flame 1600 FS, 1600 FPI, Envirofire 1600 FS, 1600 FPI 3.5 11500-33600 63 Non Catalytic Sherwood Industries, Ltd. Enviro Fire 1000FS and Vista Flame 1000FS, 1000 4.1 11700-32700 63 Non Catalytic

Sherwood Industries, Ltd. Enviro Model 1700I, 1700 & Vista Flame 1700I, 1700, 1700
Venice 4.5 9,400-31,800 63 Non Catalytic Sherwood Industries, Ltd. Mini 1.6 8,378 - 23,488 63 Non Catalytic Sherwood Industries, Ltd. Vista Flame Envirofire 1000 6.5 10200-30800 63 Non Catalytic Sherwood Industries, Ltd. Vista Flame Envirofire 1500 7 11700-23100 63 Non Catalytic

x Sierra Products, Inc. Sierra Evolution 8000 TEC 2.5 9700-35900 72 Catalytic

x Sierra Products, Inc. Evolution Model 7000C 2.8 7700-29400 72 Catalytic

x Sierra Products, Inc. Sierra Ambassador 4700 TEC 3.2 10800-42600 72 Catalytic

x Sierra Products, Inc. EF-2100 5.7 11,000-42,900 63 Non Catalytic

x Sierra Products, Inc. Sweet Home AFX-HT, AFI-HT 6.4 11300-28200 63 Non Catalytic

x Sierra Products, Inc. Cricket 5300 6.6 11000-36400 63 Non Catalytic

x Sierra Products, Inc. Sierra Classic 1500T 7.5 6900-34600 63 Non Catalytic

Stove Builder International Inc. BIO-45MF, Eco-45, FP-45, Hybrid-45MF 1.2 8,569-29,784 78 Pellet

x Stove Builder International Inc. Emerald 2000 1.7 7500-24500 78 Pellet

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 15List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type
Stove Builder International Inc. BIO-35MF, Eco-35, FP-35, Hybrid-35MF 1.77 6,668-15,290 78 Pellet
Stove Builder International Inc. Osburn 1100, Osburn 1100-I 2.9 11,000- 35,000 63 Non Catalytic
Stove Builder International Inc. Caddy, Alterna 4.2 10,142 - 71.014 78 Pellet
Stove Builder International Inc. FW3000 3.5 11,800-32,400 63 Non Catalytic

Stove Builder International Inc. HT 1600-Standard/HT 1600 Deluxe, HT-1600 Siberian, Ashley
1600 3.5 11200-26400 63 Non Catalytic
Stove Builder International Inc. Osburn 2400 B 3.5 11900-40900 63 Non Catalytic
Stove Builder International Inc. Osburn 2400-I, Osburn 2400 FS 3.5 11,900-40,900 63 Non Catalytic
Stove Builder International Inc. Euromax, Eco-65 2.58 6,873-34,727 78 Pellet
Stove Builder International Inc. HT-2000 Standard/HT-2000 Deluxe/HT-2000 3.9 11600-60300 63 Non Catalytic
Stove Builder International Inc. HT2000, Solution 3.4, Ashley 2000 3.9 11,600-38,700 63 Non Catalytic
Stove Builder International Inc. 1600 4.4 11800-42400 63 Non Catalytic

x Stove Builder International Inc. Monaco 2008 4.4 11479-30,450 63 Non Catalytic

Stove Builder International Inc. Monaco, Stratford, Solution 2.5, Lafayette 4.4 11,479-30,450 63 Non Catalytic
Stove Builder International Inc. Osburn 1600, Osburn 1600-I, Ashley 4600, Forrester 4700 4.4 11,800-42,400 63 Non Catalytic

x Stove Builder International Inc. 1600 B-I/Ashley 4600/Forester 4700 4.8 11900-35500 63 Non Catalytic

Stove Builder International Inc. S244, Pyropak, Osburn 900 5.3 10,600-26,100 63 Non Catalytic

Stove Builder International Inc. Gemini 1500 (With Blower), Adirondack, Savannah, Eldorado, Jurassien, Celtic, Osburn 1500 6.2 11500-43900 63 Non Catalytic

Stove Builder International Inc. HE-1800,Escape 1800, Solution 2.3, Solution 2.3-I, XTD1.9, XTD1.9-I, Osburn 2000, Osburn 2000-I, Dundee 1.9 6.3 11,600-38,700 63 Non Catalytic
Stove Builder International Inc. HT-1200 and Ashley 1200 6.5 8300-36000 63 Non Catalytic
Stove Builder International Inc. HT1200, Ashley 1200 6.5 8,300-36,000 63 Non Catalytic

Stove Builder International Inc. Gemini 1500 (Without Blower), Adirondack, Savannah, Eldorado, Jurassien, Celtic, Osburn 1500 7.5 11100-37300 63 Non Catalytic

Stove Builder International Inc. XTD1.5, XTD1.5-I, Solution 1.8, Solution 1.8-I, Escape 1400-I, Blackcomb, Columbia 4.3 10,800-34,000 63 Non Catalytic
Stove Builder International Inc. 1.6 Series 4.02 10,852 - 23,272/33 63 Non Catalytic
Stove Builder International Inc. 1.3 Series 3.99 9,887 - 21.825 63 Non Catalytic Stove Builder International, Inc. Osburn 1800, Osburn 1800-I 2.7 9700-36300 63 Non Catalytic Stove Builder International, Inc. Osburn 2200, Osburn 2200-I 2.7 11700-30400 63 Non Catalytic Stove Builder International, Inc. Apollo, Apollo II 3.6 10600-24700 63 Non Catalytic Stove Builder International, Inc. Le Chancelier, NXT-1 and Solution 2.9, Glencoe 2.1 4.4 11900-29400 63 Non Catalytic

x Stove Builder International, Inc. LeBachelier 4.9 11800-24500 63 Non Catalytic

Stove Builder International, Inc. New Generation NG 1800/Magnolia 2015 5.7 11,500-30,800 63 Non Catalytic Stove Builder International, Inc. Osburn 1100 5.7 11000-35000 63 Non Catalytic

Stove Builder International, Inc. XVR-II, XT-1400 adn XLT-II, Eastwood 1500, Jasper, Clyde 1.6 5.9 11800-27300 63 Non Catalytic Stove Builder International, Inc. XVR-I, XLT-1, Classic, Eastwood 1800 6.9 11,400-27,500 63 Non Catalytic Stove Builder International, Inc. XVR-III, XLT-III, Eastwood, 1900, Millenia 7.4 11,900-34,700 63 Non Catalytic Stove Builder International, Inc. Sahara, Kyle 2.0 7.5 11,000-25,700 63 Non Catalytic StoveBuilder International, Inc. FP-8, Saguenay 4 10,900 -36,900 63 Non Catalytic StoveBuilder International, Inc. FP-9i 4.2 11,600-38,700 63 Non Catalytic StoveBuilder International, Inc. FW2700, Deco, Optima 4.4 11,000-69,500 63 Non Catalytic StoveBuilder International, Inc. CW2500, Solution 2.0-I 4.7 9,600-57,800 63 Non Catalytic StoveBuilder International, Inc. FW2470 5 12,000- 28,500 63 Non Catalytic

StoveBuilder International, Inc. Legend, Baltic, Austral, Myriad, Azimuth, Osburn 2300, Magnolia
2015 5.7 11,500-30,800 63 Non Catalytic StoveBuilder International, Inc. Model HE-1800, XE-1800 & XTD-1.9 5.9 11600-38700 63 Non Catalytic StoveBuilder International, Inc. Mini-Caddy 6 10,900-36,900 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 16List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type StoveBuilder International, Inc. Eurostar, Osburn 5000 2.18 10.301 - 30,456 78 Pellet StoveBuilder International, Inc. XTD1.1, XE-1000, Solution 1.6 6 9900-47300 63 Non Catalytic StoveBuilder International, Inc. 2.3 Series 3.89 11,600 - 32,200 63 Non Catalytic StoveBuilder International, Inc. Caddy, Caddy-on, Tundra, Heatmax 6.6 12,000-52,100 63 Non Catalytic
Stove Builder International Inc. Olympia 4.6 9,659-26,407 72 Catalytic
Stove Builder International Inc. Evolution 3.5 8588 - 37,513 63 Non Catalytic
Stove Builder International Inc. Malibu 1700/2200 4.97 11,700-29.700 63 Non Catalytic
Stove Builder International Inc. Rustic 2100 and Tradition 2100 4.97 11,700-29,700 63 Non Catalytic
Stove Builder International Inc. Diamant, Diamante Insert 7.5 11,100-26,100 63 Non Catalytic
Stove Builder International Inc. Rustic/Tradition 1600 3.5 8588 - 37,513 63 Non Catalytic
Stove Builder International Inc. EverestEtna/Equinox/Malibu 2000 5.6 12,588 - 37,513 63 Non Catalytic
Stove Builder International Inc. EverestEtna/Equinox/Malibu 2500 5.9 12,588 - 37,513 63 Non Catalytic
Stuv S.A. 30 Compact 2.79 12,129 - 16,640 63 Non Catalytic

x Suburban Manufacturing Company Woodchief W6-88C, Woodmaster W6-88WC 3.4 9500-42500 72 Catalytic

TEC Enterprises 2000 pellet stove 4.7 11600-22500 78 Pellet Thelin Company Inc. Little Gnome Pellet Stove 3.28 3100-8400 78 Pellet Thelin Company Inc. Thelin T-4000 3.6 9,900-38400 63 Non Catalytic Thelin Company Inc. Providence, Providence Signature 1.2 12,839 - 35,680 78 Pellet

x Thermic Distribution Europe Efel Symphony 390.74 1.8 10700-33000 72 Catalytic

x Thermic Distribution Europe Harmony IIIB 2.7 11,200-57,300 63 Non Catalytic

x Thermic Distribution Europe Model S-33,H33,R33,33 3.3 8,600-37,300 63 Non Catalytic

x Thermic Distribution Europe Efel Harmony 386.75 3.8 7100-51000 72 Catalytic

x Thermic Distribution Europe Harmony I 4.4 11800-55000 63 Non Catalytic

Thermic Distribution Europe S43, H43, SP43, C43 4.17 12,500-39,275 63 Non Catalytic

x Thermic Distribution Europe Efel Symphony 387.74 5.1 10600-49700 72 Catalytic

x Thermic, Inc. Crossfire FS-1 0.5 6900-39900 78 Pellet

x Tianjin Berkeley Furniture Corporation TR 001 4.18 9200-28300 63 Non Catalytic

Travis Industries, Inc. Small Flush Wood Hybrid Fyre 0.89 9,784-31,428 76.51 72 Catalytic

x Travis Industries, Inc Avalon Cottage/Mission 2.9 11600-36500 63 Non Catalytic

x Travis Industries, Inc Lopi Sheffield 3.9 10,300-34,400 63 Non Catalytic

x Travis Industries, Inc Flush Wood A Fireplace Insert 4.1 11,300-33,400 63 Non Catalytic

x Travis Industries, Inc Lopi Flawless Performance 380, 440 7 6900-48700 63 Non Catalytic

Travis Industries, Inc. Avalon Spokane 1750 380-NT & X-NT 1.94 9300-42200 63 Non Catalytic

x Travis Industries, Inc. Flush Wood 2.45 12,084 - 29,605 63 Non Catalytic

Travis Industries, Inc. Lopi Endeavor, Lopi Revere , Lopi Republic 1750, 1.94 9300-42200 63 Non Catalytic Travis Industries, Inc. Avalon Rainier 90/Rainier 45 2 11200-40000 63 Non Catalytic Travis Industries, Inc. Fireplace Xtrordinair Elite 36 Z.C. & B.I. 2.3 11900-47100 72 Catalytic

x Travis Industries, Inc. Model 44-A BI and Z.C. 2.3 10700-75700 72 Catalytic

Travis Industries, Inc. Leyden and Avalon Arbor 2.4 10,700-33,900 63 Non Catalytic Travis Industries, Inc. Fireplace Xtrordinair 44 Elite 2.5 11000-45300 72 Catalytic Travis Industries, Inc. Avalon Olympic,Liberty, Freedom Bay 2.6 12000-45100 63 Non Catalytic

x Travis Industries, Inc. Lopi Flex FS, FL, LX 2.9 10900-31000 72 Catalytic

Travis Industries, Inc. Avalon Pendelton 90/Pendelton 45 3 8700-44400 63 Non Catalytic

x Travis Industries, Inc. LOPI Answer/Patriot (Formerly Answer-NT) 3.3 12000-41000 63 Non Catalytic

x Travis Industries, Inc. Avalon 1000C2 3.5 7300-47100 72 Catalytic

x Travis Industries, Inc. Model 36 F 4 11900-55000 72 Catalytic

x Travis Industries, Inc. Fireplace Xtrordinair Model 36A 4.1 10300-54700 72 Catalytic

x Travis Industries, Inc. Flex-95 FL, LX, and FS 4.1 10900-55300 72 Catalytic

x Travis Industries, Inc. Lopi Elan E1, E2 4.3 11700-26300 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 17List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type

Travis Industries, Inc. ANSWER/LOPI PATRIOT/LOPI PARLOR, Republic1250 and Avalon Spokane, Avalon Camano 4.4 11600-38500 63 Non Catalytic

x Travis Industries, Inc. Avalon 901 5.2 7500-45500 63 Non Catalytic

x Travis Industries, Inc. LOPI 380-96 5.2 9400-52800 63 Non Catalytic

x Travis Industries, Inc. Avalon 996 5.5 9500-45600 63 Non Catalytic

x Travis Industries, Inc. Avalon 700 5.9 9200-39100 63 Non Catalytic

x Travis Industries, Inc. Lopi X Fireplace Insert 6 13600-29100 63 Non Catalytic

x Travis Industries, Inc. Lopi The Answer 6.7 10500-63100 63 Non Catalytic

x Travis Industries, Inc. Lopi Premiere Answer Series PA1, PA2, PA3, PA4,PA5 7 8000-31500 63 Non Catalytic

x Travis Industries, Inc. Lopi X/96 7.2 11600-53900 63 Non Catalytic

x Travis Industries, Inc. Avalon 1196, Lopi 520/96, Flush Bay-96 7.4 11300-43600 63 Non Catalytic

x Travis Industries, Inc. Lopi Elan-96 7.4 12000-51400 63 Non Catalytic

Travis Industries, Inc. LG Flushwood Insert Hybrid - Fyre 0.58 8544-35278 80.3 72 Catalytic Travis Industries, Inc. Cape Cod 0.45 10,749 - 39,413 80.1 72 Catalytic Travis Industries, Inc. Flushwood Plus 4.4 12000 - 29600 72 Non Catalytic

x Tri-Fab, Inc. SunRise P-54 & SunRise PIL-8 5 10600-26500 63 Non Catalytic

x Tri-Fab, Inc. SunRise P-48-H, P-48-L 5.5 11700-25800 63 Non Catalytic

x Tri-Fab, Inc. SunRise P56 6.2 10700-39700 63 Non Catalytic

Tulikivi Oyj Tulikivi Maxi XV 2 4.22 12,058-38,224 63 Non Catalytic Tulikivi Oyj Tulikivi MINI XV 1 4.51 12,100-38,200 63 Non Catalytic United States Stove Company Ashley CAHF-2, Atlanta ACF-2, King MCF-2 1.6 12,800 - 38.900 72 Catalytic United States Stove Company Ashley AHS2, AHS2B; King KHS2 1.9 13700-34300 72 Catalytic United States Stove Company 2500 ST 3.1 11,576 - 36,295 63 Non Catalytic United States Stove Company Country Hearth 2200I 5.4 27,136 - 69,000 63 Non Catalytic United States Stove Company Ashley AFS24, King K3, cat., freestanding/insert 2.6 10300-34600 72 Catalytic United States Stove Company Forester Model 5824 4.6 7,775 - 15,974 63 Non Catalytic United States Stove Company Clayton Mfg Clay 60B, 70 2.7 12100-54300 72 Catalytic United States Stove Company Ashley C-92 3 11000-36900 72 Catalytic United States Stove Company Wonder Wood (Glass Front) 2921, Sears 143.8417 3.3 12500-54600 72 Catalytic United States Stove Company Bay Insert 4500 3.7 9600-30700 72 Catalytic United States Stove Company Wonder Wood 6000, 2821, Sears 143.8404 3.7 9100-18700 72 Catalytic United States Stove Company ASHLEY NCA-1/KING KPS 7.16 6500-23200 63 Non Catalytic United States Stove Company 6039, 6039 T, 6039 HF, 6039 TP, 6041 1.5 8,528-29,921 78 Pellet United States Stove Company 5500M, 5500XL, 5500XLT 1.6 9,126-27,677 78 Pellet United States Stove Company Model 2500, SW3100 3.06 10,100-25,000 63 Non Catalytic United States Stove Company APS 1100B 5.9 10,100-25,000 63 Non Catalytic United States Stove Company 2000, SW2100 3.69 11,817 - 31,713 63 Non Catalytic United States Stove Company 2400 1.13 7,315 - 14,033 72 Non Catalytic United States Stove Company 3000 (AFS7500), SW4100 1.9 11,624 - 38,140 63 Non Catalytic United States Stove Company 3000 FT 1.9 11,624 - 38,140 63 Non Catalytic United States Stove Company Breckwell W3000FS/W3000I 2.3 11,600 - 33,700 63 Non Catalytic United States Stove Company Vogelzang, Ashley, King (5770, VG5770) 3.17 10,898-24,335 78 Pellet United States Stove Company Breckwell (SW740) 2.47 11,057-36,681 63 Non Catalytic Vermont Castings Encore 2040 1.6 9,975 – 33,963 63 Non Catalytic Vermont Castings Defiant Encore 0.6 6200-32900 72 Catalytic Vermont Castings Encore 1450 N/C 0.7 10,600-24050 63 Non Catalytic Vermont Castings Defiant 1910 & 1945 0.8 10600-44400 72 Catalytic Vermont Castings 2370 1 5700-18300 72 Catalytic Vermont Castings Century/Dutchmaster FW and CDW 1 11,800-32,300 63 Non Catalytic Vermont Castings Dutchwest Small Convection Heater #2460 1.1 6600-27300 72 Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 18List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type Vermont Castings Dutchwest Extra Large Convection 2462 1.3 8300-28000 72 Catalytic Vermont Castings FA455 1.3 10400-26500 72 Catalytic Vermont Castings DutchWest Large 2479 1.31 11,300-26,500 63 Non Catalytic Vermont Castings Dutchwest Large Convection Heater (Model 2461) 1.41 10700-29500 72 Catalytic Vermont Castings DutchWest Small Model 2460 1.41 7,800-25,100 63 Non Catalytic Vermont Castings DutchWest Medium 2478 1.5 10,600-25,300 63 Non Catalytic Vermont Castings C.D. Lg. Fed. Convection Heater FA264CCL, FA264CCR 1.6 6600-26700 72 Catalytic Vermont Castings Defiant Encore 2550 (Formerly 2190) 1.6 8700-41700 72 Catalytic Vermont Castings Defiant Encore 2140 1.8 9000-41300 72 Catalytic Vermont Castings Intrepid II Model 1990 2.1 8300-26700 72 Catalytic Vermont Castings Model 2170 2.1 9400-22800 72 Catalytic Vermont Castings WinterWarm Fireplace Insert Model 1280 2.1 10300-30000 72 Catalytic Vermont Castings WinterWarm Small Insert Model 2080 2.1 8700-31100 72 Catalytic Vermont Castings FA264 2.2 9500-31700 72 Catalytic Vermont Castings Intrepid II Model 2070 2.4 9200-19300 72 Catalytic Vermont Castings Model EWF 36A 2.4 11,300-75,500 72 Catalytic Vermont Castings C.D. Extra-Lg. Federal Convection Heater FA288CCL 2.6 8400-38700 72 Catalytic Vermont Castings EWF36 2.7 11,800-68,600 72 Catalytic Vermont Castings C.D. Small Federal Convection Heater FA224CCL 2.8 7000-30600 72 Catalytic Vermont Castings C.D. Rocky Mountain Heater FA211CL 2.9 6800-27800 72 Catalytic Vermont Castings Montpelier 2.9 10,094-27,550 63 Non Catalytic Vermont Castings Montelier/Stratton 2.9 10094-2727550 63 Non Catalytic Vermont Castings Vermont Castings Defiant 1610 2.9 10,000-30,000 63 Non Catalytic Vermont Castings 2370 3 10.094-27,550 72 Catalytic Vermont Castings FA224 3.1 9100-34800 72 Catalytic Vermont Castings FA288 3.1 7800-29300 72 Catalytic Vermont Castings Intrepid II 1308 3.1 10200-22500 72 Catalytic Vermont Castings Intrepid Model 1640 3.3 8200-19500 63 Non Catalytic Vermont Castings Madison Model 1655 3.3 11,300-39,700 63 Non Catalytic Vermont Castings Resolute Acclaim (Model Number 2490) & TLWS1 3.4 9500-33900 63 Non Catalytic Vermont Castings C.D. Federal "A Plus" FA224ACL 3.5 7200-30000 72 Catalytic Vermont Castings EWF 30 3.5 11,100-40,500 63 Non Catalytic Vermont Castings C.D. Sequoia FA455 3.6 8700-60300 72 Catalytic Vermont Castings C.D. Adirondack Wood Heater FA267CL 3.7 8400-40000 72 Catalytic Vermont Castings WinterWarm Small Insert (model 2370) 4 9250-21500 72 Catalytic Vermont Castings Aspen 1920 & Plymouth HWS10 4.3 9100-18000 63 Non Catalytic Vermont Castings C.D. Large Federal Box Heater FA209CL 4.3 9000-25600 72 Catalytic Vermont Castings C.D. Small Federal Box Heater FA207CL 4.3 6200-28000 72 Catalytic

Vermont Castings Campbell/Jacuzzi FW300005-FW300008 & FW300019-
FW300027 4.4 12000-55100 63 Non Catalytic Vermont Castings CJW2000L02, JW2000L10, DW2000XXX and JW2000P10 4.4 12000-55100 63 Non Catalytic Vermont Castings JW1500L10 and JW1500P10, FW1500, DW1500 4.4 10300-29200 63 Non Catalytic Vermont Castings S27X/S28X & FW27 Series, CJW1500L02, 4.4 10300-29200 63 Non Catalytic

Vermont Castings S27X/S28X & FW27 Series, CJW1500L02, JW1500L10 and JW1500P10, FW1500, DW1500 4.4 10300-29200 63 Non Catalytic Vermont Castings Seville 1635 and 1600 Insert 4.5 9,900-30,800 63 Non Catalytic

Vermont Castings CW2500X00, CW2500X02, JW2500X00,CJW2500X02,
DW2500 and JW2500X10 4.7 9500-57800 63 Non Catalytic Vermont Castings FW247001 to FE247004 and JW1000PF1 5 11500-18900 63 Non Catalytic Vermont Castings Resolute Acclaim 0041 5.1 8700-30900 72 Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 19List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type Vermont Castings Madison 1650 5.5 11400-31000 63 Non Catalytic Vermont Castings Seville Insert 5.5 10200-27400 63 Non Catalytic Vermont Castings Aspen Model 1920 6.3 10100-26400 63 Non Catalytic Vermont Castings Dutchwest 2477 1.4 7800-25100 63 Non Catalytic Vermont Castings Defiant 1975 1.1 11400-34065 72 Catalytic Vermont Castings Savannah SSW30FTAL 2.5 11600-30601 63 Non Catalytic Vermont Castings Savannah SSW30FTAPB 2.5 11600-30602 63 Non Catalytic Vermont Castings Savannah SSW30STAPB 2.5 11600-30604 63 Non Catalytic Vermont Castings Savannah SSW30STAL 2.5 11600-30-603 63 Non Catalytic Vermont Castings Savannah SSW30FTPB 2.5 11600-30600 63 Catalytic Vermont Castings Savannah SSI30 3.47 11000-30600 63 Non Catalytic Vermont Castings Savannah SSW40 4.3 11953-35767 63 Non Catalytic Vermont Castings Dutchwest DW270007 4.4 10300-29201 63 Non Catalytic Vermont Castings Dutchwest DW2500X02 4.7 9500-57801 63 Non Catalytic Vermont Castings Dutchwest DW2000L02 2.7 11800-32301 63 Non Catalytic Vermont Castings Dutchwest DW1500L02 4.4 10300-29201 63 Non Catalytic Vermont Castings Dutchwest DW244 5.3 10600-26101 63 Non Catalytic Vermont Castings Dutchwest DW 247001 5 11500-18901 63 Non Catalytic Vermont Castings Dutchwest DW1000L02 5.3 10600-26101 63 Non Catalytic Vermont Castings Dutchwest DW300007 2.7 11800-32300 63 Non Catalytic Vermont Castings Merrimack 3.6 10574-31780 63 Non Catalytic Vermont Castings Savannah SSW20 3.8 11000-45000 63 Non Catalytic Vermont Castings Windsor WR244 5.3 10600-26100 63 Non Catalytic Vermont Castings Seville 1630, Stratton 6.3 12000-27300 63 Non Catalytic

x Vestal Manufacturing Vestal Fireplace Insert V-200-I, V-200-P, V-200-L 2 11700-26500 72 Catalytic

x Vestal Manufacturing Vestal Radiant Heater V-100 2.2 9400-27700 72 Catalytic

Vogelzang International Corporation TR-009B Performer 3.73 11,299-36,089 63 Non Catalytic Vogelzang International Corporation TR-009 Performer 3.89 11,299-36,089 63 Non Catalytic Vogelzang International Corporation TR-004 Colonial 4.02 11,299-36,089 63 Non Catalytic Vogelzang International Corporation Durango TR001 and Model TR002 3.6 11,299-36,089 63 Non Catalytic Vogelzang International Corporation Highlander, Shiloh Insert, Model TR003 3.8 9000-26300 63 Non Catalytic Vogelzang International Corporation TR007 Norwood, TR011 Norwood 3.2 11,913-34,108 63 Non Catalytic Vogelzang International Incorporated Defender 4.18 9200-28300 63 Non Catalytic
Wamsler Herd und Ofen GmbH HOK 10 4.6 9200-16900 63 Non Catalytic Waterford Stanley Limited 104 MK II 31 2.9 8800-25900 63 Non Catalytic Waterford Stanley Limited 100B 90 32 TV 3.1 10800-32400 63 Non Catalytic Waterford Stanley Limited 100B 90 32 RV 3.9 10600-26500 63 Non Catalytic Waterford Stanley Limited Trinity OA 3.97 11500-43800 63 Non Catalytic Waterford Stanley Limited Ashling 4.1 12000-29800 63 Non Catalytic Waterford Stanley Limited Erin OA 4.1 10400-30300 63 Non Catalytic Waterford Stanley Limited Erin/90 TV 4.2 10500-40900 63 Non Catalytic Waterford Stanley Limited Model 100B, 100B O.S.A., Leprechaun 4.3 9000-26700 63 Non Catalytic Waterford Stanley Limited Erin/90 TV 5.7 10200-39900 63 Non Catalytic Waterford Stanley Limited Trinity 35 7 11800-39300 63 Non Catalytic Waterford Stanley Limited 100B Design 29, Fionn 7.5 7200-27500 63 Non Catalytic Waterford Stanley Limited Erin 7.6 11800-41500 63 Non Catalytic

x Webco Industries Marquis 800, 800 XL 3.6 9900-20000 72 Catalytic

x Weitz & Co., Inc. Briarwood XE 88 6.4 12800-34200 63 Non Catalytic

x Weitz & Co., Inc. Briarwood BB, BBI and BBZC 4.8 10600-25300 63 Non Catalytic

x Weitz & Co., Inc. Eagle 88, Pioneer ZC 6.4 12800-22800 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 20List of EPA Certified Wood Stoves December 2013

Out of
Productio

n Manufacturer Name Model Name Emission
Rate G/Hr Heat Output

btu/hr Actual

Measured Efficiency (CSA B415.1) EPA Estimated

(Default) Efficiency Type

x Weitz & Co., Inc. Briarwood II 87 7.3 9900-45900 63 Non Catalytic

x Welenco Manufacturing, Inc. P-1000W 0.7 9600-23900 78 Pellet

Weso-Aurorahautte GmbH Prestige 125, 225, 325, 425 7.3 8900-31200 63 Non Catalytic
Weso-Aurorahautte GmbH Renaissance 326 8 9200-32900 63 Non Catalytic
Winrich International Winrich Pellet Stove 1.6 8500-27900 78 Pellet

x Winston Stove Company Model WP-18 0.6 10000-21300 78 Pellet

x Winston Stove Company Model WP-24 1.5 9700-29400 78 Pellet

Wiseway Pellet Stoves GW1949 1.9 7481-19475 78 Pellet Wittus Fire By Design XEOOS Twinfire 2.4 11,519- 27,432 63 Non Catalytic Wittus Fire By Design Shaker Stove 7.3 9,667-29,242 63 Non Catalytic
Wolf Steel Ltd. NPS45 2.4 8,827 - 29,023 78 Pellet
Wolf Steel Ltd. 1900 series (Napoleon 1900) 2.9 11800-34000 63 Non Catalytic
Wolf Steel Ltd. Napoleon 2000 3.2 11000-31100 63 Non Catalytic
Wolf Steel Ltd. 1400 series (Napoleon 1400, 1400L, 1450,1401) 3.5 11500-33600 63 Non Catalytic
Wolf Steel Ltd. 2200 series (Timberwolf 2200, 2201) 3.6 12,084-31436 63 Non Catalytic
Wolf Steel Ltd. 2100 series (Timberwolf) 3.9 11,238-37580 63 Non Catalytic
Wolf Steel Ltd. 1100 series ( Napoleon 1100, 1100L, 1100C, 1150, 1101) 4.1 11700-32700 63 Non Catalytic
Wolf Steel Ltd. NZ25 4.46 11200-32300 63 Non Catalytic
Wolf Steel Ltd. EPA1600C 5.4 12,375-28,127 63 Non Catalytic
Wolf Steel Ltd. NZ-26 5.4 11500-27400 63 Non Catalytic
Wolf Steel Ltd. Napoleon 1000 6.5 10200-30800 63 Non Catalytic
Wolf Steel Ltd. Napoleon 1500 7 11700-23100 63 Non Catalytic
Wolf Steel Ltd. 1600C-1 7.18 9,200-33,400 63 Non Catalytic
Wolf Steel Ltd. TPSI35 2.1 11,200 - 36,000 78 Pellet
Wolf Steel Ltd. NZ3000 7.2 11129-31436 63 Non Catalytic
Wolf Steel Ltd. EPI22 2.6 11129-31436 63 Non Catalytic
Wolf Steel Ltd. EPI3 2.6 11,281 - 28,500 63 Non Catalytic

x Wolf's Casual Living BV 3.8 10800-35400 72 Catalytic

x Wolf's Stoves BV2 Elite Bay 2.6 11700-46100 63 Non Catalytic

x Woodkiln Inc. Woodkiln WK-23 3.8 10700-27200 63 Non Catalytic

Woodstock Soapstone Company, Inc. Catalytic Fireview Soapstone Stove #205 1.35 10900-42900 72 Catalytic

Woodstock Soapstone Company, Inc. Paladian Model 202, Paladian Model 203 & Keystone Model 204 1.9 8500-35000 72 Catalytic Woodstock Soapstone Company, Inc. Catalytic Fireview Soapstone Stove #201, Classic #200 3.5 13200-40000 72 Catalytic Woodstock Soapstone Company, Inc. Progress Hybrid Soapstone Stove #209 1.33 12,538 - 73,171 81 78 Catalytic-Hybrid

x Yunca Heating Yunca WEGJ E/481 5 10700-30300 63 Non Catalytic

Zephyr Stoves, Inc. View 2.0 4.5 10,700-34,800 63 Non Catalytic

Actual Measured Efficiency - Per CSA B415.1 Default - Category rating assigned by EPA (The estimated efficiency is a follows: 72% (catalyst-equipped), 63% (non-catalyst equipped), and 78% (wood pellets)). § 60.536(i)(3).

Section 1. Page 21List of EPA Exempt Wood Heating AppliancesEPA Wood Heater ProgramThe United States Environmental Protection Agency (EPA) regulates particulate emissions from wood heating appliances as part ofthe Clean AirAct’s New Source Performance Standard for Residential Wood Heating Appliances at 40 CFR Part 60, Subpart AAA. Wood heating appliancessubject to this regulation must have a firebox volume less 20cubic feet, weigh less 800 kilograms, possess a burn rate less than 5 grams per hourand have an air to fuel ratio less than 35 to 1. The wood stove regulations apply to wood heating appliances intended for residential heating.Appliances such as cookstoves, wood burning furnaces, outdoor woodboilers, coal stoves and fireplaces are not subject to theseregulations.The following is a list of wood heating appliances dated that have been formally exempted from the EPA wood stove program. The manufacturers ofthese appliances demonstrated that they do not meet the criteria necessary for EPA wood stove certification by submitting testreports andengineering drawings to the EPA. Please note, the applianceson this list are not EPA certified wood stoves and therefore may not be legal for saleor installation in some jurisdictions in the United States.Please contact John DuPree at 202-564-5950 should you have questionsregarding the EPA Wood Heater Programor EPA certified wood stoves.

### 3/16/10 

# EXEMPT APPLIANCES

Manufacturer

Model Name Basis for Exemption


### Alpha Energy Designs

815 D Street
Lewiston ID 83501

, USA

208-746-5502
Alpha A20 Fireplace Insert Burn Rate > 5kg/hr



### Alternative Energy Northwest, Incorporated

16311 Smokey Point Blvd Arlington WA 98223

, USA

206-652-8124

2001 Pellet Stove Air-to-Fuel Ratio > 35:1



### American Energy Systems R.D.M.

50 Academy Lane
Hutchinson MN 55350

, USA

612-587-6565
Magnum ZC Burn rate > 5 kg/hr



### American Road Equipment Company

4201 North 26th Street
Omaha NE 68111

, USA

402-451-2575

Erik Jr. Elite M Air-to-Fuel Ratio > 35:1



### Andersen Mfg., Inc.

3125 N. Yellowstone
Box 434D

, Idaho Falls ID 83401
USA (208) 523-6460
Elco Fireplace Burn Rate > 5 kg/hr



### Aqua II Manufacturing

2421 west Clemmonsville road
Winston Salem NC 27127

, USA (919)768-4800
Aqua II Water Stove Qualifies as FurnaceManufacturer

Model Name Basis for Exemption


### Aqua-Therm

Route 1, Box 1
Brooten MN 56316

, USA

612-346-2264
Aqua-Therm 145, 275, 345 Qualifies as Boiler



### Ardisam

1690 Elm Street
Cumberland WI 54829

, MF3500 Qualifies as a Furnace.



### Biofire, Inc.

3220 Melbourne Salt Lake City UT 84106

, USA

801-486-0266
3x3, 4x3, 4x4, 5x3 Weight > 800 Kg



### Century Manufacturing Company, Inc.

1620 East 20th Street
P.O. Box 1744 Joplin , MO 64801
USA (417) 624-1480

CO-28-WG Burn Rate > 5 Kg/hr

CO-36 Fireplace Furnace Burn Rate > 5 Kg/hr



### CFM Corporation (Vermont Castings, Inc.)

Route 107, Box 501
Bethel VT 05032

, USA (802) 234-2300
Dauntless Fireplace Burn Rate > 5 Kg/hr



### Cool Country Enterprises

P.O. Box 786 41508 Maycreek Road

, Gold Bar WA 98251
USA

360-793-2110
Earth Friendly P.S. Air-to-fuel ratio > 35:1.

2Manufacturer

Model Name Basis for Exemption


### Country Flame Technologies, Inc.

900 George Street
Marshfield MO 65706

, USA

417-466-7161

NPS-1000 Air-to-fuel Ratio > 35:1



### Country Stoves, Inc.

, PS 40 & PI 40 Air to Fuel Ratio



### Dovre, Inc.

401 Hankes Avenue
Aurora IL 60505

, USA (312) 844-3353
Focus II, Model FOC2 Qualifies as Coal Stove

Sunburst II 2100 Burn Rate > 5 kg/hr



### Dumont Refrigeration Corp.

P.O. Box 148
Monmouth ME 04259

, USA

207-933-4811
Temptest 150, 350 Qualifies as Boiler



### Earthstone

2733 Mariquinta Street
Suite 101 Long Beach , CA 90803
USA

310-434-7095
Earthstone Wood Burning Ovens 60, 90, 130 Wood-fired ovens



### ECOHEAT of Canada Inc.

P.O. Box 93110, 1450 Headon Road Burlington, Ontario L7M 4A3

, Canada

905-331-2702

Ecoheat Cookstove

3Manufacturer

Model Name Basis for Exemption


### Energy Equipment and Manufacturing Company

615 South 32nd Avenue
Yakima WA 98902

, USA

509-457-1108
Energy Hearth Fireplace Furnace Burn Rate > 5 Kg/hr



### England's Stove Works, Inc.

589 S. Five Forks Road
Monroe VA 24574

, USA (804) 929-0120
Model 25-PDV , 55-TRP22 and 55-SHP22 Air-To-Fuel ratio > 35:1

Models 25-PDVC and 55-SHP10 Air-to-Fuel-Ratio > 35:1

Models 25-PDVC and 55-SHP10 Air-to-Fuel-Ratio > 35:1



### GEMSTAR Fireplace Co., Ltd.

6265 19th Street Surrey, B.C. V3S 5M8

, Canada

604-530-9060

GEMSTAR Air-to-Fuel Ratio > 35:1



### Gibraltar Stoves, Inc.

512 - 72nd Street
Holmes Beach FL 34217

, USA

813-779-2217
LCC, MCC, SCC, CFS, CFI & DDI Classified as Coal Stove



### Hardy Manufacturing Co., Inc.

Route 4, Box 156 Philadelphia MS 39350

, USA

601-656-5866
Hardy, Hardy Jr. Qualifies as Boiler



### Hearth and Home Technologies

1445 North Highway
Colville WA 99114

, USA

509-684-3745

Quadra-Fire 1000 Pellet Stove Burn Rate > 5 Kg/hr.

Quadra-Fire 1000 Pellet Stove Air-to-Fuel ratio > 35-to-1

4Manufacturer

Model Name Basis for Exemption


### Hearth & Home Technologies

, PEL-30 Contour Air-to-Fuel Ratio > 35



### Heartland Appliances, Inc.

1050 Fountain Street North Cambridge Ontario N3H 4R7

, Canada (519)743-8111
A-19-3 Oval Woodburning

A263 Sweetheart

Artisan Cookstove

Cookstove

Cookstove



### Heating Energy Systems, Inc.

P.O. Box 593 14300 SE Industrial Way

, Clackamas OR 97015
USA

503-786-4004

Trailblazer Classic 1600PS Air-To-Fuel Ratio > 35:1



### Heatmor Outdoor Wood Burning Furnaces

Highway 11 East, Box 787 Warroad, MN 56763

, USA

218-386-2769
100CSS, 175SSE,200CSS, 400CSS and 400DCSS Qualifies as Furnace.



### Hicks Waterstoves & Solar System

2541 South Main Street Mt. Airy NC 27030

, USA

919-789-4977
500, 700, 1000 gallon waterstoves Qualifies as Boiler



### High Energy Manufacturing PO B 400 PO Box 400 Vermillion Bay Ontario 54829

, Canada POV 2VO

J2000 Qualifies as a Furnace.

5Manufacturer

Model Name Basis for Exemption


### Jensen Metal Products, Inc.

7800 Northwestern Avenue
Racine WI 53406

, USA (414)886-9318
Models 24A,24AC,30A & 30AC Qualifies as Furnace



### Ka-Heat Kachelofen, Ltd.

R.R. NO4, 670 Packer Road Roseneath, Ontario K0K 2X0

, Canada

905-352-3848

FK07 and FK09 Burn rate > 5 kg/hr



### Klass Waterstove

4931 Elkorn Ct.
Salem OR 97301

, USA

503-391-2880

Klass Waterstove Qualifies as Furnace



### L.B. Brunk & Sons, Inc.

10460 S.R. 45N
Salem OH 44460

, USA (216) 332-4297
120, 150, 190 Qualifies as Furnace



### Lamppa Manufacturing & Distributing Co., Inc.

P. O. Box 422
Tower MN 55790

, USA

218-753-2330

Kuuma Wood Sauna Stove Air-To-Fuel Ratio > 35:1



### Lennox Hearth Products

1110 West Taft Ave. Orange

, CA 92865

USA

714-921-6100
Whitfield Profile 20 / Optima 20 Air-to-Fuel ratio < 35:1

Whitfield Profile 30 / Optima 3 Qualified for exemption.

Whitfield Renaissance WW 1 Pellet Stove Air-To-Fuel Ratio > 35:1

6Manufacturer

Model Name Basis for Exemption


### Majco Building Specialties, L.P.

1000 East Market Street
P.O. Box 800 Huntington , IN 46750
USA (219) 356-8000
Majestic BFC 36 Burn rate > 5 kg/hr.

Model FC-36 Burn rate > 5kg/hr.



### National Steelcrafters of Oregon

P.O. Box 2501 Eugene

, OR 97402

USA (503) 683-3210

P24FS and P24I Air-to-Fuel Ratio > 35:1

P2700FSA Air-to-Fuel Ratio > 35:1



### Nature's Furnace, Inc.

3338 Ute Avenue
Waukee IA 50263

, USA

515-987-2397

Biomass Reactor Qualifies as Furnace.



### NHC Inc.

317 Stafford Avenue
Morrisville VT 05661

, USA

802-888-5232

L07 Cookstove

Model American Heritage Wood Burning Stove Burn Rate > 5 Kg/hr

Model Hearthstone 1 Burn Rate > 5 Kg/hr



### Rais A/S

23 Hack Green Road Pound Ridge NY 10576

, USA (914) 764-5679
Rais #2,#3,#4,#86,#101,#106,#115 Cookstove

7Manufacturer

Model Name Basis for Exemption


### Reed Metal Works, Inc.

HC2, Box 656
Warroad MN 56763

, USA

218-386-2769

JR Heatmor Model 200CSS and 400CSS Qualifies as Furnace.



### Reliant Industries, Inc.

333 Industrial Dr. #3
Placerville CA 95667-6849

, USA

916-622-5887

Essex Air-to-Fuel Ratio > 35:1

Reliant Tempest Pellet Stove Air-To-Fuel > 35:1.



### Riteway-Dominion Manufacturing Company, Inc.

1680 Country Club Road
Box 5 Harrisonburg , VA 22801
USA (703) 434-3800
Omni I, Omni II Qualifies as Furnace.



### RJM Manufacturing, Inc.

Route 5, Box 190 Chippewa Falls WI 54729

, USA

715-723-9667
Energy King Furnace 120, 145, 185 Qualifies as Furnace



### Royal Crown European Fireplaces, Inc.

333 East State, Suite 206 Rockford, IL 61104

, USA

815-968-2022
100-0, 100-2, 200-0, 200-3, 202-1, 202-4, 206-0 Weight > 800 Kg



### RSF / Industrial Chimney Company, Incorporated

400 J-F Kennedy St Jerome QC J7Y 4C7

, Canada

450-565-6336
Omega Burn Rate > 5 Kg/hr

Opel 2000E, OPEL AP Burn rate > 5 Kg/hr

Oracle Burn Rate > 5 Kg/hr

8Manufacturer

Model Name Basis for Exemption


### Scott Stoves, Inc.

P.O. Box 1033 Hayden Lake ID 83835

, USA

208-772-7310

Pellet Stove Model 1 Air-to-Fuel Ratio > 35:1



### Sedore Stoves USA

47909 County Road 37 Deer River, MN 56636

, USA

218-246-2908

Model 3000 Qualifies as F urnace/Boiler



### Sherwood Industries, Ltd.

6782 Oldfield Road
Saanichton BC

Canada , V8M 2A3

604-652-6080
Empress/Windsor Air to Fuel Ratio

OMEGA Air to Fuel Ratio

Vista Flame Envirofire EF II Air to Fuel Ratio

Vista Flame Envirofire Evolution Model EF 5/VF 5 Air to Fuel Ratio

Vista Flame Envirofire Pellet Stove Air to Fuel Ratio



### Snorkel Stove Company

108 Elliott Avenue West
Post Office Box 20068

, Seattle WA 98102
USA

206-283-5701
Snorkel, Scuba Hot Tub Heater Hot Tub Heater



### Stove Builder International Inc.

1700 Leonharmel Street Quebec City Quebec G1N 4R9

, Canada

418-527-3060

Series EE1200 Acorn Minimum burn rate greater than

9Manufacturer

Model Name Basis for Exemption


### Suburban Manufacturing Company

P.O. Box 399 676 Broadway Street Dayton , TN 37321
USA (615) 775-2131

Coalchief CC6-88 Coal Stove

Coalmaster C6-88 Coal Stove

Woodchief FP6-88U & FP6-88WCU Burn Rate > 5.0 kg/hr



### Taylor Products, Inc.

P.O. Box 518
Elizabethtown NC 28337

, USA (919) 862-2576
Taylor Outside Wood Fired Hot Water Furnace Qualifies as Furnace.



### The Maxson Company/Acucraft Fireplace Systems

, Z-Max Burn Rate > 5 Kg/hr



### The New Alberene Stone Company

P.O. Box 300 Schuyler VA 22969

, USA

804-831-2228
H 950, HPU 950 Weight > 800 Kg

HU 2850, HU 3750 Weight > 800 Kg

KTU 1650, KTU 1650L, KTU 1900L Weight > 800 Kg

LLU 1150 1H, LLU 1150 2H, LU 2150, HU 3750, LU2750 Weight > 800 Kg

LU 1900, KTLU 1800L, TLU 2700L, TLU 2800L, TLU3300 Weight > 800 Kg

P&M 1450, P&M 1500, P&M 2050 Weight > 800 Kg

SKU 850 Weight > 800 Kg

TU 1100 Weight > 800 Kg

TU 1400, TU 1400L Weight > 800 Kg

TU 1700, TU 1800, TU 1800 L Weight > 800 Kg

TU 800, TU 1025, TU 1250 Weight > 800 Kg

10Manufacturer

Model Name Basis for Exemption


### Thelin Company Inc.

P.O. Box 847 Nevada City

, NV 95959

USA (916) 273-1976

Echo Air-to-Fuel Ratio > 35:1

Focus II, FOC2 Coal Stove

Thompson, Design E Air-to-Fuel Ratio > 35:1



### Turbo-Burn, Inc.

4225 E Joseph Spokane WA 99207

, USA (509) 487-3609

TB-1 & TB-2 Qualifies as Furnace.



### U.S. Stove Company

227 Industrial Park Drive South Pittsburg

, TN 37380

USA (615) 837-2100
Logwood 2421 Burn Rate > 5 Kg/hr

Model 1261 Burn Rate > 5 kg/hr

MODEL 127 Burn rate > 5 kg/hr

MODEL 4300 Burn Rate > 5 Kg/hr

Paragon 5440 Air-To-Fuel Ratio > 35:1

Tri-Star 5448-Q Air-To-Fuel Ratio > 35:1



### Unique Functional Products

135 Sunshine Lane
San Marcos CA 92069

, USA (619) 744-1610

UFP Free Heat Machine Fireplace Accessory



### Vogelzang International Incorporated

400 West 17th Street
Holland MI 49423

, USA (616) 396-1911
BK50E, BK100E, BK150E Burn Rate > 5.0kg/hr

BX42E, FS260E, HH005, P205E, PB65XL, SR57E Burn Rate > 5.0kg/hr

VG450ELG, VG450EL, VG450ELGB, VG650ELGB, VG810CL Burn Rate > 5.0kg/hr

11Manufacturer

Model Name Basis for Exemption


### Waterford Stanley Limited

Bilberry Waterford

, Ireland

011-353-51-302300
The Stanley Cookstove Qualifies as Cookstove



### Wolf SteelLimited

24 Napolean Road
Barrie Ontario

Canada L4M 4Y8 , Canada

NPS 40 Qualifies as a Furnace.

NZ6000 Qualifies as a Furnace.



### Wood-aire

P.O. Box 296
Commerce OK 74339

, Canada

918-675-4355
3225 Fireplace Furnace Burn Rate > 5 Kg/hr



### N.B. : This list only shows those appliances for which manufacturers have requested and been granted exemption by EPA. Other appliances may exist which are exempt but for which EPA has not made a determination. EPA does not require manufacturers of exempt appliances to demonstrate that their products are exempt. However, to appear on this list, a manufacturer must submit documentation or test data from an accredited testing laboratory.

Other States and localities may have other exempt appliance policies which differ from EPA's policy.

12

### San Joaquin Valley Unified Air Pollution Control District Meeting of the Governing Board September 18, 2014



## ADOPT PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD BURNING PROGRAM

Attachment E:

Registration Forms ( 2 PAGES)

# INTERIM REGISTRATION APPLICATION 2014/15 Wood Burning Season

Applicant Information

Device Information

By providing my signature below, I hereby agree to the above conditions and certify that all information provided in this registration is true and correct to the best of my knowledge. I understand that my interim registration may be revoked if at any time the San Joaquin Valley Air Pollution Control District discovers that any of the information I provided is untrue, inaccurate, not current, or incomplete. Full Name*

Mailing Address* City* State* Zip Code*

Email Address Primary Phone #* Alternate Phone #

Device Address* Was this wood burning heater purchased and installed under the Distirct’s Burn Cleaner incentive program?
If yes, please specify the project indentification number:

Device Type* City* State* Zip Code*

Manufacturer Model

Signature Date Device County* *Required Fields



# CONDITIONS

1. The following materials shall not be burned in a registered wood burning heater: garbage, treated wood, plastic products, rubber products, waste petroleum products, paints and paint solvents, coal, or any other material not intended by a manufacturer for use as a fuel in a wood burning fireplace, wood burning heater, or outdoor wood burning device.
2. The registered wood burning heater shall be maintained and operated per manufacturer specifications.
3. The registered wood burning heater shall not be operated during periods of District announced “No Burn” days for the county in which the registered wood burning heater is located.
4. The registered wood burning heater shall have no visible smoke, except when a fire is started, when fuel is added and when the fire is being extinguished. Visible smoke produced during these three events shall not exceed fifteen minutes per event.
5. The registration of a wood burning heater is non-transferable.

# WOOD BURNING DEVICE REGISTRATION

CONDITIONS

1. The following materials shall not be burned in a registered wood burning heater: garbage, treated wood, plastic products, rubber products, waste petroleum products, paints and paint solvents, coal, or any other material not intended by a manufacturer for use as a fuel in a wood burning fireplace, wood burning heater, or outdoor wood burning device.

2. The registered wood burning heater shall be maintained and operated per manufacturer specifications.

3. The registered wood burning heater shall not be operated during periods of District announced “No Burn” days for the county in which the registered wood burning heater is located.

4. The registered wood burning heater shall have no visible smoke, except when a fire is started, when fuel is added and when the fire is being extinguished. Visible smoke produced during these three events shall not exceed fifteen minutes per event.

5. The registration of a wood burning heater is non-transferable. 

## REGISTRATION NO: EXPIRATION DATE:

REGISTRATION HOLDER:
MAILING ADDRESS:

DEVICE LOCATION:

DEVICE COUNTY:

DEVICE TYPE:

MANUFACTURER:

MODEL NO:

Northern Region 4800 Enterprise Way Modesto, CA 95356-8718
Tel: 209 557 6400

Fax: 209 557 6475 

## Central Region 1990 E. Gettysburg Fresno, CA 93726-0244 Tel: 559 230 6000

Fax: 559 260 6061 

## Southern Region 34946 Flyover Court Bakersfield, CA 93308-9725
Tel: 661 392 5500

Fax: 661 392 5585 

## JANE DOE
1234 MAIN STREET MODESTO, CA 93765-4321

1234 MAIN STREET MODESTO, CA 93765-4321

STANISLAUS

EPA CERTIFIED WOOD INSERT

GREEN BURNS STOVE

GB-3534-ADD W-123456-1 XX/XX/XXXX