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: SJVUAPCD Governing Board

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-income 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 proposed new Rule 3901 (Fees for Registration of Wood 

Burning Heaters). 

4. Authorize the Chair to sign the attached Resolution. 
SJVUAPCD 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 residents 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 and 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 reductions 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 eventually 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). 

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SJVUAPCD Governing Board

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

BURNING PROGRAM

September 18, 2014

Summary of the Proposed Wood Burning Curtailment 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 

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 

increasing the number of burn days allowed for registered clean wood burning heaters 

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/m3 to 20 μg/m3. The 

proposed amendments will significantly increase the number of permissible burn days 

for cleaner certified wood burning devices by raising the No Burn threshold to 65 μg/m3

. 

If approved, the proposed amendments 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 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 

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SJVUAPCD 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 the 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/m3)

Proposed 

Level 2

(above 

65 μg/m3)

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 allowing certified devices to burn during a level one 

curtailment (greater than 20 μg/m3 but less than 65 μg/m3), the District proposes a 

registration program for these cleaner burning 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 the District to better focus 

resources. Registration will also ensure 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 burn 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 

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SJVUAPCD Governing Board

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

BURNING PROGRAM

September 18, 2014

under normal operating conditions, be maintained properly, 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 will 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 accordance 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 registered individuals on the District’s website for the public 

to access. 

Free Interim 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 significant 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 applicants 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, as 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 District’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 

heaters, 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 

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SJVUAPCD 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 

implemented 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 effective 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 wood 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 Valley 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-time 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%

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SJVUAPCD 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 heaters 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 emissions 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%

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SJVUAPCD 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 from 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 reductions from simply lowering the threshold from 30 μg/m3 to 20

μg/m3

, 

• 0.065 tons/day increase in emissions if all existing clean certified units registered

and burned on days when PM2.5 concentrations are projected to be between 30

μg/m3 to 65 μg/m3, 

• 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 projected to be between 20 μg/m3 to 65 μg/m3, and

• 2.04 tons/day of reductions 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 modeling 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 

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SJVUAPCD 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).

Health Impacts of Wood Smoke Particulate Matter Emissions

Reducing emissions from residential wood burning is a priority under the District’s 

Health Risk Reduction Strategy because multiple 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 residential 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 burning 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 an 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 Valley residents. One of the primary goals of this study was to learn more about 

residential wood burning habits and attitudes. Survey 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. Refer to Appendix E of the final draft staff report for 

the complete survey: 

• 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 respondents 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 device 

to a clean alternative if they were given up to a 50% discount on a new unit. 

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SJVUAPCD 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 fireplaces 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 Program 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 Valley 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 District’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 proposed 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

 
SJVUAPCD 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 expensive 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.

Additional 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 lowincome 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 multilingual Check Before You Burn outreach and education program. The District has an 

11
SJVUAPCD Governing Board

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

BURNING 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 percent 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 continued 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 members, 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 media 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:

• Educating the public and the media about the new tiered episodic wood burning 

curtailment program, 

• Encouraging residents to upgrade to cleaner certified devices and take 

advantage of the enhanced Burn Cleaner Program, and 

• Educating 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 neighborhood 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
SJVUAPCD 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 public 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 development 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 public 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, Patio & 

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 

Cleaner 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 Valley 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 

Residential Wood Burning Program. 

13
SJVUAPCD 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 appropriate. 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 Citizen’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 publicly 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 made 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 

during development of this rule are summarized below:

Comment: The 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 quality regulations in the nation and have already 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 scarce. Achieving additional 

emission reductions from businesses beyond those already achieved will require 

significant investments on the part of Valley businesses who have already spent billions 

of dollars in control technology. Despite significant progress 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 reductions in wood smoke emissions. 

14
SJVUAPCD 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. Scientific 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 reducing toxic wood smoke emissions in 

Valley neighborhoods during the peak PM2.5 winter season (November through 

February). 

Comment: Amending the curtailment threshold for all wood burning devices in the 

Valley from 30 to 65 μg/m3 is a relaxation of the rule and the draft curtailment threshold 

should be no higher than 30 μg/m3

. 

Response: On the contrary, 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/m3 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/m3 threshold. This proposed curtailment level is significantly lower than the current 

curtailment threshold of 30 μg/m3. Amending the rule to allow the cleanest wood 

burning heaters to be used between 20 and 65 μg/m3 would provide significant 

motivation to Valley residents 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 would reduce emissions beyond those that could be accomplished by only 

reducing the curtailment threshold to 20 μg/m3. The proposed amendments will achieve 

an estimated reduction of 5.1 tons per day of PM2.5 emissions.

Comment: The Duraflame Company provided a comment that the proposed revision of 

lowering the concentration threshold to 20 μg/m3 dramatically increases the number of 

No Burn days and tilts the burden of reducing PM2.5 emissions far beyond the 

contribution 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 that 

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 Inventory). December 2012. Retrieved on 8/15/14 from 

http://www.valleyair.org/Air_Quality_Plans/PM25Plans2012.htm. 

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SJVUAPCD Governing Board

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

BURNING PROGRAM

September 18, 2014

resulted in abnormally high PM2.5 concentrations during the 2013-14 winter season and 

the 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 (Scientific 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 emissions.

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 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 curtailments on high pollution 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 fineparticle 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 generated, 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 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%20Sci%20Foundation%20and%20Modeling.pdf. 

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SJVUAPCD Governing Board

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

BURNING PROGRAM

September 18, 2014

Table 3 General Air Emission Factors4

In addition, the 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 districts. 

Response: Proposed amendments to Rule 4901 as a whole 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 amendments will result in 5.1 tons per 

day of reductions in PM2.5 emissions. Matching 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/m3

, which is 10 μg/m3 lower than 

any of the other districts and by itself will result in significant emission reductions 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 (WoodBurning Devices) was 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 Duraflame Firelogs, and Douglas Fir Cordwood. Prepared for Jim Nolan Puget 

Sound Clean Air Agency. May 23, 2006.

17

 
SJVUAPCD Governing Board

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

BURNING PROGRAM

September 18, 2014

threshold of 30 μg/m3 – 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 Matter and Visible Emissions – Wood-Burning Devices) has a No 

Burn curtailment threshold of 35 μg/m3 – 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 Management 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/m3 while allowing certified devices to burn up to 35 μg/m3 – 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 federal 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 incentives 

18
SJVUAPCD Governing Board

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

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. The 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 District 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 recommendations 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 Proposed Amendments to Residential 

Wood Burning Program (200 pages)

Attachment E: Registration Forms (2 pages) 

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 ADOPT 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 

 

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1990 E. Gettysburg Ave. 

Fresno, CA 93726 

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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 FIREPLACES) AND PROPOSED 

NEW RULE 3901 (FEES FOR 

REGISTRATION OF WOOD BURNING 

HEATERS) 

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RESOLUTION NO. ______________

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

duly constituted unified air pollution control district, as provided in California 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 regulations to accomplish the purpose of 

Division 26 of the CH&SC; and 

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

Basin (Valley) has been classified as a nonattainment 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 Valley has been classified as a 

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

 WHEREAS, for each federal nonattainment pollutant, federal CAA §172 requires the 

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

control measures as expeditiously 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 4901 to lower the episodic curtailment 

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

 WHEREAS, proposed amendments to Rule 4901 would 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 ADOPT 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 

 

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Curtailment would be declared in a given geographic area by the District when 

pollutant levels are forecast to be equal to or exceed 20 μg/m3 but not to exceed 65 

μg/m3

 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/m3

 in said area; and 

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

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

geographic area, while the cleanest wood burning 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 created for the registration of wood 

burning heaters that meet specific qualification requirements identified within rule 

language; and 

 WHEREAS, a registration program would be created for the registration of qualified 

Wood Burning Heater Professionals to verify 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 emissions when and where those reductions are 

needed most, in urban residential 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 ADOPT 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 

 

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 WHEREAS, the District is proposing administrative amendments to Rule 4901 to 

clarify rule requirements by adding definitions and removing outdated and redundant 

language; and 

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

fee associated with the voluntary registration and renewal of qualifying wood burning 

heaters for use during Level One Episodic Wood Burning Curtailments; and 

 WHEREAS, new Rule 3901 would commit 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 adopts the proposed amendments to Rule 4901 

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

(Fees for Registration of Wood Burning Heaters). 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 which 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 testimony 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 rulemaking proceeding, that a need exists for said 

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

commitments of the SIP and requirements of the federal CAA and the California CAA. 
SJVUAPCD Governing Board 

ADOPT PROPOSED AMENDMENTS TO RULE 4901 (WOOD BURNING FIREPLACES AND WOOD 

BURNING HEATERS) AND ADOPT 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 

 

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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 meaning can be easily understood by those persons or industries 

directly affected by said rule. 

 d. CONSISTENCY. The Governing Board finds that 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 existing state or federal 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 that the requirements of CH&SC §40728.5 

and 40920.6 have been satisfied to the greatest extent possible, and that the 

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

any adverse socioeconomic impacts associated with the proposed rulemaking. 

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

significant adverse effect on the environment, the proposed actions are exempt from 

the provisions of the California 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 directed to file a Notice of 

Exemption with the County Clerks of each of the counties in the District. 

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

appropriate agencies certified copies of this resolution and the rules adopted herein 

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

CH&SC §40728. 
SJVUAPCD Governing Board 

ADOPT PROPOSED AMENDMENTS TO RULE 4901 (WOOD BURNING FIREPLACES AND WOOD 

BURNING HEATERS) AND ADOPT PROPOSED NEW RULE 3901 (FEES FOR REGISTRATION OF 

WOOD BURNING HEATERS) 

September 18, 2014

 -5- Resolution for Proposed Amendments to Rule 4901 

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8. The Executive Director/Air Pollution Control Officer is directed to transmit said 

rules to the California Air Resources Board for incorporation into the SIP. 

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

Officer to include in the submittal or subsequent documentation any technical 

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

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

THE FOREGOING was passed and adopted by the 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 the 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 PAGES)
PROPOSED September 18, 2014 

4901-1 Proposed Amendments to Rule 4901

RULE 4901 WOOD BURNING FIREPLACES 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 fireplaces, wood burning heaters, and outdoor wood burning 

devices., and to establish a public education program to reduce wood burning emissions. 

2.0 Applicability 

This rule applies to: 

2.1 Any person who manufactures, sells, offers for sale, or operates a wood burning 

fireplace, or wood burning heater, or outdoor wood burning device. 

2.2 Any person who sells, offers for sale, or supplies wood intended for burning in a 

wood burning fireplace or wood burning heater. 

2.3 Any person who transfers or receives a wood burning stove or wood burning 

heater as part of a real property sale or transfer. 

2.4 Any person who installs a wood burning fireplace or wood burning 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 distributor or a retailer who buys a wood 

burning fireplace, wood burning 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 burning heaters, or outdoor 

wood burning devices to retailers or others for resale. 

3.5 EPA: the United States Environmental Protection Agency. 

3.6 EPA Phase II Certified: meets the performance and emissions standards set forth 

in the NSPS. Code of Federal Regulations, Part 60, Title 40, Subpart AAA. 
PROPOSED September 18, 2014 

4901-2 Proposed Amendments to Rule 4901

3.7 Garbage: any solid, semisolid, and liquid wastes generated from residential, 

commercial, and industrial sources, including trash, refuse, rubbish, industrial 

wastes, asphaltic products, manure, 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 Emissions from Fires in Low Mass 

Wood-burning Fireplaces,” that can be weighed (including the weight of the test 

fuel) on a platform scale. 

3.9 Manufacturer: any person who constructs or imports a wood burning fireplace or 

wood burning heater. 

3.10 Masonry Heater: any site-built or site-assembled, wood burning solid-fueled 

heating device constructed mainly of masonry materials in which 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 heating devices must 

meet the all federal requirements and be designed and constructed per construction 

specifications set forth in ASTM E 1602-3, “Guide for Construction of Solid Fuel 

Burning Masonry Heaters.” 

3.11 New Residential Development: any single or multi-family housing unit, for which 

construction began on or after January 1, 2004. Construction began when the 

foundation for the structure was constructed. 

3.12 New Wood Burning Heater: 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: the operation of a wood burning heater as 

defined in this rule, except when a fire is started in the wood burning heater, 

when fuel is added to the wood burning 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 Performance Standard. For purposes of this rule the NSPS 

is the Code of Federal Regulations, Part 60, Title 40, Subpart AAA. 

3.15 Outdoor Wood Burning Device: any wood burning fireplace, wood burning 

stove, or other device designed 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 chimineas. This does not include 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 exterior and interior house and trim paints, enamels, varnishes, 

lacquers, stains, primers, sealers, undercoaters, roof coatings, wood preservatives, 

shellacs, and other paints or paint-like products. 

3.175 Paint Solvents: any organic solvents sold or used to thin paints or clean up 

painting equipment. 

3.186 Pellet-Fueled Wood Burning Heater: any wood burning heater manufactured for 

the purpose of heating a space and is intended to operate on pellet 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: includes, but is not limited to, compressed sawdust, compressed paper 

products, and compressed forest residue, wood chips and other waste biomass, 

ground nut-hulls and fruit pits, corn, and cotton seed. 

3.2018 Permanently Inoperable: 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 equal to or less than 

2.5 microns. PM10 has an aerodynamic diameter equal to or less than 10 

microns. 

3.220 Real Property: the land 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, water lines, or electrical systems that 

primarily are used to control the environment for people and to benefit the land. 

3.231 Retailer: any person engaged in the sale of wood burning fireplaces, wood 

burning heaters, or outdoor wood burning devices directly to the consumer. 

3.242 Seasoned Wood: wood of any species that has been sufficiently dried so as to 

contain 20 percent or less moisture by weight. 

3.23 Sole Source: the only source of heat 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 heaters 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 appliance capable of and 

intended for space heating (i.e. wood stove, pellet-fueled wood burning heater, or 

wood burning fireplace insert). 

3.30 Wood Burning Season: for purposes of this rule, 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 gaseous-fueled. 

4.2 Cookstoves, as described in Code of Federal Regulations 60.531. 

4.3 Any burning occurring on the ground is open burning and 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 for 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 for sale, supply, install, or transfer 

a used wood burning heater unless it has been rendered permanently 

inoperable, satisfies requirements pursuant to Section 5.1.1, or is EPA 

Phase II Certified, or is a pellet-fueled wood burning heater, or is a low 

mass fireplace, masonry heater, or other wood-burning device of a make 

and model that meets all federal requirements EPA emission targets and 

has been approved in writing by the APCO. 

5.1.3 Public Awareness Information 

 Retailers selling or offering for sale new wood burning heaters shall 

supply public awareness 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 sizing of wood burning heaters, and 

5.1.3.6 Episodic Wood Burning Curtailment levels as defined in 

Section 5.6. 

5.1.4 Sections 5.1.1 and 5.1.2 do not apply to wood burning 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 assuring that each wood burning heater 

included in the real property is: 

5.2.1.1 EPA Phase II Certified or has a more stringent certification 

under the NSPS at time of purchase 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 requirements in the NSPS at the 

time of purchase or installation, or , 

5.2.1.3 permanently rendered Rendered permanently inoperable. or 

removed and rendered inoperable. 

5.2.2 Upon the sale or transfer of real property, the seller shall 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) included 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 for 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 APCO upon request. 

5.3 Limitations on Wood Burning 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 shall 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 burning heater per dwelling 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 after January 1, 2015 

5.3.2.1 No person shall install 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 shall install more than two (2) EPA Phase II 

Certified or more stringent certification as currently enforced 

under the NSPS, wood 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 Phase II Certified or more stringent 

certification, as currently enforced under the NSPS, per 

dwelling unit in any residential development with a density 

equal to or less than two (2) dwelling units per acre. 

5.4 Advertising Requirements for Sale of Wood 

5.4.1 No person shall sell, offer for sale, or supply any wood which is orally 

or in writing, advertised, described, or in any way represented to be 

“seasoned wood” unless the wood has a moisture content of 20 percent 

or less by weight. 

5.4.2 The APCO may delegate to another person or agency the authority to test 

wood for moisture content and determine compliance with Section 5.4.1. 

5.5 Prohibited Fuel Types 

No person shall cause or allow any of the 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 not intended by a manufacturer for use 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 Burning Curtailment 

This section shall be in effect annually during the months of November through 

February. 

5.6.1 Level One Episodic Wood Burning Curtailment 

 The APCO shall declare a Level One Episodic Wood Burning 

Curtailment for a geographic region whenever the potential for a PM2.5 

concentration is forecast 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 effect provided the wood burning 

heater: 

5.6.1.2.1 Is not fired on a prohibited 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 according 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 declare a Level Two Episodic Wood Burning 

Curtailment for a geographic region whenever the potential for a 

PM2.5 concentration of greater than 65 μg/m3 or for a PM10 

concentration of 135 μg/m3 or greater is predicted for the geographic 

region. No person within the geographic region for which a Level 

Two Episodic Wood Burning Curtailment has been declared shall 
PROPOSED September 18, 2014 

4901-9 Proposed Amendments to Rule 4901

operate a wood burning fireplace, low mass fireplace, masonry heater, 

wood burning heater, or outdoor wood burning device when a Level 

Two Episodic Wood Burning Curtailment is in effect. 

5.6.1 No person shall operate a wood burning fireplace, wood burning heater, 

or outdoor wood burning device whenever the APCO notifies the public 

that an Episodic Curtailment is in effect for the geographic region in 

which the wood burning fireplace 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 for a PM10 concentration of 135 μg/m3 or greater 

is predicted for the geographic region. 

5.6.3 The following wood burning 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 wood burning fireplace or wood 

burning heater is are the sole available source of heat in a 

residence. This includes times of temporary service outages, 

as determined by the gas or electrical utility service. 

5.6.4 Episodic Wood Burning Curtailment Notice 

The APCO shall notify the public of each Episodic Wood Burning 

Curtailment by any of the 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 message for which the telephone 

number is published. in the telephone 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 the APCO determines is 

appropriate. 

5.6.5 Contingency Provision 

Notwithstanding Section 5.6.2, on and after sixty days following the 

effective date of EPA final rulemaking 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 APCO shall notify 

the public of an Episodic Curtailment for a geographic region 

whenever a PM2.5 concentration of 20 μg/m3 or greater or a PM10 

concentration of 135 μg/m3 is predicted for the geographic region. 

5.7 Registration of Wood Burning Heaters 

5.7.1 Eligibility for Registration 

 A wood burning heater is eligible to be registered with the District 

provided it is either: 

5.7.1.1 EPA certified with a Phase 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 heaters which do not meet the requirements of 

Section 5.7.1.1 or 5.7.1.2 are ineligible for registration. 

5.7.1.4 Any registration 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 season of 2014/2015 only, an Interim 

Registration program will be in place. A wood burning 

heater may participate in the Interim Registration program 

provided the wood burning heater: 

5.7.2.1.1 Meets the eligibility 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 Level One Episodic 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 registration of a wood burning 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 after the 2015/2016 wood burning season, persons 

applying to register a wood burning heater shall: 

5.7.3.1 Submit a completed application and supplemental 

documentation demonstrating compliance with the eligibility 

requirements specified in Section 5.7.1 to the District. 

Supplemental documentation shall include the following: 

5.7.3.1.1 Receipt or invoice from the installation or 

purchase that includes the manufacturer and 

model name of the wood burning heater, or 

5.7.3.1.2 A certification from a District Registered Wood 

Burning Heater Professional 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 purchased and/or 

installed more than one year prior to registration 

with the District, the person 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 required 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 Section 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 the District a Registration Renewal 

application with verification that the wood burning heater has 

been inspected by District Registered Wood Burning 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 Sections 5.8.1 or 5.8.2 may result in 

disqualification of registration. 

5.9 Disqualification of Registration 

5.9.1 If the District finds a registered wood burning 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 the operator of the wood burning heater 

demonstrates compliance with the requirements of Section 5.5 and 

Section 5.6. 

5.9.3 Persons with a disqualified registration 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 determination 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 the wood burning heater, in 

writing, that the District has made a preliminary 

disqualification determination and 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 notification required by Section 5.9.4.1 

that the person who registered the wood burning heater confer 

with the District, in an office conference within 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 office conference required by Section 5.9.4.2 

provided that the person who registered the wood burning 

heater accepts the request 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 petitioner demonstrates to the satisfaction of the 

APCO that the violations forming the basis for the disqualification were 

the result of circumstances beyond the reasonable control of the petitioner 

and could not have been prevented by the exercise of reasonable care. 

5.10 Registration of Wood Burning Heater Professionals 

5.10.1 To qualify to register as a Wood Burning Heater 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 Investigation Research and 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 Institute (NFI) certification, or 

5.10.1.4 A person determined to be qualified to perform inspections, 

maintenance, and cleaning activities on wood burning heaters 

by the APCO. 

5.10.2 Persons applying to register as a Wood Burning Heater Professional with 

the District shall: 

5.10.2.1 Submit a completed application for registration to the District.
PROPOSED September 18, 2014 

4901-14 Proposed Amendments to Rule 4901

5.10.2.2 Submit any necessary supplemental documents as determined 

by the APCO as necessary to verify statements and 

qualifications as presented in the application for registration. 

5.10.2.3 If the applicant does not have a certification 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 the applicant meets the certification standards as 

required by certifications pursuant to Sections 5.10.1.1 

through 5.10.1.3. 

5.10.3 Registration as a Wood Burning Heater Professional with the District is 

valid for up to three years from the date of issuance. 

5.10.4 The District shall maintain a list of registered Wood Burning Heater 

Professionals on the District web page. 

5.11 Inspection of Registered Wood Burning Heaters 

The District has the right of entry for the purpose of inspecting any wood burning 

heater registered with the District in order to enforce or administer this rule. 

6.0 Administrative Requirements 

6.1 Upon request of the APCO, the manufacturer 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 burning heater shall retain a copy of the 

District issued registration and make it available 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 determined using EPA Method 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 any individual who chooses to register a wood 

burning heater pursuant to District Rule 4901. 

3.0 Registration Fee 

 Applicants registering a wood burning heater shall pay a non-refundable registration fee 

of $12.50 as a part of the application process. 

4.0 Renewal Fee 

 Individuals choosing to renew their registration with the District shall pay a 

nonrefundable renewal fee of $12.50 as a part of the application process. 

 No earlier than 60 days prior to the expiration date of the registration, 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 the 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 to 

Residential Wood Burning Program 

(200 PAGES)
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

Prepared by: Anna Myers, Senior Air Quality Specialist 

Contributors: Shawn Ferreria, Senior Air Quality Specialist 

David Lighthall, Ph.D., Health 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, Compliance Supervisor 

Amelia Yuan, Compliance Supervisor 

Heather Heinks, Public Education Administrator 

Jon Klassen, Program Manager 

Todd DeYoung, Program Manager 

Errol Villegas, Program Manager 

Michael Carrera, Compliance Manager 

Ryan Hayashi, Director of Compliance 

Sheraz Gill, Director of Strategies and Incentives 

Jessi Fierro, Assistant District Council 

Annette Ballatore-Williamson, District Council 

Jaime Holt, Chief Communications Officer 

Morgan Lambert, Deputy Air Pollution Control Officer 

Samir Sheikh, Deputy Air Pollution Control Officer

Final	Draft	Staff	Report	

for	Amendments	to	the	

District’s	Residential	

Wood	Burning	Program

September 18, 2014
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Draft Staff Report: Residential Wood 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 Residential Wood Burning Emissions ............................ 7

A. PM2.5 Attainment .................................................................................................. 7

1. Valley’s Unique Air Quality Challenges ........................................................... 7

2. Residential Wood Burning Emissions ............................................................. 8

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

B. Health Benefits from Reducing Wood Smoke Exposure ..................................... 10

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

A. Wind and Temperature Instability Provide the Strongest Mechanisms for 

Pollution Diffusion ............................................................................................... 12

B. Humidity and Sunlight Contribute to PM2.5 Concentrations ................................ 12

IV. Current Approach to Reduce Emissions ............................................................. 13

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

B. Burn Cleaner Incentive Program ......................................................................... 13

C. Public Education and Outreach ........................................................................... 16

V. Evaluation of Potential Regulatory Opportunities to Reduce Emissions ............. 19

A. Increase No Burn Days for Non-Registered Wood Burning Heaters and Wood 

Burning Fireplaces by Lowering the Curtailment Level ....................................... 19

B. Encourage Transition to Clean Burning Heaters ................................................. 20

C. Allow more burning days for clean burning heaters ............................................. 22

D. Expanded Wood Burning Season ....................................................................... 23

E. Re-evaluate Current Exemptions ........................................................................ 24

F. EPA Proposed New Source Performance Standards (NSPS) ............................. 24

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

A. Proposed Amendments to Rule 4901 .................................................................. 26

1. Section 1.0 (Purpose) ................................................................................... 26

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

3. “Phase II” rule clarifications ........................................................................... 27

4. Addition of “NSPS” for clarification of federal requirements .......................... 27

5. Section 3.0 (Definitions) ................................................................................ 27

6. Section 4.0 (Exemptions) .............................................................................. 28
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Draft Staff Report: Residential Wood 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 Transfer 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 (Prohibited Fuel Types) .............................................................. 30

11. Section 5.6 (Episodic Wood Burning Curtailments) ...................................... 31

12. Section 5.7 (Registration of Wood Burning Heaters) .................................... 33

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

14. Section 5.9 (Disqualification of Registration) ................................................ 35

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

16. Section 5.11 (Inspection of Registered Wood Burning Heaters) ................... 37

17. Section 6.0 (Administrative Requirements) ................................................... 37

18. Section 7.0 (Test Methods) ........................................................................... 37

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

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

1. Proposed Increased Incentive Amounts ....................................................... 38

2. Additional Assistance forLow-Income Residents .......................................... 39

3. Updates to Program Documents ................................................................... 40

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

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

A. Global Climate Change and Greenhouse Gases ................................................ 41

B. Health Benefits .................................................................................................... 41

C. Emission Reduction Analysis .............................................................................. 41

D. Economic Analyses ............................................................................................. 42

1. Cost Effectiveness Analysis .......................................................................... 42

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

E. Rule Consistency Analysis .................................................................................. 42

F. California Environmental Quality Act Analysis ..................................................... 43

VIII. Rule Development Process ................................................................................ 44

A. 2012 PM2.5 Plan Development ........................................................................... 44

B. Technical Workgroup Committee Meetings ......................................................... 44

C. Proposed Rule Amendments Guided by Scientific Public Survey ....................... 45

D. Public Workshops ................................................................................................ 46
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

 4 Final Draft Staff Report with Appendices for 

Proposed Amendments to Residential Wood Burning Program 

E. Public Hearing ..................................................................................................... 46

LIST OF FIGURES

Figure 1 San Joaquin Valley Topography Traps Air Pollution ..................................... 8

Figure 2 Burn Cleaner Graphic .................................................................................. 14

Figure 3 District's Check Before You Burn Graphic ................................................... 16

Figure 4 District RAAN and iPhone App Images ........................................................ 17

Figure 5 District Healthy Air Living Graphics .............................................................. 17

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

Pellet Stove .................................................................................................. 21

Figure 7 Average PM2.5 emissions based on wood burning heater type .................. 22

Figure 8 Illustration of Section 5.3.1 Requirements ................................................... 30

Figure 9 Illustration of Section 5.3.2 Requirements ................................................... 30

Figure 10 Current and Proposed Wood Burning Curtailment Levels ........................... 31

LIST OF TABLES

Table 1 Winter Average Emissions (tpd) from Residential Wood Combustion ............... 9

Table 2 Average Number of Days Forecast Above Curtailment Thresholds* ............... 20

Table 3 Days with PM2.5 ≥ 30μg/m3 ............................................................................ 23

Table 4 Proposed Standards for New Wood Stoves and Pellet Stoves ....................... 25

Table 5 Amendments from Implementing the Contingency Provision .......................... 33

Table 6 Summary of Proposed Increased Incentive Funding Amounts ........................ 39

APPENDICES

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 
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I. SUMMARY 

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) air quality is steadily improving, the Valley 

experiences unique and significant difficulties in achieving these increasingly stringent 

standards. The San Joaquin Valley Air Pollution Control District (District) has 

implemented several generations of emissions control measures for those stationary 

and area sources under its jurisdiction. Similarly, the California Air Resources Board 

(ARB) has adopted stringent regulations for mobile 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 regulations, greatly aided by the efforts of 

Valley businesses and residents, 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 evaluating all potential opportunities to reduce 

directly emitted PM2.5 emissions and PM2.5 precursors guided by the District’s Board 

adopted Guiding Principles and Health-Risk Reduction Strategy. One result of this 

extensive effort was the commitment to amend District Rule 4901 (Wood Burning 

Fireplaces and Wood Burning Heaters). Studies discussed later in this report show that 

emissions from residential wood burning are not only a major contributor to 

exceedances of the federal air quality standards for PM2.5 but are also toxic to human 

health and can even cause premature death. Modeling performed during the 

development of the Districts 2012 PM2.5 Plan demonstrates that reductions from this 

source are an essential component of attaining the federal air quality standards. 

The District takes a multidimensional and proactive approach to reducing emissions in 

the Valley. This philosophy is especially true for reducing emissions from residential 

wood burning with a combination of regulatory controls through Rule 4901, public 

outreach and education, and the District’s Burn Cleaner Wood Stove Change-out 

Program (Burn Cleaner Program). 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. 

These amendments will encourage Valley residents to transition from older more 

polluting wood burning heaters and wood burning 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 burn days allowed for registered clean wood burning heaters 

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/m3

 to 20 μg/m3. The 
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proposed amendments will significantly increase the number of permissible burn days 

for cleaner certified wood burning devices by raising the No Burn threshold to 65 μg/m3

. 

If approved, the proposed amendments 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 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. Updating the District’s Burn Cleaner 

Program amounts and accessibility will also assist with encouraging this transition. 

Emissions reduced through amendments to the program are significantly greater than 

those achieved by reducing the curtailment threshold alone, as demonstrated in this 

report. 

This section intentionally blank. 
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II. IMPORTANCE OF REDUCING RESIDENTIAL WOOD BURNING EMISSIONS 

Traditional regulatory controls are a core component of the District’s multi-faceted 

strategies to attain the PM2.5 federal health-based air quality standards. The extreme 

air quality challenges of the Valley demand that 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. Since 1992, the District has adopted over 500 rules 

and rule amendments, 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 reductions 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. 

A. PM2.5 ATTAINMENT 

Photochemical modeling conducted for the development of the District’s 2012 PM2.5 

Plan demonstrates that further reducing emissions from residential wood burning would 

contribute to improved PM2.5 air 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 meteorology 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 pollutant-scouring winds at bay most of the 

year. Temperature inversions, while present to some degree throughout the year, can 

last for days during the winter holding in nighttime 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 quality 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. 
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Figure 1 San Joaquin Valley Topography Traps Air Pollution 

The Valley’s natural challenge in cleaning out 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 reduce 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 number of months that 

strategies are most effective in reducing peak PM2.5 concentrations. 

2. Residential Wood Burning Emissions 

Wood smoke contains PM2.5 and an additional large 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 gases, 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 monitor carbon black as the definitive 

chemical signature of wood smoke, the study found night-time 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 season, 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-Field Exposures from Distributed Residential Wood Smoke 

Combustion Sources. Report prepared for the California Air Resources Board. Retrieved from 

http://www.arb.ca.gov/research/rsc/10-28-11/item2dfr07-308.pdf 
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very high intake fraction (the portion of the total emissions that actually end up being 

inhaled) from residential wood burning when compared to other sources of particulate 

matter that are less proximate. The following table is a summary of the winter average 

emissions in the Valley from the residential wood combustion source category as 

identified in the District’s 2012 PM2.5 Plan.

2

 

 

Table 1 Winter Average Emissions (tpd) from Residential 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 residential wood combustion contribute 15.6% of average winter 

PM2.5 emitted from stationary and area sources in the Valley’s 2012 emission 

inventory. The 2012 emission inventory 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 federal 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. Reducing emissions will expedite attainment 

and protect public health, which is a priority under the District’s Health-Risk Reduction 

Strategy given the significant localized health 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 journals and other major reports. Such scientific 

analyses, and the field studies providing the data for these analyses, 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 coordination for many of these efforts. In particular, the Study 

Agency’s $28 million, ongoing California Regional Particulate Air Quality Study 

(CRPAQS) efforts have improved understanding of the Valley’s PM emissions, 

composition, and the dynamic atmospheric processes surrounding them. Through 

CRPAQS and the establishment of a strong scientific foundation about PM2.5 in the 

Valley, researchers have developed methods to identify the most efficient and costeffective emissions control strategies 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
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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 hours of sophisticated computer modeling and review by a 

team of technical staff, including close coordination with the District. The modeling 

approach was reviewed and vetted through a technical 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 nighttime 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 REDUCING WOOD SMOKE EXPOSURE 

Based on a large body of interrelated scientific research conducted in the Valley and 

elsewhere, episodic curtailments of residential wood combustion 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 level of cumulative population exposure to urban 

residential wood combustion emissions compared to other sources, (2) the relative 

effectiveness of burning curtailments in reducing per capita PM2.5 exposure levels in 

urban areas where the Valley population is concentrated, (3) the relative toxicity of 

chemicals found in PM2.5 that are generated 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 prioritizing control strategies for individual 

emission sources. 

Polycyclic aromatic hydrocarbon species are recognized as potential carcinogens and 

are also highly implicated in the triggering of oxidative stress that promotes the 

malfunctioning of the immune system, particularly 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 inhalation of wood smoke contributes to chronic 

 3

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

Medicine 60:612–616. Retrieved from http://oem.bmj.com/content/60/8/612.full
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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 systemic effects such as oxidative stress and 

blood coagulation, which can ultimately result 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 enclosed geophysical environment of the Valley acts to magnify 

the health impacts of wintertime residential wood combustion. The Valley regularly 

experiences multi-day periods of atmospheric 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 concentration of directly emitted 

particulates that envelop urban neighborhoods. 

Windows and doors cannot prevent ultrafine particles in wood smoke from penetrating 

homes, meaning neighboring households that are downwind of wood-burning neighbors 

during inversion events are exposed to the wood smoke of their neighbors. 

In 2008, the Central Valley Health Policy Institute found that District wood burning 

curtailments on high pollution days reduced annual exposure by 13.6% in daily PM2.5 

exposure for Fresno, and an estimated 12.9% for Bakersfield12 resulting in 30 to 70 

avoided cases of annual premature mortality. The increase in the number of curtailment 

days resulting from the lower threshold adopted in the 2008 amendments to Rule 4901 

has resulted in a proportional increase in the health benefits of the rule. Further 

proportional health benefits can be expected from lowering the threshold again. 

 4

 Defined as a group of lung diseases affecting the interstitium 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. 5

 Pulmonary arterial hypertension begins when tiny arteries in the lungs, called pulmonary arteries, 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.; Martinez, C.; Portales, A.; Palomar, A.; Villegas, M.; and Barrios, R. 

Pulmonary Arterial Hypertension and Cor Pulmonale Associated 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. Oxidatively 

damaged DNA & its repair after experimental exposure 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 Markers of Inflammation, Coagulation, 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. Woodsmoke Air Pollution and Changes in Pulmonary Function Among 

Elementary School Children (1991) Air & Waste Management Association 84th Annual Meeting & 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, California State University, Fresno. See www.cvhpi.org. 
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III. UNDERSTANDING INFLUENCE OF METEOROLOGICAL CONDITIONS ON 

ELEVATED PM2.5

Weather plays a key role in atmospheric PM2.5 concentrations. Various meteorological 

conditions not only determine how fast PM2.5 particles are dispersed, it also controls 

how fast photochemistry converts precursor emissions into PM2.5 and controls whether 

or not certain gases are in a particulate (solid) phase or a gas phase. There are several 

key meteorological physical properties that influence PM2.5 concentrations. 

A. WIND AND TEMPERATURE INSTABILITY PROVIDE THE STRONGEST 

MECHANISMS FOR POLLUTION DIFFUSION 

A common misconception is that rainfall is what primarily disperses pollutants; however, 

horizontal and vertical mixing is required to disperse PM2.5 pollutants in the air. PM2.5 

levels will not decrease on days when there is rainfall without significant wind. In order 

to disperse particulates in the atmosphere, wind flow (horizontal mixing) and/or 

temperature instability (decreasing temperature 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 improves air quality. 

B. HUMIDITY AND SUNLIGHT CONTRIBUTE TO PM2.5 CONCENTRATIONS 

Humidity and sunlight can lead to the creation 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, relative humidity, and the composition of the pre-existing 

particles that act as condensation substrate (Wexler and Seinfeld, 1991).13 The fraction 

of reactive nitrogen that forms nitric acid and/or nitrate depends on the concentration of 

NOx and VOC as well as meteorological conditions 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 Effect of Intra-Annual Temperature Variability on Urban 

Air Pollution. Journal of Geophysical Research-Atmospheres 108 (D12).
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IV. CURRENT APPROACH TO REDUCE EMISSIONS 

The District takes a multifaceted and proactive approach to reducing emissions from 

residential wood burning. Equally 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 incentive programs to assist with the cost 

impacts of replacing older more polluting wood burning heaters and wood burning 

fireplaces with cleaner alternatives. 

A. DISTRICT RULE 4901 

District Rule 4901 is one of the most health protective 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 wintertime directly emitted PM2.5 emissions in the Valley. 

Applicable to wood burning fireplaces, wood burning heaters, and outdoor wood burning 

devices, Rule 4901 limits emissions by restricting the sale and transfer of wood burning 

heaters to EPA certified wood burning heaters; setting limits on the number of wood 

burning fireplaces and wood burning heaters installed in new residential developments; 

establishing a list of prohibited fuel types; and implementing episodic wood burning 

curtailments for days when air quality is forecasted to exceed the curtailment threshold. 

B. 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 fireplaces 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. There are currently more than 30 hearth retailers in the 

Valley that have partnered with the District to successfully implement the Burn Cleaner 

Program. 

 

 15 Nguyen, K. & Dabdub, D. (2002). NOx and VOC Control and Its Effects on the Formation of Aerosols. Aerosol 

Science and Technology 36 (5), 560–572. 
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The Burn Cleaner Program helps residents overcome some of the financial obstacles in 

purchasing cleaner alternatives through multiple levels of incentive funding: 

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

 $250 to replace a qualifying unit with a qualifying 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-income criteria continues to be critical in assisting lowincome households with the transition to cleaner burning alternatives. 

Figure 2 Burn Cleaner Graphic 

During the 2013-14 wood-burning season the 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 the replacement of 38 wood burning 

heaters. To date, the District has provided funding of over $2.3 million towards the 

replacement of 4,083 wood burning heaters through the Burn Cleaner Program, of 

which, 323 are verified low-income Valley residents. 

Recently Implemented Enhancements 

The District recently implemented enhancements to the Burn Cleaner Program in the 

2013/14 winter season to further outreach efforts and improve the usability of the 

program. The following is a summary of some of the key enhancements: 

Low-income provisions

As part of the District’s ongoing efforts to encourage more low-income qualified 

applicants to participate in the Burn Cleaner Program, significant enhancements were 

made to the low-income category 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 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 point of purchase. 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. 
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Even though a higher incentive amount is provided 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 low-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 available in Spanish to further extend the outreach efforts 

to the local community. While District staff is open and available to assist applicants 

with explaining how the program works and filling out the 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 them more user-friendly and has further 

improved the process during the application, installation, and claim for payment request 

phases. Key enhancements include: 

 Submittal of the pre-installation photo of the old wood burning heater or wood 

burning fireplace during the application phase to determine 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 everything 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 participating hearth retailers

The District has renewed its contracts with the hearth retailers and hosted informational 

meetings to discuss program changes in order to ensure a smooth roll out of the 

enhancements. As part of the District’s initiative to increase the effectiveness of the 

program, District staff has worked closely with the participating hearth retailers on 

outreach efforts and provided them with promotional tools, such as flyers and quick 

screens with information about the Burn Cleaner Program. 
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C. PUBLIC EDUCATION AND OUTREACH 

The District has an 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 population’s health, and on options they can take to reduce 

emissions. In the 2013-14 wood-burning season the District took part in 51 media 

interviews about extreme weather 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 adoption of Rule 4901 have been assisted by strong 

multimedia outreach by the District and a resultant increase 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 opinion, 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 the 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 public call and website “hit” statistics, plus 

growth in the District’s Facebook page activity, also illustrate continued growth in woodburning awareness. Survey results discussed 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 Wood Burning Program September 18, 2014 

 17 Final Draft Staff Report with Appendices for 

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Figure 4 District RAAN and iPhone App Images 

 

The District also incorporates wood-burning messaging into other public outreach 

products, including Healthy Air Living Schools materials, “Blue Sky, Brown Sky ... It’s 

Up to You!” elementary curriculum and other materials. 

Figure 5 District Healthy Air Living Graphics 

 

Multimedia Advertising Campaign 

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 members, with billboards in English 

and Spanish strategically placed throughout the Valley, radio and TV spots, and valueadded messaging delivered through media 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 the 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, such 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 Wood 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 market, which includes the District’s northern 

counties, the wood-burning message runs on two 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 billboards (including large-format vinyl 

billboards) and smaller “one-sheets” in Environmental 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-traffic areas as well as neighborhood and rural 

communities to ensure a wide reach in those areas where residential wood burning 

might be common. 

The District’s print campaign includes 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 offers the opportunity to promote seasonal 

campaigns. Media buys allow leveraging buying 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 Wood Burning Program September 18, 2014 

 19 Final Draft Staff Report with Appendices for 

Proposed Amendments to Residential Wood Burning Program 

V. EVALUATION OF POTENTIAL REGULATORY OPPORTUNITIES TO REDUCE 

EMISSIONS 

The District periodically evaluates stationary sources for potential opportunities to 

further reduce emissions. Potential 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 wood burning heaters under 

certain circumstances, the possibility of extending the wood burning season, and the 

possibility of amending the portion of the rule pertaining to the quantity of units allowed 

in new developments. These potential opportunities were further evaluated as a part of 

the development of these rule amendments. The following is a summary of those 

evaluations. 

A. INCREASE NO BURN DAYS FOR NON-REGISTERED WOOD BURNING 

HEATERS AND WOOD BURNING FIREPLACES BY LOWERING THE 

CURTAILMENT LEVEL 

Currently the District prohibits residential wood burning activities in each County within 

the Valley when PM2.5 concentrations are forecast to equal to or exceed 30 μg/m3

 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 average number of additional No Burn days likely to occur in 

future years as a result of lowering the curtailment 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 calculated 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 average 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 several variables as discussed in this staff 

report. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Draft Staff Report: Residential Wood 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 increase a resident’s natural gas costs from 

using a central heating system in lieu of a wood 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 effective rule for reducing directly emitted 

PM2.5 emissions. 

B. ENCOURAGE TRANSITION TO CLEAN BURNING HEATERS 

The Valley would experience greater air quality and health benefits throughout the wood 

burning season if more residents transitioned from older more polluting 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 Valley residents (see Appendix E) revealed 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 fireplaces, refer to Figure 6 Proportion of Residents with a 

Wood-Burning Fireplace, Wood Stove or Pellet Stove) for a graphical representation of 

the proportion of Valley residents with wood burning heaters, pellet-fueled wood burning 

heaters, and wood burning fireplaces. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Draft Staff Report: Residential Wood 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 dirtier counterparts, refer to Figure 7 for the EPA 

reported average PM2.5 emissions based on wood burning heater type. 

Survey results indicate the most effective ways to encourage transition to clean burning 

heaters is to allow more wood burning days 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 instead of the older more polluting wood 

burning heaters and wood burning 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 Wood 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 type16

C. ALLOW MORE BURNING DAYS FOR CLEAN BURNING HEATERS 

A tiered approach to episodic wood burning curtailments would allow more burn days 

for less polluting wood burning heaters at the same time as increasing 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 burning heaters and wood burning fireplaces from the current 

level of 30 μg/m3 to 20 μg/m3 as discussed above, 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 reducing 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 curtailments. See Figure 10 on page 30 for 

a visual representation of the proposed new tiered episodic curtailment approach. 

 

16Modified from: EPA. Consumers – Energy Efficiency and Wood-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 Wood 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 season was analyzed as a potential opportunity 

for further reducing emissions from the residential wood burning source category. The 

current wood-burning season runs from the beginning of November 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 levoglucosan, a primary indicator for wood burning, 

are not nearly as high in October or March as found to be during the current wood 

burning season of November through February. Additionally, a six-year average was 

calculated for the number of No Burn days in each county from 2008 through 2013 for 

the months of October and March as illustrated in Table 3. The resulting estimated 

number of increased No Burn days based on historical 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 combination of less extensive burning activity 

and the minute number of additional No Burn days. Therefore, it is not recommended 

that the wood burning season be extended. 

Table 3 Days with PM2.5 ≥ 30μg/m3

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

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Proposed Amendments to Residential Wood Burning Program 

E. RE-EVALUATE CURRENT EXEMPTIONS 

District Rule 4901 currently has two exemptions 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 emissions; therefore, no amendments to the exemption section 

of Rule 4901 are recommended at this time. 

F. EPA PROPOSED NEW SOURCE PERFORMANCE STANDARDS (NSPS) 

On February 3, 2014, EPA published proposed amendments to 40 CFR Part 60 Subpart 

AAA, Standards of Performance for New Residential Wood Heaters.17 The proposed 

rule lowers emission limits for currently certified wood heaters and sets certification 

emission limits for a broader range of wood- or pellet-burning heaters, stoves, and 

home heating appliances not previously included in the regulation, including all pellet 

stoves, single burn rate wood or pellet-burning stoves and heaters. Additionally, the 

proposed rule strengthens testing methods and certification 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 other 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 weigh 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 units equipped with a catalytic combustor and 

7.5 g/hr for units without a catalytic combustor. Units certified to these emission limits 

are said to be Phase-II Certified and will maintain that certification until the certification 

expires, which is up to 5 years from the issuance date. 

Under the current NSPS, pellet stoves are not explicitly exempt from required 

certification; however, most models currently sold fall outside the regulation because 

they operate on an air-to-fuel ratio greater than 35-to-1. Single burn rate wood heaters 

are also not explicitly exempt from the current NSPS but are not regulated by it because 

they operate below the burn rate criteria 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 Wood 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 the certification emission limits for woodburning heaters that are currently required to be certified and sets certification limits for 

a broader range of wood-burning heaters by removing the existing certification criteria 

1–4 above. Moving forward, if the proposed NSPS is finalized as-is with no 

amendments prior to finalization, then certification will be required for all pellet stoves 

and heaters, all single burn rate wood heaters, and all existing previously certified 

adjustable burn rate wood heaters once their current certification 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 emission limit of 1.3 g/hr for all woodstoves and 

pellet stoves. Refer to Table 4 for the proposed standards and phase-in schedules. 

With implementation of the proposed NSPS, all existing previously certified adjustable 

burn rate wood heaters will be required to either obtain certification under the new 

emission limits or cease production once their current certification expires. 

Although they do not require EPA certification, 96 percent of pellet heaters meet the 

proposed Step 1 PM emissions limit of 4.5 grams per hour. Single burn rate wood 

heaters are incapable of operating at the lowest burn rates, and it is the lower burn rates 

that result in the highest level of PM emissions; therefore, most single burn rate wood 

heaters will also meet the proposed Step 1 PM emissions limit. 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 retail 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 Stoves18 and Pellet Stoves19

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-rate. 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 Wood Burning Program September 18, 2014 

 26 Final Draft Staff Report with Appendices for 

Proposed Amendments to Residential Wood Burning Program 

VI. PROPOSED AMENDMENTS TO THE DISTRICT’S RESIDENTIAL WOOD 

BURNING PROGRAM 

Proposed amendments to the District’s Residential Wood Burning Program would 

encourage owners and users of older more polluting wood burning heaters and wood 

burning fireplaces to transition to less polluting alternatives. This transition would 

benefit Valley air quality throughout the wood burning season regardless of episodic 

wood burning curtailments because clean wood burning heaters produce significantly 

less emissions then older more polluting wood burning heaters and wood burning 

fireplaces as illustrated in Figure 7 in this staff report. Emissions reduced as a result of 

amendments to the Residential Wood Burning Program 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 amendments to the District’s Residential Wood 

Burning program: 

1. Amendments to Rule 4901 language 

a. Incorporate tiered episodic wood burning curtailments 

b. Add a registration program for qualified wood burning heaters, 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 for 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 Registration of Wood Burning Heaters) 

3. Enhancements to the District’s Burn Cleaner incentive program 

4. Enhancements to the District’s forecasting activities to support the tiered 

curtailments 

A. PROPOSED AMENDMENTS TO RULE 4901 

Refer to this section for a description of the rule amendments to Rule 4901 and refer to 

the proposed rule for the proposed language changes. 

1. Section 1.0 (Purpose) 

The purpose of the rule would be updated to remove outdated language stating that the 

District will establish a public education program. The removed language is no longer 

relevant because the District has already established a robust educational program for 

residential wood burning heaters as discussed in other sections of this 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 heaters, as mentioned throughout the rule, and to remove “wood 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

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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 therefore redundant. 

3. “Phase II” rule clarifications 

EPA’s proposal of amending the existing NSPS for certification requirements for new 

wood burning heaters does not currently include 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 enforced 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 following sections: 

 Section 3.6 (Definition of “EPA Certified”) 

 Section 5.1 (Sale or Transfer 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 (Administrative Requirements) 

4. Addition of “NSPS” for clarification of federal requirements 

To ensure compliance with the most recent and up-to-date federal standards, the rule 

would be amended to add the “NSPS” as the acronym 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, the numbering will also be affected. For purposes of this 

staff report, the following amendment summaries are discussed using the updated draft 

numbering. 

Section 3.6 (EPA Phase II Certified) would be amended to replace the Code of Federal 

Regulations Part 60, Subpart AAA with NSPS consistent with the previous discussion. 

Section 3.10 (Masonry Heater) would be updated to make it consistent with rule 

requirements in Section 5.1.2, and to clarify that a solid fuel is wood fuel. 

Section 3.13 (Normal Operating Conditions) would be added to the rule to establish 

what the District considers and will enforce as normal operating conditions for a 

registered wood burning heater, this new definition is in support of new Section 

5.6.1.2.4. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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

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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 Device) would be amended to remove the 

redundant “wood burning stove” language, 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-fueled 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) would be updated to clarify requirements by 

replacing “device” with “wood burning heater.” 

Section 3.23 (Sole Source) would be removed from rule language because it is 

redundant to rule requirements in Section 5.6.3.2. 

Section 3.28 (Wood Burning Fireplace) would 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 supported 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 included in the wood burning 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 exemption, but a clarification 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 advertises, sells, offers for sale, supplies, 

installs, or transfers a new wood burning heater. This section would be amended to 

clarify that these requirements are applicable to the sale and to the transfer of new and 

used wood burning heaters. Rule language would be amended to clarify that the 

certification of wood burning heaters 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 Wood Burning Program September 18, 2014 

 29 Final Draft Staff Report with Appendices for 

Proposed Amendments to Residential Wood Burning Program 

certification criteria of wood 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 amendment, 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 wood burning heater is sold or 

installed in the Valley that it is the cleanest available wood burning heater to ensure 

emissions continue to decrease from this source category. As such this section would 

be amended to clarify that the wood burning heater must have the most stringent EPA 

certification as currently enforced by EPA. If the wood burning heater is a pellet-fueled 

unit, then it must be either exempt from EPA certification requirements pursuant to 

language in the NSPS or it must be certified pursuant to the NSPS, whichever is more 

stringent at the time of purchase or installation 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 Transfer of Real Property) 

Section 5.2 would be amended to incorporate 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 residential developments. Current 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 installation 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 provide time for builders to comply with new 

standards, which is consistent with the time frame provided in the 2003 amendments to 

Rule 4901 which first introduced these requirements to the rule. 

a) Section 5.3.1 (Effective 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 Wood 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 burning 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 the installation of a wood burning fireplace in a residential 

development with a density greater 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 the 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 developments 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 level. District Rule 4901 is more stringent in that for the 

extremely limited cases where wood burning devices are allowed 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 replacing the term “solid fuel burning device” with an 

identification of the applicable units – wood burning fireplace, wood burning heater, or 

outdoor wood burning device. 
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Final Draft Staff Report: Residential Wood 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 Curtailments) would be amended to replace 

existing language with a two-tiered episodic wood burning curtailment program. The 

first tier would lower the existing residential wood burning curtailment threshold from the 

current threshold of 30 μg/m3

 to a new more stringent limit of 20 μg/m3. This will 

increase the number of No Burn days for residential wood burning. The addition of a 

second tier would effectively create a window 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 Episodic 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 forecast to be equal to or exceed 20 μg/m3

 but not 

to exceed 65 μg/m3

. The use of registered wood burning heaters would be allowed 

provided it is operated in compliance with rule requirements. When PM2.5 

concentrations are in this range it is generally because the air has become stagnant and 

the pollutant concentrations are rising. Prohibiting the use of dirty wood burning heaters 

and wood burning fireplaces would dramatically 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 Wood 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 Episodic Wood Burning Curtailment) 

Section 5.6.2 would be amended to add provisions to the rule for Level Two Episodic 

Wood Burning Curtailments. A Level Two Wood Burning Curtailment would be called 

when the PM2.5 concentrations are forecast to exceed 65 μg/m3

 for a given region. No 

wood burning heaters, wood burning fireplaces, or outdoor wood burning devices 

located in the region shall be operated during a Level Two Episodic curtailment. 

The PM10 135 μg/m3

 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 butane to the list of gases that are not 

considered natural gas. This addition clarifies 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 simplify and clarify rule requirements. 

e) Section 5.6.5 (Contingency Provision) 

Section 5.6.5 would be deleted 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 demonstration or the Reasonable Further 

Progress (RFP) demonstration. Contingency measures must be fully adopted rules or 

control measures that are ready to be implemented 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 lowering the curtailment level to 20 μg/m3 of 

PM2.5, to be triggered with an EPA finding that 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 Plan21, approved by EPA on May 22, 201422. 

However, with this 2014 amendment to the Rule 4901 curtailment level, the District will 

already be implementing a curtailment 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 wood burning season, more than 

what would have been achieved through the contingency measure commitment for 

2015 (see Table 5). Even if the District assumed 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 
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Final Draft Staff Report: Residential Wood 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 commitment required under the contingency. 

However, as discussed earlier, results of the scientific survey indicate that a much 

larger percentage of people will be transitioning to cleaner devices and the emissions 

reductions achieved through the proposed amendments will be significantly higher.. 

Thus, the lowered curtailment level in the 2014 amendment to Rule 4901 can take the 

place of the previous Section 5.6.5 contingency measure, and Section 5.6.5 can be 

removed from the rule. 

 

It is also important to note that the proposed 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 the contingency measure 

alone. Proposed amendments to the residential wood burning program will reduce an 

estimated 5.1 tons per day (tpd) of directly emitted PM2.5 emissions (see Appendix B 

Table B-10); whereas, implementation of the contingency provision would result in 3.40 

tpd PM2.5 emission reductions (see Table 5 below). 

Table 5 Amendments from Implementing 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 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 allowing certified devices to burn during a level one 

curtailment (greater than 20 μg/m3 but less than 65 μg/m3), the District proposes a 

registration program for these cleaner burning 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 the District to better focus 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Draft Staff Report: Residential Wood 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 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 burn 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 maintained properly, and refrain from burning 

prohibited materials. 

a) Section 5.7.1 (Eligibility for Registration) 

New Section 5.7.1 would establish eligibility requirements for 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 requirements will strengthen the standard and 

eliminate the “phase” nomenclature, making the use of clean burning heaters during 

Level One Episodic Curtailments challenging to define. The District recognizes that 

Valley residents have invested significant amounts 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 requirements. The District has also invested 

grant funds, as discussed in Section IV.B of this staff report, to assist with the purchase 

of these heaters. 

Wood burning heaters that qualify for registration include heaters that are EPA Phase II 

certified or have a more stringent certification pursuant to requirements in the Code of 

Federal Regulations (CFR), Part 60, Title 40, Subpart AAA at the time of purchase 

and/or installation, or an exempt pellet-fueled wood burning heater that is exempt 

pursuant to the aforementioned CFR at the time of purchase and/or installation. 

b) Section 5.7.2 (Interim Registration of Wood Burning Heaters) 

New Section 5.7.2 would provide a one season (2014-15) interim registration period to 

aid with the transition to the registration program for Valley residents. This interim 

period of transition will be a simplified version of the full registration program in that 

supplemental documentation, a registration fee, and a verification of inspection would 

not be required for this interim period. This section also clarifies that an interim 

registration obtained under false information is void and also an interim registration may 

be disqualified pursuant to Section 5.9 of the 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 effective 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 exceed plan commitments. 

c) Section 5.7.3 (Registration 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 
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Final Draft Staff Report: Residential Wood 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 interim registration process and be accompanied 

by a fee. The rule defines required information, documentation, operation requirements, 

and reference to new Rule 3901 for the registration fee. 

The applicant will be required to verify that 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 the manufacturer and the model name of the 

wood burning heater or a certification from a District Registered Wood Burning Heater 

Professional. Additionally, if the wood burning heater is older than twelve months, then 

the registration application will also require a certification of inspection from a District 

Registered Wood Burning Heater 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 process, registration renewals 

would also be accompanied by a fee. Section 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 often heater registrations would be required 

to be renewed and the documentation 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 operated and maintained per 

manufacturer specifications and continue to burn as cleanly as certified by the EPA. 

This registration renewal program would potentially 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 owners of said wood burning heaters are 

cleaning and maintaining them on a regular basis. 

14. Section 5.9 (Disqualification of Registration) 

New Section 5.9 would provide information on the disqualification process for heater 

registrations. This section discusses what actions would qualify for a disqualification of 

wood burning heater registration, how the District 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 (Registration of Wood Burning Heater Professionals) 

New Section 5.10 would define the requirements for a Registered Wood Burning Heater 

Professional. This section states what certifications would be required to qualify as a 

registered Wood Burning Heater Professional and the application process for registering 

as one. A list of registered Wood Burning Heater Professionals would be posted on the 

District’s webpage and made available upon request. 

This provision would be added to rule language to ensure that the District does not 

inadvertently exclude qualified individuals who have certifications 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 
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Final Draft Staff Report: Residential Wood 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 individuals 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 individuals by adding specific language to Section 5.10.2 that states 

“If the applicant does not have a certification 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 the applicant meets the certification standards as required 

by certifications pursuant to Sections 5.10.1.1 through 5.10.1.3.” 

a) Section 5.10.1 

New Section 5.10.1 would provide the qualification requirements that an individual must 

meet in order to register with the District as a Wood Burning Heater Professional. The 

District would require a professional certification from the Fireplace Investigation 

Research and Education (F.I.R.E), the Chimney Safety Institute of America (CSIA), or 

from the National Fireplace Institute (NFI) or an equivalent qualification as determined 

by the APCO. Each of the three certifications are voluntary certifications to establish 

standardized criteria for certification and are recognized as such industry-wide. 

The F.I.R.E. certification recognizes individuals as having the minimum professional 

training, education, and experience to inspect, investigate fire and explosion incidents, 

and/or participate in related civil and criminal litigation. This certification includes a 

training materials and a certification exam. Depending on options selected, the 

certification costs range between $1,795 and $2,385. Certifications are valid for three 

years. Inspectors become re-certified by either passing a test based on changes within 

the current edition of the International Residential Building Code/International Building 

Code, or by attending, completing, and showing 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 governed by volunteer industry professionals 

and technical experts, and is an American Society of Home Inspectors (ASHI) Affiliate. 

Certification includes an online or in-person review session, completion of exams, 

payment of annual certification fees, and signing 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). Certification 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 division of the Hearth, Patio & 

 

23 Fireplace Investigation Research and 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 Wood 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 organization for the hearth 

industry. Certification costs $399 for HPBA members and $598.50 for non-members. 

Certification is valid for three years and re-certification is achieved by submitting proof of 

completing required courses and a $139 certification fee, re-testing 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 documentation. 

c) Section 5.10.3 

New Section 5.10.3 defines that 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 identified 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 professional certifications and be valid until said certification 

expires, or three years, whichever is shorter. For those individuals without one of the 

aforementioned certifications who registers with the District as a Wood Burning Heater 

Professional as determined by the APCO, their registration would be valid for three 

years from the date of issuance from the District. 

d) Section 5.10.4 

New Section 5.10.4 would require 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 Registered Wood Burning Heaters) 

New Section 5.11 would allow District staff to inspect any wood burning heater 

registered with the District in order ensure enforceability of rule requirements. 

17. Section 6.0 (Administrative Requirements) 

New Section 6.2 would require the person who registers a qualified wood burning 

heater to keep a copy of the District issued 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 enforces 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 operation of a registered wood burning heater 

pursuant to Section 5.6.1.2.4 

 

25 National Fireplace Institute. (2014). Obtained from http://nficertified.org/pages_industry/industry-1v2.cfm. 
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Final Draft Staff Report: Residential Wood 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 (FEES FOR REGISTRATION OF WOOD 

BURNING HEATERS) 

New Rule 3901 (Fees for Registration of Wood Burning Heaters) would be created to 

complement amendments to Rule 4901. This rule would specify specific fee amounts 

and process requirements for the registration of heaters pursuant to Section 5.7.1 of 

Rule 4901. 

The applicant would be required to pay a registration 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 registration program identified that resources would 

be required from the ITS Department, the Finance Department, and the Compliance 

Department to implement the registration program. Conservative estimates determined 

an average of one hour of staff time (at $100/hr) would be needed for each application. 

However, the District recognizes that additional 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 seasons unless the registration is disqualified by 

the District. The District commits to notify persons with registered heaters 60 days prior 

to expiration of said registration of the upcoming expiration date. 

C. ENHANCEMENTS TO THE DISTRICT’S BURN CLEANER INCENTIVE 

PROGRAM 

The District continues to take proactive steps to enhance the Burn Cleaner Program. 

The District works with its program partners and is also actively engaged with the 

community and hearth industry to encourage participation 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 Valley 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.26 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 District’s database of funded Burn Cleaner projects. 

The increase in incentive funding amounts would encourage more residential property 

owners to replace their existing heaters 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/2014/march/final/09.pdf. 
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 39 Final Draft Staff Report with Appendices for 

Proposed Amendments to Residential Wood Burning Program 

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

low-income qualified applicants would help them pay for a majority of the costs of a 

replacement, as many are unable to afford 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 installation costs beyond the proposed funding 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 evaluated the option of providing low-income 

tenants an opportunity to reduce their emissions from residential wood burning through 

the Burn Cleaner Program. The tenants are directly affected by the emissions produced 

from using older, higher-polluting heaters, and any associated utility costs with the 

home. As a result, the District is proposing to extend the low-income provisions to 

homeowners who rent to low-income qualified tenants, provided specific criteria are met 

through a careful District review and approval process. 

The proposed criteria include the following: 

o Residential properties owned by local Public Housing Authorities are ineligible. 

o Residential properties with eligible heaters must have existing tenants that either: 

1) Qualify under the Housing Choice Voucher Program (Section 8); or 

2) Meet the program’s low-income eligibility requirements (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 valid signed lease/rental agreements with 

eligible low-income tenants with at least 6 months remaining on the lease. 
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 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 guidelines and applications to allow applicants 

the option to receive their approved voucher packets via email. This option will help the 

qualified applicant move forward with the purchase and installation of their new heater 

more quickly instead of waiting for approval by standard mail. 

D. ENHANCED FORECASTING 

Calling residential wood-burning curtailments at lower levels minimizes direct PM2.5 

emissions, thus lowering the rate of PM2.5 build-up during periods of atmospheric 

stagnation. The District already dedicates sufficient resources and technological tools 

to the forecasting staff for the existing episodic curtailment program. However, the new 

tiered curtailment approach will require additional time and effort to ensure that 

forecasts account for the two proposed threshold 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 curtailment approach. Accuracy of forecasts will 

ensure that the appropriate episodic curtailment level is called by the District based on 

the weather conditions and pollutant concentrations forecast for each day. 

This section intentionally blank. 
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Final Draft Staff Report: Residential Wood Burning Program September 18, 2014 

 41 Final Draft Staff Report with Appendices for 

Proposed Amendments to Residential Wood Burning Program 

VII. ADDITIONAL ANALYSES 

A. GLOBAL CLIMATE CHANGE AND GREENHOUSE GASES 

The California Global Warming Solutions Act of 2006 (AB 32) created a comprehensive, 

multi-year program to reduce greenhouse gas (GHG) emissions in California, with the 

overall goal of restoring emissions 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 rationale that climate change is occurring is compelling and 

convincing. In addition to the long-term consequences of climate change, the District is 

concerned with the potential ramifications of more moderate but imminent changes in 

weather patterns. The Valley depends heavily on agriculture for its economy and has 

developed agricultural practices based on the last several decades of weather patterns. 

Unanticipated and large fluctuations in these patterns could have a devastating effect 

on the Valley’s economy. 

While there are many win-win strategies that can reduce both GHG and criteria/toxic 

pollutant emissions, when faced with situations that involve tradeoffs between the two, 

the District believes that the more immediate public health concerns that may arise from 

an increase in criteria or toxic pollutant emissions should take precedence. The District 

Governing Board adopted the Climate Change Action Plan (CCAP) in August 2008. For 

California Environmental Quality Act (CEQA) requirements, one of the goals of the 

CCAP is to establish District processes for 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 efficient, effective and entrepreneurial air quality 

management strategies. The District periodically compiles attainment plans to identify 

individual regulations and other strategies that will achieve the emissions reductions 

needed for the Valley to meet federal health-based air quality standards. Guided by its 

Health-Risk Reduction Strategy, the District 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 manner. The control strategy as a whole, 

then, has important public health 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 emissions, it benefits public 

health by contributing to improved ozone and PM2.5 air quality. 

C. EMISSION REDUCTION ANALYSIS 

District staff evaluated the emissions reductions that would result from amendments to 

Rule 4901. The District’s 2012 PM2.5 Plan committed the District to reduce 1.5 tons 
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Final Draft Staff Report: Residential Wood Burning Program September 18, 2014 

 42 Final Draft Staff Report with Appendices for 

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per day of directly emitted PM2.5 upon full implementation 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/m3

 to 20 

μg/m3

, 

 0.065 tons/day increase in emissions if all existing clean certified units registered 

and burned on days when PM2.5 concentrations are projected to be between 30 

μg/m3

 to 65 μg/m3, 

 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 projected to be between 20 μg/m3

 to 65 μg/m3, and 

 2.04 tons/day of reductions from the transition of older dirtier wood burning 

heaters and wood burning fireplaces to cleaner certified devices. 

Refer to Appendix B (Emission Reduction Analysis) for the analysis for Rule 4901. Rule 

3901 has no emissions reductions associated with it therefore there is no emission 

reductions analysis for Rule 3901. 

D. ECONOMIC ANALYSES 

1. Cost Effectiveness Analysis 

Pursuant to California Health & Safety Code (CH&SC) Section 40920.6(a), the District 

analyzes the cost effectiveness of new rules or rule amendments. The amendments 

are cost effective. Refer to Appendix C (Economic Analyses) for the analysis for Rule 

4901. Rule 3901 does not have emissions reductions associated with it; therefore there 

is no cost effectiveness analysis for Rule 3901. 

2. Socioeconomic Analysis 

Pursuant to CH&SC Section 40728.5(a), “Whenever a district intends to propose the 

adoption, amendment, or repeal of a rule or regulation 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 regulation.” No significant socioeconomic impacts are expected 

from these rule amendments. Refer to Appendix C (Economic Analyses) for the 

analysis for amendments to Rule 4901. Rule 3901 will not significantly affect air quality 

or emissions limitations; therefore, is not subject to a socioeconomic analysis. 

E. RULE CONSISTENCY ANALYSIS 

Pursuant to Sections 40727 and 40727.2 of the California Health and Safety Code, prior 

to adopting, amending, or repealing 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 elements of existing or proposed District rules, existing 
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Final Draft Staff Report: Residential Wood 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 rules, regulations, and guidelines that apply to the same 

source category. The rule elements analyzed are emission limits, monitoring and 

testing requirements, recordkeeping and reporting requirements, and operating 

parameters and work practice requirements. Amendments to Rule 4901 and 

requirements in new Rule 3901 do not conflict 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 rules or regulations or fee rules tailored 

specifically for wood burning fireplaces or wood burning heaters; therefore, there are no 

rules in conflict with or inconsistent with the requirements of Rule 4901 and Rule 3901. 

State Rules, Regulations, and Policies 

There are no identified California 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 Techniques Guidelines (CTG), 

Alternative Control Techniques (ACT), National Emission Standards for Hazardous Air 

Pollutants (NESHAP), or Maximum Achievable 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 amendments to the NSPS, the standard has 

not yet been finalized at the time of these proposed rule amendments and therefore 

cannot be compared to the existing or the proposed rule. 

F. CALIFORNIA ENVIRONMENTAL QUALITY ACT ANALYSIS 

According to the California Environmental Quality Act (CEQA) statutes and pursuant to 

Section 15061 of the CEQA Guidelines, 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 effect on the environment (CEQA 

Guidelines §15061 (b)(3)). Therefore pursuant to Section 15062 of the CEQA 

Guidelines, Staff will file a Notice of Exemption upon Governing Board approval of 

amendments to Rule 4901. 
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Proposed Amendments to Residential Wood Burning Program 

VIII. RULE DEVELOPMENT PROCESS 

The public process for these rule amendments 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 amendments 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. The web page includes information about the existing rule 

and proposed amendments under consideration, District 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 opportunity to reduce emissions of directly 

emitted PM2.5 in the Valley. Additionally, because emission reductions from residential 

wood burning activities occur at the neighborhood level, amending this rule is a priority 

under the District’s Health-Risk Reduction Strategy; 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 comments beyond those provided 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 received 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 representatives of the Hearth, Patio & 

Barbeque Association. The technical workgroup committee met once a month for five 

months during the summer of 2013 to discuss individual aspects of rule requirements, 

implementation, and alternatives. Topics of discussion at these proactive, productive, 

and cooperative meetings included the pros and cons of implementing a tiered 

curtailment approach in the Valley; enforcement of existing and future rule 

requirements; the Districts current Burn Cleaner incentive program and potential 
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 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 heaters, regulations, and 

incentive programs. Information gained during these technical workgroup meetings has 

been incorporated into the staff report, amendments 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 third party company, Gomez Research, 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 rule, the Burn Cleaner incentive program, and District public 

outreach and education efforts. 

The study results show a great understanding 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 popular 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-burning activity in response to the 

program 

 Just 17% of respondents knew about the Districts’ Burn Cleaner incentive 

program 

 In assessing what would motivate an owner 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 
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 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 information and plan commitments, new NSPS 

regulations, potential methods of public outreach, and potential incentive program 

enhancements. The District then solicited feedback and comments from the public at 

the workshop and for a two week comment period after the workshop that ended at 5:00 

PM on Thursday, April 10, 2014. Refer to Appendix A (Comments and Responses) for 

a summary of significant comments and District responses. 

The District hosted a public workshop on the evening 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, staff 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 amendments. The public is invited to provide 

comments to District Governing Board Members during the public hearing. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses 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 Residential Wood Burning Program 

September 18, 2014 
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SUMMARY OF SIGNIFICANT COMMENTS 

RULE 4901 (WOOD BURNING 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 Control District (District) on August 19, 2014. 

Summaries of significant comments received 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 contribute to our high PM in the winter 

months. The amount of vehicles that travel in our Valley as well as the PM that 

enters from outside our Valley is hard to control, 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 impact on the emissions of particulate matter 

that is released into the atmosphere. Humans are capable of change, it’s the big 

changes too fast that make us feel like we have no control or say so about our 

everyday lives. Then we start pointing fingers 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 the federal health-based ambient air quality 

standards are unmatched by any other region in the nation. In response to these 

federal mandates and to improve quality of life for Valley residents, the District has 

developed and implemented multiple 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 federal standards. 

The District’s attainment plans contain a comprehensive set of local and state 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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A - 4 Final Draft Staff Report with Appendices for 

Proposed Amendments to Residential Wood Burning Program 

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. Although the District is not 

proposing to control the type of wood residents 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 increasing the number of burn days allowed for 

registered clean wood burning 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 allowed for EPA certified wood burners 

allows an unjustified increase in emissions 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 curtailment levels. 

 Wood burning in fireplaces and dirty stoves should be totally banned in the Valley 

at forecasted levels higher than 12-15 μg/m3

 as this is the new EPA health based 

standard. 

 There should be no new fireplaces installed 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 inserts but not to certified wood inserts. 

 The reductions gained from the dirty wood stoves only burning on days below 20 

μg/m3 is totally offset by the certified stoves burning between 20 and 65 μg/m3

because the certified stove emits 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/m3

 will be incentive enough for people to make 

the conversion from a dirty wood stove to a certified wood stove. 

 There should be a cost effectiveness analysis for the proposed increase to 

economic incentives. $1,000 to change a dirty wood stove to a certified wood 

stove then operating those stoves 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/m3 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/m3 threshold. This proposed curtailment level is significantly lower than the 

current curtailment threshold of 30 μg/m3

. Amending the rule to allow the cleanest 

wood burning heaters to be used between 20 and 65 μg/m3

 would provide significant 
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A - 5 Final Draft Staff Report with Appendices for 

Proposed Amendments to Residential Wood Burning Program 

motivation to Valley residents for transitioning 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 burning heater pollutes at 

least twenty times less than a wood burning fireplace (refer to Figure 7 in the final 

draft staff report); therefore, encouraging this transition would reduce emissions 

beyond those that could be accomplished by only reducing the curtailment threshold 

to 20 μg/m3

. The proposed amendments will achieve 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. 

 
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SUMMARY OF SIGNIFICANT COMMENTS 

RULE 4901 (WOOD BURNING 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 comments 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 Quality 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 (Section 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 California Environmental Justice Network; 

Catholic Charities, Stockton Diocese; College Community Congregational Church, UCC (Fresno); Coalition for Clean 

Air; and Sierra Club California Tehipite Chapter. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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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 confusion that the public may experience 

with a tiered curtailment program the District is preparing public outreach and 

educational materials that will build off of the already established outreach for 

residential wood burning. Public education and continuous messaging through 

multi-media as described in the staff report will enable the District to minimize 

potential confusion experienced by the public. Additionally, District staff is available 

to speak with members of the public and provide any requested clarifications about 

the tiered residential wood burning program. 

The proposed tiered episodic wood burning curtailment 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 effectively reducing directly emitted PM2.5 

emissions at the same time. The older more polluting wood burning heaters and 

wood burning fireplaces are expected to experience an increase of an average of 34 

additional No Burn days per wood burning season 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; therefore the users of these units would be 

purchasing more wood to burn in their wood 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 more polluting wood burning heaters or wood 

burning fireplaces, providing an overall benefit to the Valley. 

3. COMMENT: The incentives offered for residents to switch to cleaner burning wood 

burning heaters are great and the more incentives 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 multifaceted approach in reducing winter 

PM2.5 emissions. The increase in incentive amounts combined with the tiered 

episodic wood burning curtailments will encourage the transition from the older more 

polluting wood burning heaters and wood burning fireplaces to achieve emission 

reductions beyond those that would be reduced through offering larger incentive 

amounts alone. Refer to the staff report for a complete discussion. 
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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 installers 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 being 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 provision for qualified individuals 

who do not have one of the three identified certifications to become registered with 

the District as a Wood Burning Heater Professional, 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 for all wood burning devices in the 

Valley from 30 μg/m3

 to 65 μg/m3 is a relaxation of the rule. The draft curtailment 

threshold should be no higher than 30 μg/m3

. (CVAQ) 

RESPONSE: On the contrary, 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/m3 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/m3

 threshold. This proposed curtailment level is significantly 

lower than the current curtailment threshold of 30 μg/m3

. Amending the rule to allow 

the cleanest wood burning heaters to be used between 20 and 65 μg/m3 would 

provide significant motivation to Valley residents 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 would reduce emissions beyond those that 

could be accomplished by only reducing the curtailment threshold to 20 μg/m3

. 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 allow the installation of wood burning 

fireplaces and other wood burning devices in new residential developments. This is 

less stringent than South Coast AQMD (SCAQMD), which bans the installation of 

wood burning fireplaces and wood burning heaters in new developments. (CVAQ)
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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RESPONSE: The statement that SCAQMD does not allow the installation of wood 

burning devices in new developments is incorrect. In fact, SCAQMD Rule 445 

allows the installation of wood burning devices in new developments that have 

limited access to natural gas or are located above 3,000 feet. The District’s Rule 

4901 is actually more stringent in that for the extremely limited cases where wood 

burning devices are allowed to be installed, 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 certification 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 through 5.10.1.3 identify specific 

certifications, Section 5.10.1.4 provides criteria by which an individual without these 

certifications can become registered with the District to perform the inspections and 

certifications. Adding Section 5.10 to the 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 operating as cleanly as designed by the 

manufacturer and as certified by EPA. 

8. COMMENT: The rule should be clarified to state 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/m3

 dramatically increases the number of No Burn days and tilts the burden of 

reducing PM2.5 emissions far beyond the contribution that occasional residential 

wood burning makes to PM2.5 emissions in the Valley. Additionally, even though 

general fireplace usage declined significantly, pollution levels were still high; 

indicating other sources of PM2.5 drove increased pollution levels on warm stagnant 

air days. Proposed amendments effectively double the number of projected No Burn 

days and prohibits burning for most residents for more than half of the 120-day 

wintertime period. The District does not provide substantial evidence that such an 

incentive program will promote reduction of PM2.5 emissions. (DI) 

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) 
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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 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 resulted in abnormally high PM2.5 concentrations during the 2013-14 

winter season and the 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 (Scientific 

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 emissions. 

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 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 curtailments on high pollution 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. 

10. COMMENT: All pellet-fueled devices are either EPA certified or EPA exempt. 

Language should be added to the rule that allows the use of EPA-certified pellet 

heaters, not just EPA-exempt pellet heaters. Additionally, can people register pelletfueled devices without inspection for the interim 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). December 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%20Sci%20Foundation%20and%20Modeling.pdf. 
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RESPONSE: While it is true that all pellet-fueled wood burning heaters 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). Each 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 (Section 3.29) which would be amended to 

specifically identify pellet-fueled wood burning heaters. 

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SUMMARY OF SIGNIFICANT COMMENTS 

RULE 4901 (WOOD BURNING 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 comments 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 expressed differing opinions on the 

implementation of increased restrictions 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 members of the public oppose more stringent restrictions (LT, 

KH, KF). Some members of the public are in favor of more stringent restrictions 

then 20 μg/m3

 (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. Reducing emissions from this source 

provide some of the most cost effective and health protective emission reductions in 

the Valley as discussed throughout the staff report. That said, the District 

recognizes that replacing older more polluting wood burning heaters and wood 

burning fireplaces with less polluting alternatives 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 Responses 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 District is considering. Some commenters 

expressed support of a tiered approach to episodic wood burning 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 more polluting wood burning heaters and 

wood burning fireplaces to replace those units with less polluting alternatives such 

as EPA Phase II Certified wood burning 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 would be achieved by 

reducing the curtailment threshold alone. These increased emission reductions will 

result in health benefits and progress the Valley 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 March was presented to the public at the 

workshop. Some members of the public did not support expanding the wood 

burning season because the benefits gained through a longer would burning season 

would be minimal (KF), while others did support expanding the wood burning 

season. (TM)

RESPONSE: The District evaluated the potential benefits and feasibility of 

expanding the wood burning season to include one or two additional months and 

based on the results of the evaluation the District will not pursue expanding the 

wood burning season. See the staff report for more information. 

4. COMMENT: Some members of the public called for increased public outreach 

efforts, including more advertising on No Burn days, to promote the 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 proactive 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 opportunities for increased public outreach and 

education. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses 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. The 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 report violators. (LB, PC, TM) 

RESPONSE: Enforcement efforts currently include several phone numbers to report 

violations of episodic curtailments including 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 heaters, 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 registration program for qualifying wood 

burning heaters because it may discourage homeowners from buying these wood 

burning heaters, regardless of ultimately allowing them the right to burn. (HPBA) 

RESPONSE: A registration program provides the District with an enforcement 

mechanism which allows for the use of registered wood burning heaters to be used 

during certain times when the use of non-registered wood burning heaters would be 

prohibited. A registration program helps the District to ensure that the person who 

registers a qualifying wood burning heater understands all provisions of Rule 4901 

and operates the wood burning heater in compliance 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 implementation of a registration program, 

registration fees should be waived because homeowners make significant 

investments for these clean burning devices and making them pay District fees could 

discourage them from participating. (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 Valley residents register their devices if the 

District chooses to pursue this option. (BH, KVA)

RESPONSE: The District incurs additional staffing and other costs to create and 

maintain a registration program and would therefore need to recover some of these 

costs. Registration of a qualifying wood burning heater is voluntary; 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 Responses September 18, 2014 

A - 15 Final Draft Staff Report with Appendices for 

Proposed Amendments to Residential Wood Burning Program 

therefore not participate in the additional burn days provided through a tiered 

curtailment program. The District 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 regulating 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 businesses and not individual residents in the 

Valley. Many of the District’s prohibitory rules on Valley businesses are fourth or 

fifth generation, meaning they have been revised several times and emissions limits 

have been lowered as new emission control technologies have become available 

and cost effective. Valley businesses have invested millions of dollars to reduce 

emissions. With regards to the agricultural community specifically, emissions are 

reduced through District rules including but not limited to Rule 4702 (Internal 

Combustion Engines), Rule 4103 (Open Burning), 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 through regulatory actions, the District also 

provides incentive funding that is matched 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 recipients have invested over 

$400,000,000 in matching funds to purchase, replace, 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 the emissions are from residential 

wood burning? (MB) 

RESPONSE: Since PM2.5 measurements are mass-based, the mass can be 

separated into its various species components through an analysis called speciation. 

Speciation of the Valley’s PM2.5 emissions demonstrates that 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 burning 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 Responses 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 source 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 allowed to burn every single day 

regardless of air quality. (RL) 

RESPONSE: The District has evaluated the potential benefits of allowing additional 

days for clean burning devices to be utilized in the Valley and has drafted the 

episodic tiered curtailment levels to reflect this evaluation. Registered wood burning 

heaters would be allowed to be used and older more polluting wood burning heaters 

and wood burning fireplaces would not be allowed to be used when the air quality is 

forecast to have PM2.5 concentrations between 20 μg/m3

 and 65 μg/m3 because it is 

during this time that the fine particulates are building up in the Valleys air. 

Preventing the use of the more polluting wood burning heaters and wood burning 

fireplaces while at the same time allowing the use of registered wood burning 

heaters will slow down or even stop the accumulation 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/m3

, 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 much against wood-burning and never 

mentions other things people burn. Shutting down family business that are based on 

firewood sales will hurt the local economy. (CS) 

RESPONSE: District outreach efforts include educating 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 products, waste petroleum products, paints 

and paint solvents, coal, and any other material 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 support an increase in incentive funding 

for clean burning devices (RB, BH, KVA, HPBA), 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 Valley 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 Responses 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 tree 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 technologies 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 granted a permanent exemption 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 Code of Regulations 

require all homes, apartments, rooms for rent, or other habitable spaces be provided 

with heating facilities capable of maintaining minimum room temperature 

requirements, with the exception of certain limited-density owner-built rural 

dwellings. Open-hearth fireplaces do not comply with this code requirement, since 

such fireplaces do not function as efficient 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 Responses September 18, 2014 

A - 18 Final Draft Staff Report with Appendices for 

Proposed Amendments to Residential Wood Burning Program 

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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 Residential 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 program reduces directly emitted PM2.5 

emissions from residential wood burning 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 heaters and wood burning fireplaces (commonly 

called open hearth fireplaces) to cleaner alternatives. Emissions reduced as a result of 

the proposed amendments to the residential wood burning program would achieve 

emission reductions beyond those reduced through lowering the curtailment threshold in 

Rule 4901 alone. 

Proposed amendments to the program include amendments to District Rule 4901 

(Wood Burning Fireplaces and Wood Burning heaters) to implement a tiered episodic 

wood burning curtailment program; proposed new Rule 3901 (Fees for Registration of 

Wood Burning Heaters) to establish a fee structure to support a robust registration 

program for certified clean devices; and enhancements 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 accounts for the emissions reduced as a direct 

result of implementing the proposed tiered curtailment program. The second analysis 

accounts for the overall emissions reduced 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 season day. Even if the expected reductions 

from turnover to clean wood burning devices are not accounted for, the proposed 

amendments to Rule 4901 would result in a reduction 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 reduce 1.5 tpd of PM2.5 during the 

winter season (November through April) effective 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 reductions equates to 2.18 tpd when averaged 

over the entire winter season, exceeding 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 PROPOSED EPISODIC TIERED CURTAILMENT 

PROGRAM 

For purposes of claiming emission reductions in the SIP for proposed rule amendments 

this emission reduction analysis will only account for those emissions reduced as a 

result of the proposed tiered episodic curtailment program. The current episodic wood 

burning curtailment threshold level of 30 μg/m3 would be lowered to 20 μg/m3 for wood 

burning fireplaces and non-registered wood burning heaters. Proposed amendments 

would create a second tier to allow the use of registered wood burning heaters when 

pollutant levels are forecast to exceed 20 μg/m3 but not to exceed 65 μg/m3. All 

residential wood burning would be prohibited if the pollutant levels are forecast to 

exceed 65 μg/m3

. 

The calculations within this analysis are made with the conservative assumption that all 

wood burning heaters and wood burning 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 cleaner technologies. 

The emission reduction analysis was performed using the following steps: 

A. Identify the ARB emission inventory for residential wood burning devices 

B. Determine the wood-burning seasonal emissions from residential wood burning 

C. Divide the ARB Wood Stove category into its components of pellet-fueled wood 

burning heaters, clean wood burning heaters, 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 estimated No Burn days for future years 

G. Determine the emission reductions 

H. Determine the number of average estimated increase in burn days for registered 

wood burning heaters for future years 

I. Determine the additional emissions from 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 total emission reductions for the Valley 

The following provides the methodology, assumptions, 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 inventory 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 categories: 1) Fireplaces, 2) Pellet-Fueled Wood 

Burning Heaters, and 3) Wood Burning Heaters. The ARB emission inventory for 

“Wood Stoves” includes emissions from both types of heaters (pellet-fuelled wood 

burning heaters and wood burning heaters). 

 Table B-1 ARB 2015 PM2.5 Winter Season 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 emissions from the daily winter emission 

inventory 

a. The existing emission inventory accounts for the winter season which 

includes the months of November through April (180 days). However, the 

wood-burning season consists of the months of November through 

February (120 days). 

b. Because there is little to no residential 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 multiplying the inventory by 180 days (winter season) then 

dividing it by 120 days (wood-burning season). 

i. Example: 

1. Fresno County Wood Stove emissions 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-Burning Season Emission Inventory by County 

(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, clean wood burning heaters, and dirty wood burning 

heaters 

Amendments to Rule 4901 will implement a tiered episodic curtailment program in 

which episodic curtailments will be called at different thresholds for wood burning 

heaters that are registered with the District versus wood burning heaters that are not 

registered with the District. 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 qualify to register will do so. To calculate 

the emissions reduced based on the tiered episodic curtailments the emission inventory 

must first be divided into the two categories: 1) clean wood burning heaters that qualify 

for registration and 2) dirty wood burning heaters. 

D. Distribute the ARB emission 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 from 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 data2 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 data the fireplaces are 20 times dirtier than the 

certified wood burning heaters, 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 emission 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 emission inventory x percentage 

of emissions from dirty wood burning stoves 

2. 0.812 tpd x 0.95 

3. 0.771 tpd from dirty wood burning heaters 

Table B-3 2015 PM2.5 Emission 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-Burning Stoves and Fireplaces. (2012, November 14). 

Retrieved from http://www.epa.gov/burnwise/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 categories. The new categories are: 1) Clean 

wood burning heaters and 2) Dirty wood burning heaters 

The determination of the emissions reduced 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/m3

 threshold. Wood burning heaters categorized 

as “Dirty” wood burning heaters consist 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/m3

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 wood burning heater emission inventory 

(Table B-3) and the clean wood burning heater inventory (Table B-3). 

a. Example: 

i. Fresno County pellet-fueled wood burning heater inventory + 

Fresno County clean wood burning 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 heater 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 Emissions 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 the staff report. 

Table B-5 Average Number of Days Forecast Above 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 each 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 heaters 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 increase in burn days for registered wood 

burning heaters for future years 

Wood burning heaters that register with the District will experience 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/m3 

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 2009-10, 2010-11, 2011-12, 2012-13, 2013-14 

wood-burning seasons 

I. Determine the additional emissions from 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 Burn 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 reductions from implementation of the tiered 

curtailment program 

1. Determine the total emission reductions for the Valley by subtracting the 

emissions increase from registered wood burning heaters (Table B-8) from the 

emissions reduced (Table B-6). 

a. Example: 

i. Fresno County emission reductions – Fresno County emissions 

increase 

ii. 74.61 tons per season – 1.75 tons per season 

iii. 72.86 tons of PM2.5 emissions 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
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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 season 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 reduced 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. 
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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 PROPOSED AMENDMENTS TO RESIDENTIAL 

WOOD BURNING PROGRAM 

A. Contributing factors to emission reductions from proposed amendments to 

the District’s residential 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 result of the combination of the episodic 

curtailment levels and the increased incentive amounts as discussed in detail in the 

staff report; and 

2) The implementation of the lowered curtailment threshold from 30 to 20 μg/m3. 

The following is a summary of this analysis. 

Survey Results 

The results from a third party survey of Valley residents (see Appendix E) identify the 

two main motivators for the transition to clean wood burning heaters. 24% of Valley 

residents with non-EPA certified wood burning heaters and wood burning 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 their current wood burning fireplace or wood 

burning heater with a cleaner, less-polluting wood burning heater if they could use it 

more often than currently allowed. Taking this information into account, the District is 

recommending increasing incentive amounts and increasing the number of burn days 

allowed for qualified registered wood burning heaters through a tiered curtailment 

program. 

Conservative Analysis 

To perform a conservative emission reduction analysis for the transition of non-EPA 

certified wood burning heaters and wood burning fireplaces to cleaner wood burning 

heaters the District assumes 24% of the older more polluting 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 Cleaner Program database, the majority of wood 

burning heaters and wood burning fireplaces that are replaced 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 calculation methodology 

Total emissions reduced as a result of amendments to the District’s residential wood 

burning program would be equal to the emission reductions resulting from 24% of the 

older more polluting wood burning heaters and wood burning fireplaces being replaced 

with clean wood burning heaters plus the emissions that would be reduced from the 

remaining dirty wood burning heater 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 registered wood burning heaters being 

operated on days when the pollutant levels would be forecast to be 20-65 μg/m3. 

Table B-10 below summarizes the calculations 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 DISTRICT 

Final Draft Staff Report: Residential Wood Burning Program  B-15 Final Draft Sta

Proposed Amendments to Resid

Table B-10 Emission Reductions Resulting from Conversion of Dirty Heaters to Clean 

 A B C D E F G H 

Source / 

Formula Table B-6 A / 120 Table B-8 C / 120 Table B-4 (total) - B F x 0.24 G x 20% Table B-5 

Table B-

Emissions 

reduced from 

dirty devices 

resulting from 

lowering the 

curtailment from 

30 to 20 μg/m3

(tons/season) 

Emissions 

reduced from 

dirty devices 

resulting from 

lowering the 

curtailment from 

30 to 20 μg/m3

(tpd) 

Emissions 

from registered 

wood burning 

heaters on 

additional burn 

days (when 

forecast is 

between 30 

and 65 μg/m3) 

(tons/season) 

Emissions 

from registered 

wood burning 

heaters on 

additional burn 

days (when 

forecast is 

between 30 

and 65 μg/m3) 

(tpd) 

Remaining 

emissions 

from dirty 

devices after 

lowering the 

curtailment 

threshold 

(tpd) 

Emissions 

reduced 

from 24% of 

dirty devices 

transitioning 

to clean 

devices 

(tpd) 

20% increase 

in emissions 

from newly 

registered 

devices 

(when 

forecast is 

between 20 

and 65 μg/m3) 

(tpd) 

Number 

addition

burn days 

registere

devices 

(when 

forecast 

between 

and 65 μg

(tpd) 

Fresno 74.606 0.62 1.75 0.015 1.450 0.348 0.070 79 Kern 41.860 0.35 0.68 0.006 0.847 0.203 0.041 73 Kings 6.953 0.06 0.09 0.001 0.166 0.040 0.008 64 Madera 24.518 0.20 0.47 0.004 0.441 0.106 0.021 66 Merced 36.346 0.30 0.58 0.005 0.707 0.170 0.034 55 San Joaquin 71.484 0.60 0.46 0.004 1.869 0.449 0.090 53 Stanislaus 65.797 0.55 1.27 0.011 1.280 0.307 0.061 70 Tulare 78.428 0.65 2.48 0.021 1.723 0.414 0.083 65 TOTAL 3.33 0.065 2.04 
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Appendix C: Economic Analysis September 18, 2014 

 

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APPENDIX C 

Economic Analysis 

Proposed Amendments to Residential Wood Burning Program 

September 18, 2014 
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ECONOMIC ANALYSIS 

Amendments to Rule 4901 

Pursuant to California Health and Safety Code (CH&SC) requirements, the District has 

performed a cost effectiveness analysis and socioeconomic analysis to assess the 

economic impacts of amendments to Rule 4901 in the Valley. The registration of 

residential wood burning heaters is an optional program; no Valley resident is required 

to replace an existing wood burning heater or to register their wood burning heater. 

Therefore, there are no required costs or economic impacts associated with the new 

registration program. However, potential economic impacts 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 wood burning season. In summary, Level One Episodic 

Curtailments would be declared when the PM2.5 concentrations are forecast to exceed 

20 μg/m3 but not to exceed 65 μg/m3; the use of registered clean wood burning heaters 

would be allowed. Level Two Episodic Curtailments would be declared when the PM2.5 

concentrations are forecast to exceed 65 μg/m3; the use of all residential wood burning 

heaters would be prohibited. Refer 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 Episodic Tiered Curtailment Thresholds 
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Appendix C: Economic Analysis September 18, 2014 

 

 C - 4 Final Draft Staff Report with Appendices for 

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I. Cost Effectiveness Analysis 

Per CH&SC Section (§) 40920.6(a), the District conducts absolute and incremental cost 

effectiveness analyses of available emission control options to evaluate the economic 

reasonableness of a rule or rule amendment prior to adoption. As the following write-up 

will explain, these rule amendments result in an annual emission reduction of 392.22 

tons of directly emitted PM2.5 (refer to Appendix B), with no significant additional cost to 

Valley residents. 

Absolute cost effectiveness of a control option is the additional annual compliance cost 

(in dollars per year) of the control technology or technique divided by the emission 

reduction achieved in tons of pollutant reduced per year (tons/year). 

Incremental cost effectiveness is the difference in cost between two successively more 

effective controls, divided by the additional 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 the staff report, lowering of the threshold for Episodic Wood 

Burning Curtailments from 30 μg/m3

 to 20 μg/m3 would result in an estimated Valleywide average increase of 34 No Burn days per wood burning season per county. The 

costs resulting from this analysis are not significant. 

Additionally, the registration of clean burning residential wood burning devices is an 

entirely optional program; no Valley resident is required to replace an existing device or 

register their device. As these requirements are not mandatory, there are no required 

costs associated with them. 

Table 1 Additional No Burn Days Projected 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 the cost of turning on the home’s heating 

system instead of burning an approved fuel such as seasoned wood or pellets in the 
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Appendix C: Economic Analysis September 18, 2014 

 

 C - 5 Final Draft Staff Report with Appendices for 

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home’s wood burning heater. Because 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 cost amendments. The District 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. INTRODUCTION

Pursuant to CH&SC §40728.5 as well as the District’s 2011 Economic Analysis Process 

Recommendations,

1

 the District conducted a socioeconomic analysis of the proposed 

rule amendments. This socioeconomic 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. SOCIOECONOMIC ANALYSIS 

The CH&SC consists of six specific requirements. The discussion of the necessity of 

adopting, amending, or repealing Rule 4901 to attain state and federal ambient air 

quality standards is in the body of the staff report. 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, including 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 following 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 the 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 Valley. Retailers who sell 

residential wood burning devices and associated fuels are in a position to increase 

profits due to the estimated increase in Valley residents who will upgrade their existing 

fireplaces and older more polluting devices for EPA certified devices. Retailers who sell 

the seasoned wood for fireplaces would experience some decrease in profits due to the 

additional No Burn days, however they would still be able to sell smaller amounts of 

wood to those homes with registered wood burning devices who will see an increase in 

 

1

 San Joaquin Valley Air Pollution Control District [SJVAPCD]. (2011, October 20). Enhancements to District 

Economic Analysis of Regulations. Fresno, CA. Retrieved from 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2011/October/GB_Agenda_Item_13_Oct_20_

2011.pdf 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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the use of their wood burning heaters. The combination 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 consumer 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 employment and the economy of the region 

Because this is a no cost rule and the socioeconomic impacts on Valley businesses and 

industries is not significant, no impact is anticipated on employment or the economy of 

the region. 

C. ADDITIONAL SOCIOECONOMIC ANALYSES

Per the 2011 Economic Analysis Process 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 also 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 from 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 this analysis, the District did a ten year 

historical review which included the October 2008 amendments. The analyses for the 

2008 amendments resulted in the conclusion that impacts stemming from the proposed 

amendments are less than significant across the board, particularly from the vantage 

point of the retailers that sell logs and small businesses are not disproportionately 

impacted by the rule. 

2. Impacts to Small Businesses, Municipalities, and At-Risk Communities 

As discussed in the analyses above, the impact to small businesses and at-risk 

communities is less than significant and municipalities would not be affected by rule 

amendments. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix D: Health Benefit Analysis September 18, 2014 

 

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APPENDIX D 

Health Benefit Analysis 

Proposed Amendments to Residential Wood Burning Program 

September 18, 2014 
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HEALTH BENEFIT ANALYSIS 

I. Health Benefits from Reducing Wood Smoke Exposure 

Based on a large body of interrelated scientific research conducted in the San Joaquin 

Valley (Valley) and elsewhere, episodic curtailments of residential wood combustion 

(RWC) under Rule 4901 have resulted in substantial health benefits for the Valley 

population since these controls were adopted in 2003 and strengthened in 2008. 

Furthermore, the rule is the most cost-effective rule adopted by the San Joaquin Valley 

Air Pollution Control District (District), conferring the greatest absolute 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 related to (1) the high level of cumulative 

population exposure to urban RWC emissions compared to other sources, (2) the 

relative effectiveness of burning curtailments in reducing per capita PM2.5 exposure 

levels in urban areas where the Valley population 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 penetration of ultrafine particles 

from RWC into neighboring homes. As a result of these factors, Rule 4901 is a key 

component of the District’s Health Risk Reduction 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 for individual emission sources. 

Wood smoke contains a combination of aerosols (particles) that are less than 2.5 

microns in diameter (PM2.5) with an additional large number of ultrafine particles less 

than 0.1 microns (PM0.1). It is also a rich source of gasses including carbon monoxide, 

formaldehyde, sulfur dioxide, and other irritant gases such as polycyclic aromatic 

hydrocarbons (PAH). PAH species are recognized as potential carcinogens and are 

also highly implicated in the triggering of oxidative stress that promotes the 

malfunctioning of the immune system, particularly 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 inhalation 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 Pollution 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 interstitium (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 harder 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). 
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Appendix D: Health Benefit Analysis September 18, 2014 

 

 D - 4 Final Draft Staff Report with Appendices for 

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been linked to detrimental mutagenic and systemic effects such as oxidative stress and 

blood coagulation, which can ultimately result 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 enclosed geophysical environment of the Valley acts to magnify 

the health impacts of wintertime RWC relative to other California air basins such as the 

Bay Area and South Coast that are well-exposed to fresh marine air currents and not 

surrounded by mountains that trap the pollutants. The Valley regularly experiences 

multi-day periods of atmospheric 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, sometimes well beyond the federal daily standard of 35 μg/m3

. 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 concentration of directly emitted particulates that envelop 

urban neighborhoods. Because of the concentration effect of winter nighttime 

inversions, urban RWC has a disproportionate 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 reloading wood stoves or fireplaces. Additionally, because 

windows and doors cannot prevent ultrafine particles (PM0.1) in wood smoke from 

penetrating homes, neighboring households that are downwind of wood-burning 

neighbors during inversion events 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, California and published in 2011.10 Using aethalometers 

designed to monitor carbon black found in wood smoke, the study found nighttime 

outdoor concentrations in Cambria neighborhoods 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 Pulmonale Associated with Chronic Domestic Woodsmoke 

Inhalation. (1993) Chest 103:12-20. 6

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

Oxidatively damaged DNA and its repair after experimental 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 hypopharyngeal/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 Pollution 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/research/rsc/10-28-11/item2dfr07-308.pdf
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concentrations of carbon black in neighboring 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 very high intake fraction (the portion of a 

source’s total emissions that actually 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 generate large numbers of PM0.1. Taking into consideration 

the length of PM0.1 inhalation during sleeping hours, the relatively high concentration of 

PM0.1 found in RWC plumes, and the number affected of individuals in an urban 

neighborhood, the intake fraction resulting from the source 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 concentrations of PM2.5 measured by urban 

monitors. 

Any evaluation of the relative health benefits of Rule 4901 must take in consideration a 

number of risk factors that amplify 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 that 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 elevated emergency room admissions and daily 

concentrations of ammonium nitrate, a species 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 environments. 

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 epidemiological research to be concentrated in 

winter months when RWC emissions are highest. 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 
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II. Using EPA’s BenMAP Model to Estimate Health Benefits of Rule 4901 

 

Reflecting the scientific factors described above regarding the disproportionate health 

benefits from reducing exposure to wood smoke, prior research sponsored by the 

District has shown that Rule 4901 and subsequent amendments (2003, 2008, 2014) 

confer substantial health benefits for residents of the Valley. 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 designed to quantify reductions in morbidity 

(disease) and mortality (pre-mature death) based on an estimated 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 number of reduced cases of 

disease-related events and pre-mature death for a given reduction in annual PM2.5 

exposure and (2) the economic value 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 conducted by the Central Valley Health Policy 

Institute and UCSF-Fresno, the significant 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 curtailment days resulting from the lower 24 

hour threshold adopted in the 2008 Rule 4901 amendments from 65 μg/m3

 to 30 μg/m3

has resulted in a proportional increase in the health benefits of the rule above and 

beyond that of the 2003 Amendments. Further significant health benefits can be 

expected from the proposed reduction in the 24 hour curtailment threshold for Rule 

4901 to 20 μg/m3

. 

Our point of emphasis here is that the health benefits resulting from each Rule 4901 

amendment are cumulative, with each revision resulting 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 directly 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 program, 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 emissions of PM2.5 from 

all sources have only declined by 30% in the same time period. 

Further insights can be gained from 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 direct PM2.5 discussed above, Table D-1 

summarizes the substantial health benefits 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 amendments. And while it is difficult to quantify 

the health benefits of an individual rule due to the statistical limitations of the BenMAP 

model, a review of all control 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 substantial benefits that have 

already resulted from the 2003 and 2008 amendments. 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix D: Health Benefit Analysis S

 D - 8 Final Draft Staff Repo

Proposed Amendments to Residential W

Table D-1: BenMAP Estimates of 2019 Average Annual Reduction in Morbidity and Mortality un

PM2.5 Plan 

Health Endpoint Totals Fresno Kern San Joaquin Stanislaus Tulare Merced 

Acute Myocardial 

Infarction 93 29 25 9 7 11 3 

HA, Asthma 0-19 131 56 28 9 11 13 4 

HA, Cardiovascular 175 47 51 16 14 26 6 

HA, Asthma 20-99 246 64 77 30 16 35 11 

ER Visits, Asthma 20-99 407 123 94 48 28 53 22 

Chronic Bronchitis 595 168 164 57 49 80 25 

ER Visits, Asthma 0-19 699 252 160 47 44 90 36 

Acute Bronchitis 1,498 404 406 149 127 222 72 

Upper Respiratory 

Symptoms 15,523 4,206 4,294 1,482 1,260 2,334 728 

Lower Respiratory 

Symptoms 19,011 5,093 5,207 1,887 1,595 2,829 912 

Asthma Exacerbation 114,376 31,144 31,124 11,269 9,469 17,037 5,445 

Work Loss Days 125,138 34,816 35,300 11,752 10,077 16,882 5,367 

Pre-Mature Mortality 671 172 207 72 61 86 26 

Note: Shaded health endpoints are based on concentration response functions (CRF) derived from the 2010 VaStudy conducted by CSU Fresno and UCSF-Fresno. 
APPENDIX E

Public Survey Reports

Proposed Amendments To Residential Wood Burning Program

September 18, 2014
This page intentionally blank.
Residential Wood Burning, Lawn 

Care, and Commuting Survey 

Final Report 

February 2014

Submitted to:

San Joaquin Valley Air 

Pollution Control District

Submitted by:

Gomez Research 

Pasadena, California
Public Opinion Survey 2014 

Gomez Research i

TABLE OF CONTENTS 

EXECUTIVE SUMMARY..................................................................................... iv 

I. INTRODUCTION ....................................................................................... 1 

II. METHODOLOGY ....................................................................................... 1

III. FINDINGS .................................................................................................. 3

Residential Wood Burning .......................................................................... 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 

IV. CONCLUSIONS ...........................................................................................19

APPENDICES: 

Appendix A: Survey Instrument with Weighted Frequencies 

Appendix B: Demographic Profile of Residents Surveyed 
Public Opinion Survey 2014 

Gomez Research ii

List of Tables 

Table 1: Demographic Profile of Residents Surveyed Compared to Population Estimates ....... 30
Public Opinion Survey 2014 

Gomez Research iii

List of Figures

Figure 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 Idling 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 ................... 18
Public Opinion Survey 2014 

Gomez Research iv

EXECUTIVE SUMMARY 

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 total of 1,000 telephone surveys were conducted with owners and renters of single-family homes1

in 

San Joaquin, 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. 

Key Findings

Residential Wood Burning 

a. Nearly one-third (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. Nearly one-quarter 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. Respondents 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 The sample 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. 
Public Opinion Survey 2014 

Gomez Research v

d. Just under 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. The 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. English-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.

g. 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). In addition, homeowners were more likely to report having a wood-burning

device compared to renters.

h. 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).

i. The Check 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. In addition, 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 under one-third (29 percent) of residents surveyed reported that they would be willing to

replace their traditional wood-burning fireplace or stove if they could use it on some No-Burn

days.

m. 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.
Public Opinion Survey 2014 

Gomez Research vi

n. 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.) 

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). 

Residential Lawn Care 

a. 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 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 than 

English-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.

Commuting Patterns

a. 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 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. 
Public Opinion Survey 2014 

Gomez Research vii

c. Among residents 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 their children take public transportation or carpool with

other students.

d. The most frequently cited reasons for not allowing children to walk or bike to school were

distance and concerns about safety.

e. More than two-thirds (69 percent) of residents with school-age children agreed that idling cars

are a significant source of air pollution.

General Beliefs and Awareness 

a. Findings indicate 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. Awareness 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. More than 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 

programs and outreach to increase awareness of the District’s rebate programs may be helpful in 

promoting changes in personal behavior and improving air quality. 
Page 1 

INTRODUCTION 

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 outreach 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: 

 The Methodology 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.

METHODOLOGY

Overview

A total of 1,000 telephone surveys were conducted with owners and renters of single-family homes2

in

San Joaquin, 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.) 

The surveys 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 sample 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. 
Page 2 

Caveats 

It should 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. 

Weighting

The 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. 

Statistical Comparisons 

Statistical tests were conducted for all comparative analyses to identify whether observed differences 

among demographic groups or categories were statistically significant.3 All reported differences were 

statistically significant at the 95 percent confidence level unless otherwise noted. 

Report Organization 

This report has been organized around the following topical areas: 

 Residential Wood Burning;

 Residential Lawn Care;

 Commuting Patterns; and,

 General Beliefs and Awareness.

The next section of this report presents study findings. 

3 A statistically significant difference means that the difference between years or among groups is not by 

chance, and that a real difference exists. 
Page 3 

FINDINGS 

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. 

Presence of Wood Burning Devices 

Respondents were first asked if they had a wood-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 

having 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

*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? 

Use of Wood-Burning Devices 

Respondents who 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 Exempt 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 Wood-Burning

Device, 68%

Pellet Stove, 3%

Wood Stove, 4%

Wood-Burning

Fireplace, 25%

Figure 1: Proportion of Residents with a Wood-Burning Fireplace, Wood Stove or 

Pellet Stove

Respondents Overall (n=1,000)

No Wood-Burning Device Pellet Stove Wood Stove Wood-Burning Fireplace
Page 4 

devices (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, less 

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). 

Respondents 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% 10% 20% 30% 40% 50% 60%

Not at all

Less than once a week

Once a week

Several days a week

Nearly everyday

59%

17%

8%

7%

8%

Figure 2: How Often Residents use their Fireplace/Stove in the Winter Months, Among 

Respondents Who Use Their Wood-Burning Device (n=330) 

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

24 hours a day

7-13 hours

5-6 hours

3-4 hours

1-2 hours

10%

7%

15%

42%

24%

Figure 3: Number of Hours Residents Reported Burning a Fire, Once Started

Among Respondents Who Use Wood-Burning Devices (n=133)
Page 5 

Next, 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 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. 

*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?”

Regional/Demographic Difference in Use of Wood Burning Devices 

The study 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 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. 

*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% 10% 15% 20% 25% 30% 35% 40%

South (n=325)

Central (n=305)

North (n=368)

28%

28%

37%

Figure 5: Proportion of Residents with Wood-Burning Devices

Respondents Overall, by Region

0% 10% 20% 30% 40% 50% 60% 70% 80%

Other (specify)

Trash, magazines, newspapers, other household...

Pellets

Partially dried wood that has some moisture

Manufactured logs, such as Duraflame

Seasoned firewood, split and dried

1%

11%

13%

22%

32%

71%

Figure 4: Type of Fuel Burned

Among Respondents Who Use Wood-Burning Devices (n=133)
Page 6 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

Not Sure/Refused

No

Yes

4%

12%

83%

2%

18%

80%

Figure 6: Awareness of the Check Before You Burn Program

Respondents Overall, 2010 and 2014

2014 (n=133)

2010 (n=640)

Additional 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). 

Awareness and Impact of the Check Before you Burn Program

This year, 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 air 

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. 
Page 7 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

Not Sure/Refused

No

Yes

1%

82%

17%

Figure 8 Residents Aware of the Burn Cleaner Program

Respondents Overall (n=1,000)

Next, respondents 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? Base 

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. 

Awareness and Interest of the Burn Cleaner Rebate Program 

In addition 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% 10% 20% 30% 40% 50% 60% 70% 80%

Don’t Know

Maybe

No

Yes

1%

5%

16%

78%

Figure 7: Residents Who Reported Reducing Wood-Burning 

In Response to the Check-Before You Burn Program

Respondents Aware of the Program (n=110)
Page 8 

0% 10% 20% 30% 40% 50% 60%

Don’t Know/Refused 

I already have a clean-burning device

No

Yes

8%

5%

58%

29%

Figure 9: Residents Willing to Replace Their Traditional Fireplace/Stove

Respondents with Wood-Burning Devices (n=330)

Respondents who 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 total 

estimated 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.) 
Page 9 

Beliefs about Wood Smoke

The last question 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). 

*Figure based on Q13: “Do you believe wood smoke is a significant source of air pollution in your neighborhood?”

Residential Lawn Care 

Another 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. 

Use of Gas-Powered Lawn and Garden Equipment by Residents 

Respondents were 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. 

*Figure based on Q20: “Who usually maintains your lawn, shrubs, trees or garden areas?”

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

Don’t Know/Refused 

No

Yes, probably

Yes, definitely

5%

41%

20%

35%

Figure 10: Residents Who Believe Wood Smoke is a Significant Source of Air Pollution 

Respondents Overall (n=1,000)

0% 10% 20% 30% 40% 50% 60% 70%

Don’t know/Refused 

Don’t have a lawn/Don’t care for it

A lawn serivice does all the yard work

I or others in the household do some of the yard...

I or others living in the household do all the yard work

2%

8%

25%

3%

61%

Figure 11: Proportion of Residents Who Use a Lawn Care Service

Respondents Overall (n=1.000) 
Page 10

Residents 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% 10% 20% 30% 40% 50% 60% 70% 80%

Don’t know/Refused 

No

Yes

2%

25%

73%

Figure 12: Proportion of Residents Using Gas-Powered Lawn or Garden Equipment

Respondents Who Care for their Own Lawns (n=639)

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

Stump Grinders/Chippers

Snow Blowers

Shredders

Wood Splitters

Lawn & Garden Tractors

Tillers

Riding Lawn Mowers

Brushcutters/Hedgeutters

Chain Saws

Leaf Blowers

String Trimmers

Lawn Edgers

Walk-behind Lawn Mowers

2%

2%

3%

4%

4%

8%

10%

18%

25%

35%

38%

39%

84%

Figure 13: Types of Gas-Powered Lawn and Garden Equipment Residents Used

Respondents Who Use Gas-Powered Equipment (n=459)
Page 11

Use and Frequency of Professional Lawn Service 

Residents who 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%

10%

20%

30%

40%

50%

60%

Four times a month Three times a month Twice a month Once a month

54%

4%

22%

6%

Figure 14: Number of Times a Month Residents Use Lawn Service During the Summer

Among Respondents Who Use a Lawn Care Service (n=291)

0%

10%

20%

30%

40%

50%

60% Yes, 46%

No, 51%

Don’t know, 3%

Figure 15: "Does the Lawn Service Come as Often During Winter?"

Among Respondents Who Use a Lawn Service (n=291) 
Page 12

Residents 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?”

Awareness and Interest in the Clean Green Yard Machines Rebate Program 

As 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 program is 

called the Clean Green Yard Machines Rebate Program?”

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

Don’t know/Refused 

Would not consider

Costs more than current service

Costs same as current service

Costs less than current service

15%

41%

2%

16%

25%

Figure 16: Would Consider Switching to Lawn Service with Cleaner Equipment

Respondents Who Use a Lawn Care Service (n=291)

Don’t know, 1% Yes, 15%

No, 84%

Figure 17: Residents Aware of the Clean Green Yard Machines Rebate Program 

Respondents Overall (n=1,000)
Page 13

0% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50%

Don’t Know/Refused 

Work at home one or more days a week

Use public transportation

Walk or bike

Drive in carpool or vanpool

Don’t work outside the home

Drive alone

1%

2%

2%

3%

12%

30%

50%

Figure 18: How Residents Travel to Work

Respondents Overall (n=1,000) 

Commuting Patterns

In 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 school-age children 

travel to and from school. Results are presented below. 

Current Commuting Patterns 

Respondents were 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?” 
Page 14

Future Behavior 

To help identify 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%

10%

20%

30%

40%

50%

60%

My employer

provided a more

flexible work

schedule

My employer

provided a

financial incentive

I could get

assistance with

finding a carpool

partner in my

neighborhood

My employer

provided free

designated

carpool parking

My employer

provided onsite

food service

and/or lunch

51% 49%

45%

43% 40%

Figure 19: Conditions Under Which Residents Would Consider Carpooling

Among Respondents Who Drive Alone (n=452)
Page 15

Student Pick Up and /Drop Off 

In addition 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. One-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% 10% 15% 20% 25% 30% 35% 40% 45% 50%

Don’t Know/Refused 

My children are home schooled

Carpool with other students

Take public transportation

Drive themselves

Take the school bus

Walk or bike

Someone in household drives them

0%

1%

1%

2%

4%

21%

24%

46%

Figure 20: How Children are Transported to School

Among Respondents with School-Age Children (n=381)

0% 5% 10% 15% 20% 25% 30% 35% 40% 45%

Refused to answer

Not enough time in the schedule

No sidewalk in my neighborhood

Concerned about safety

Too far

3%

7%

2%

43%

44%

Figure 21: Reasons Residents Do not Allow Their Children to Walk to School

Among Respondents Whose Children Do Not Walk or Bike (n=281)
Page 16

Beliefs about Car Idling at Schools as a Source of Air Pollution 

Finally, 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-age 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% 10% 20% 30% 40% 50% 60% 70%

Don’t know/Refused 

No

Yes

7%

25%

69%

Figure 22: Awareness of Idling as a Source of Air Pollution Effecting Children's 

Among Respondents with School-Age Children (n=381)
Page 17

General 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. 

Perceptions of Local Air Quality 

In 2010 and 2014, residents were asked if they thought the air quality in their areas had gotten better, 

worse, or stayed 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.

*Figure based on Q27: “Compared to three years ago, 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?)” 

*Figure based on Q27: “Compared to three years ago, would you say the air quality 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 

level are circled. 

0% 10% 20% 30% 40% 50% 60%

Much Worse

Somewhat Worse

About the Same

Somewhat Better

Much Better

13%

20%

51%

11%

4%

14%

15%

50%

9%

4%

Figure 23: Public Perception of Local Air Qualtiy

Respondents Overall, 2010 and 2014 (n=1,000)

2014

2010
Page 18

Awareness and Perceptions of the Air Pollution Control District 

In 2010 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 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?” 

0% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50%

Don’t know/Refused 

Very unfavorable

Somewhat unfavorable

Somewhat favorable

Very favorable

18%

7%

8%

46%

22%

Figure 24: Perforamance Ratings, San Joaquin Valley Air Pollution Control District

Among Respondents Familar with the Agency (n=592)
Page 19

Conclusions 

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 

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 programs and outreach to 

increase awareness of the District’s rebate programs may be helpful in promoting changes in personal 

behavior and improving air quality. 
Page 20

APPENDIX A: 

SURVEY INSTRUMENT WITH WEIGHTED OVERALL FREQUENCIES 
Page 21

Valley Air District Residential Wood Burning, Lawn Care, and Commuting Survey 2014 

Overall Frequencies (n=1,000) 

INTRODUCTION

My name is __________. 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

Landline

1. May I speak 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) 

Cell Phone 

1a. Since 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) 

All Respondents

1c. What county 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] 
Page 22

1e. Which 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%

WOOD COMBUSTION: BEHAVIOR AND AWARENESS 

2. 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? 5

(check all that apply) (n=1,000)

1 Yes, wood-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. How 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=330)

1 Nearly everyday 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

Identical to QH on 2010 survey. 

6 Similar to QI on 2010 survey. 
Page 23

7. Which 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%
Page 24

12a. How 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%

COMMUTING BEHAVIOR AND AWARENESS 

14. How do you 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%
Page 25

17. (Ask 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. (Ask only if Q16a = 6. Others skip to Q19) Which of the following best describes the main reason you 

decided to use a carpool to get your children to school? (Check one. Rotate first three stems.) (n=6) Due 

to the extremely small sample of respondents who responded to this question, results could not be 

analyzed statistically.

1 It is convenient 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%

 LAWN CARE: BEHAVIOR AND AWARENESS 

20. Who usually maintains your lawn, shrubs, trees or garden areas?7

(Do not read) (n=1,000)

1 I or others 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 you use any gas-powered lawn or garden equipment at your residence?8(n=639)

1 Yes 73% 

2 No (skip to prompt above Q26) 25%

9 Don’t Know/Refused (skip to prompt above Q26) 2%

22. Considering only gas-powered lawn and garden equipment, which of the following do you use?9

(yes/no

punch. 99 = don’t know) (n=459)

01 Walk-behind 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

Identical wording to Q70 from the ARB survey. 

8 Similar wording to Q80 from the ARB survey. 

9

Identical list to Q89 from the ARB survey. 
Page 26

12 Snow Blowers 2%

13 Stump Grinders/Chippers 2%

(Only ask Q23 through Q26 if Q20 = 2 or 3. Otherwise skip to Q26) 

23. During the 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%

GENERAL BELIEFS AND AWARENESS 

27. Compared to three years ago, would you say the air quality in your area has gotten better, gotten worse, 

or stayed the same? 10 (If better/worse: Is that much better/worse or somewhat better/worse?) (n=1,000)

1 Much Better 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 you heard of the San Joaquin Valley Air Pollution Control District? 11 (n=1,000)

1 Yes 57%

2 No (skip to Q30) 40%

9 Not sure/Refused (skip to Q30) 2%

 

10 Similar wording to Q5 from 2010 survey. The time interval has been changed from 5 to 3 years. 

11 Similar wording to Q11 from 2010 survey. “Maybe” has been excluded from the options. 
Page 27

29. The San 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%

DEMOGRAPHICS 

Finally, 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%
Page 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 12%

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. 
Page 29

APPENDIX B: 

DEMOGRAPHIC PROFILE OF RESIDENTS SURVEYED COMPARED TO 

POPULATION ESTIMATES 
Page 30

Table 1: Demographic Profile of Residents Surveyed 

Compared to Population Estimates 

Population

Characteristic

U.S. Census Population

(Across 8 CountyRegion)Unweighted 

Sample Weighted Sample

Fresno 23.4% 23.8% 23.1%

Kern 21.2% 18.7% 21.2%

Kings 3.7% 3.7% 3.8%

Madera 3.8% 4.2% 3.7%

Merced 6.5% 7.9% 6.5%

San Joaquin 17.4% 17.7% 17.8%

Stanislaus 12.9% 9.6% 12.6%

Tulare 11.2% 14.4% 11.5%

Cell only 32.6% 37.0% 31.6%

Male 50.4% 44.8% 50.0%

Female 49.6% 55.2% 50.0%

White 35.6% 40.4% 34.6%

Black 5.5% 3.4% 5.3%

Hispanic 49.6% 42.7% 49.2%

Asian 8.1% 4.7% 7.8%

Age <65 85.3% 78.1% 85.3%

Age 65+ 14.7% 21.9% 14.7%
Community Stakeholder

Interviews 

Final Report 

February 2014 

Submitted to: 

San Joaquin Valley Air 

 Pollution Control District 

insert logo

Submitted by: 

Gomez Research 

Pasadena, California
TABLE OF CONTENTS 

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 

Perceptions 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 

 
EXECUTIVE SUMMARY 

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. 

Key findings 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 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, 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. 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 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 is 

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 majority 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. 
INTRODUCTION

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 representatives

 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 

Rating of Current Air Quality 

One objective 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. 
Impact of Air Quality and Air Quality Regulations 

Respondents were 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 pollution. 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: 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?

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 have 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 gotten 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 correlation 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 issues. It’s really a 

drain on our society and economy. 

 I think the biggest problem is allergies. I have it myself.
Comments Regarding Business Impacts: 

 The air quality doesn’t seem to be a big issue, but the regulations have been detrimental 

to employees... 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 regulations] 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 businesses 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 businesses 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. 
 There have been 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 negative 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. 

Strategies for Improving Air Quality/Reducing Emissions 

Respondents were 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: Looking 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’t 
necessarily 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 not 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 

have 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 and use it to replace the semi-trucks on the road with 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 cannot continue 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 Madera 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 

cars off the road. 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 has 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 creating 

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 harvesting 

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 them 

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. 
 Fix the Bay Area. They are not held to the same standards. They are lax in their required 

emissions. It’s all directed at the Valley 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 

Healthy Air Living Program 

In addition 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 (35 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. 

Scale Score 

Very Favorable 23 respondents

Somewhat Favorable 12 respondents

Somewhat Unfavorable No respondents

Very Unfavorable 2 respondents

Not Sure/Refused 3 respondents

Respondents were 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. 
 Well I think 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 one 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, a 
packing 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—boycott is infective and requires 

incentives. 

 I think that it’s politically motivated. I think its fluff and not addressing the real issues. 

Check Before You Burn/Burn Cleaner Program

In addition to gauging awareness and perceptions of the Healthy Air Living Program, 

respondents 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: 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)?

 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. 
 They need to 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. Ordinary 

people who have fireplaces in their homes need to see those opportunities. So they need 

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 radio 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 open 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 difficult 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 

can do more. 

 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 fireplaces 
or wood burning 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. 

 Get the message 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 don’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. 
Perceptions of the District and Air Quality Policies 

Balance Between Public Health and Economic Prosperity 

Respondents were 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 

District 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: How well do you think the District balances protecting public health through regulation and 

helping to 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 sure 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 District 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 think 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 balance. 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 well. 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 climate 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 lot 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. 

Regulatory, Voluntary, and Incentive-Based Policies 

Finally, 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 for 

additional 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 recommended incentive programs. Stakeholders were evenly split 
in their 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) 

Regulatory (13 Respondents) Leaf blowers should be regulated, you can’t 

depend on volunteer measures. 

You have to make some things mandatory to 

get people’s attention. When we hold townhall meetings, if it’s about regulations we 

have 200 people, if it’s about education we 

get 60 people. Those regulations are 

controversial but you have to make it matter 

to people.

Voluntary (13 Respondents) We should start with voluntary measures 

and see how that works.

You can get a lot done with volunteer efforts. 

School idling must be voluntary, but

regulator or incentive programs are 

important to address other questions.

Incentives (18 Respondents) I think incentives and education are more 

effective. I really hate to see rules and 

regulations come down to the kind of detail 

there is now... There is a point where you 

are not going to get the bang for the buck for 

the kind of disturbance you are causing in 

people’s lives.

Incentives work best for lawn equipment and 

carpooling.

I think [incentives] work. There are a lot of 

options, including financial incentives.

They should be incentive based. 

Regulations are hard to enforce and would 

place a burden on one class of people, but if 

you can incentivize that would be better than

a mandate.
Q: Are there any unregulated consumer activities (e.g. lawn care, drive-through services, or 

school-site idling) that are appropriate for additional District action? Please explain.

 

 Leaf blowers, 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 federal-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. 

People don’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 

waiting...in hot weather 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 focus, 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. 
 Well nobody 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 

community 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. 

Suggestions for Additional District Action 

Lastly, 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. 

If you could 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 needs to be out there more than it is. It’s a function of cost, 

they only 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 Air Pollution 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 and 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 and 

transit 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. 
 Continue to take 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 count 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. 

 

 

 
APPENDIX A: 

INTERVIEW GUIDE 
Valley Air District Residential Wood Burning, Lawn Care, and Commuting Study 2014 

Community Stakeholder Interview Guide 

INTRODUCTION

Hello, 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 scheduled 

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. Using 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. Now that you 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 Program 

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 registered with the District to be used during Level 1 Episodic 

Curtailments must be EPA Phase II certified or exempt pursuant to requirements in the 

Code of Federal Regulations, Part 60, Title 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/publications/monitoring/caa/woodstoves/certi

fiedwood.pdf and at 

http://www.epa.gov/compliance/resources/publications/monitoring/caa/woodstoves/exe

mptwood.pdf. 

The list of exempt devices is not an all-inclusive list. Many pellet stoves were exempt 

pursuant to subpart AAA language and are not included 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 installed/purchased on or before March 31, 

2015 may be exempt. 

Additionally, rule language requires that wood burning heaters purchased and/or 

installed on or before March 31, 2015 be Phase II Certified; therefore, 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 EPA Certified Wood Stoves 

December 2013

EPA Wood 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 

manufacturer name, model name, emission rate (g/hr), heat output (btu/hr), efficiency (actual measured and estimated), and type of 

appliance. It also indicates whether the appliance is still being manufactured. An EPA certified wood stove or wood heating 

appliance has been independently tested by an accredited laboratory to determine whether it meets the particulate emissions limit of 

7.5* grams 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 (NSPS) for New Residential 

Wood Heaters under the Clean Air Act and are required to meet these emission limits. 

An EPA certified 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 Sanchez.rafael@epa.gov. 
* 

Temporary 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 1
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

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 2
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

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 3
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

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 4
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

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, Inc33 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 5
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

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 6
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

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 7
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

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 8
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

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 9
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

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 10
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

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 11
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

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 12
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

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 13
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

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, IncorporatedOpel 2000C, OPEL AP 3.7 10600-49700 72 Catalytic

RSF / Industrial Chimney Company, IncorporatedTOPAZ/CHAMELEON (Without Fan), TOPAZ, Chameleon 4 11100-25700 63 Non Catalytic

RSF / Industrial Chimney Company, IncorporatedHT (Onyx), ONYX AP 4.5 11800-35600 63 Non Catalytic

RSF / Industrial Chimney Company, IncorporatedTOPAZ/CHAEMELON (With Fan) 5.5 9500-25800 63 Non Catalytic

RSF / Industrial Chimney Company, IncorporatedArdent 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 14
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

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 15
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

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 16
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

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 17
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

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 18
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

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 19
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

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 20
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

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 21
List of EPA Exempt Wood Heating Appliances

EPA Wood Heater Pro

The United States Environmental Protection Agency (EPA) regulates particulate emissions from wood heating appliances as part of the ClAct’s New Source Performance Standard for Residential Wood Heating Appliances at 40 CFR Part 60, Subpart AAA. Wood heating appl

subject to this regulation must have a firebox volume less 20 cubic feet, weigh less 800 kilograms, possess a burn rate less than 5 grams peand have an air to fuel ratio less than 35 to 1. The wood stove regulations apply to wood heating appliances intended for residential heatin

Appliances such as cookstoves, wood burning furnaces, outdoor wood boilers, coal stoves and fireplaces are not subject to these regulation

The following is a list of wood heating appliances dated that have been formally exempted from the EPA wood stove program. The manufthese appliances demonstrated that they do not meet the criteria necessary for EPA wood stove certification by submitting test reports and engineering drawings to the EPA. Please note, the appliances on this list are not EPA certified wood stoves and therefore may not be legal or installation in some jurisdictions in the United States. Please contact John DuPree at 202-564-5950 should you have questions regarding the EPA Wood Heater Program or EPA certified wood 
EXEMPT APPLIANCES 3/16/10

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 Furnace 
Manufacturer 

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. 

2 
Manufacturer 

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 

3 
Manufacturer 

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 

4 
Manufacturer 

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. 

5 
Manufacturer 

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 

6 
Manufacturer 

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 

7 
Manufacturer 

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 

8 
Manufacturer 

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 Furnace/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 

9 
Manufacturer 

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 

10 
Manufacturer 

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 

11 
Manufacturer 

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)
SAMPLE

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*

Primary Phone #* Email Address 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. 
SAMPLE

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