San Joaquln Valley 17

AIR PÍIILUTIflil CflilTRflt DISTRICT HEALTHY AIR LIVINGJuly 20, 2015

Andrew Steckel

Rules Office Chief (Air-a)

U.S. Environmental Protection Agency

75 Hawthorne Street

San Francisco, CA 94105

Dear Mr. Steckel,

The purpose of this letter is to provide you with additional information regarding District

Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters). ln evaluating District

Rule 4901's stringency in comparison with similar SIP approved rules, EPA must

evaluate the rules in their entirety. ln doing so, we believe EPA will find that Rule 4901

is the most stringent rule in the nation. Furthermore, the September 18,2014

amendments make this rule more stringent than the current version previously approved

by EPA. Please refer to the District's staff report for a detailed demonstration.

ln relation to visible emissions, District Rule 4901 imposes additional restrictions beyond

what is already required under the District's SIP approved Rule 4101 (Visible

Emissions). While Rule 4101 allows visible emissions up to Ringelmann 1 (or 20%

opacity), Rule 4901 prohibits visible emissions, Rule 4901 creates no exemptions from

the Rule 4101 visible emissions limitations during any mode of source operation

(including stadup, shutdown or malfunction/upset conditions). Rule 410'1 visible

emissions limitations will continue to apply in addition to the more stringent

requirements under Rule 4901.

With respect to unseasoned wood, even if one erroneously assumes that the use of

such wood is permissible under Rule 4901, when the rule stringency as a whole is

considered, District Rule 4901 will still be more stringent than other rules that explicitly

prohibit the use of such wood. That said, the strict visible emission restrictions in the

rule and the following provisions serve to prevent the use of unseasoned wood:

o Paragraphs 5.1 and 5.2, which restrict sale and transfer of non-certified wood

burning heaters.

o Paragraph 5.3, which limits the amount of wood burning fireplaces and heaters in

new residential developments.

o Paragraph 5.4, which describes requirements regarding advertising for sale of

seasoned wood.

. Paragraph 5.5, which prohibits burning in a wood burning fireplace or heater

garbage, treated wood, and various other listed material.

Seyed Sadredin

Erecutive DirectorlAir Pollution Control 0fficer

florthern Begion

4800 Enterprise Way

Modesto, CA 95356-87 1 8

Tel:12091 557.6400 FAX: (2091 557.6475

Central Region (Main 0llico)

1990 E. Gettysburg Avenue

Fresno, CA 93728-0244

Tel: {559) 230-6000 FAX: (559) 230.6061

Southern Region

34946 Flyover Court

Bakerslield, CA 93308.9725

Tel: 661-392-5500 FAX: 66'l-392-5585

www.valleyair.org www.healthyairliving.com Prht.d m mycbd p.p¿r €¡
July 20,2015

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Furthermore, paragraph 5.4 includes a seasoned wood labeling restriction, paragraph

5.1.3 requires retailers to provide information on properfuel selection and use, and the

District encourages the use of seasoned wood through our extensive check before you

burn program outreach materials and website

(http ://unruw. va I leya i r. o rg/aq i nfo/cbvb, htm ).

I hope this information is helpful

Si

Sheraz Gill

Director of Strategies and lncentives