SACRAMENTO METROPOLITAN 

AIR QUALITY MANAGEMENT DISTRICT

STAFF REPORT 

Rule 421, Mandatory Episodic Curtailment of Wood and Other Solid Fuel Burning

September 7, 2007 

Prepared by: Donny Homer 

Associate Air Quality Engineer 

Jeffrey Yang 

Assistant Air Quality Engineer

Reviewed by: Kevin J. Williams, Ph.D. 

 Program Coordinator 

 Aleta Kennard 

Program Supervisor

Approved by: Brigette Tollstrup 

Division Manager
Staff Report 

Rule 421 

September 7, 2007, Page 2 

BACKGROUND

Particulate matter (PM) is a mixture of very small liquid droplets and solid particles that are 

suspended in the air. Adverse health effects are linked to particles that are less than 10 microns in 

diameter (PM10), and the subset of fine particles that are less than 2.5 microns in diameter 

(PM2.5). Consequently, the California Air Resources Board (CARB) and the U.S. Environmental 

Protection Agency (EPA) established ambient air quality standards for PM10 and PM2.5. 

Sacramento County does not meet the state ambient air quality standards for PM10 and PM2.5. 

Sacramento County does not meet the federal 24-hour ambient air quality standards for PM2.5 

established in 2006 and is expected to be designated nonattainment. State and federal laws 

require actions to reduce emissions to meet the standards. 

HEALTH IMPACTS 

According to the EPA, health studies have linked exposure to PM, especially fine particles, to 

several significant health problems, including: 

• increased respiratory symptoms, such as irritation of the airways, coughing, or difficulty 

breathing; 

• decreased lung function; 

• aggravated asthma; 

• development of chronic bronchitis; 

• irregular heartbeat; 

• nonfatal heart attacks; and 

• premature death in people with heart or lung disease. 

Exposure to PM pollution can cause coughing, wheezing, and decreased lung function even in 

otherwise healthy children and adults. EPA estimates that thousands of elderly people die 

prematurely each year from exposure to fine particles. In addition, a recent study (Dominici et al., 

2006) of the correlation between PM2.5 concentrations and hospital admission rates concluded that 

short-term exposure to PM2.5 increases the risk of hospitalization for cardiovascular and respiratory 

diseases. 

CARB has estimated both the public health and economic impacts caused by exposure to PM2.5. 

For the Sacramento Metropolitan Area, CARB estimates that each year: 

• 90 people die prematurely; 

• 20 people are admitted to hospitals; 

• there are 1,200 asthma and lower respiratory symptom cases; 

• there are 110 acute bronchitis cases; 

• there are 7,900 lost work days; 

• there are 42,000 minor restricted activity days; and 

• the total economic impact of PM2.5 exposure is over $700,000,000 per year. 
Staff Report 

Rule 421 

September 7, 2007, Page 3 

LEGAL MANDATES 

Federal Mandate: Sacramento County meets the federal PM10 and 1997 federal PM2.5 standards. 

EPA issued new federal PM2.5 standards, which reduced the allowed 24-hour PM2.5 concentration 

by almost half, effective December 2006. Staff expects Sacramento to be designated nonattainment 

for the new federal 24-hour PM2.5 standards. Federal nonattainment designations are expected to 

be made by EPA in December 2008. 

Attainment status is determined by calculating the annual 98th percentile PM2.5 concentration, 

averaged over a three-year period. States must submit designation recommendations to EPA by 

December 18, 2007, based on 2004-2006 data. The table below shows that the PM2.5 

concentrations measured at Sacramento County monitoring stations from 2004-2006 exceeded the 

federal standard. 

98th Percentile 24-hour PM2.5 Concentration1

 

2004-2006 

Monitoring Station μg/m3

13th and T Street 41.3 

UCD Med. Center - Stockton Blvd. 38.7 

Del Paso Manor 48.7 

2006 Federal Standard 35 

1997 Federal Standard 65 

If designated nonattainment, an attainment plan must be submitted not later than 3 years after the 

effective date of the designation (EPA estimates this to be April 20122

). The plan must include 

transportation conformity budgets and control measures. Transportation conformity budgets will 

require that future transportation projects stay within specified emission levels that meet attainment 

and progress goals. Failure to do so can result in withholding federal transportation project 

approvals and funding. 

Because of the potentially significant benefits from this rule, staff evaluated whether this rule might 

provide additional options to minimize or avoid impacts from federal nonattainment, through; 1) an 

Early Action Compact or 2) reduced requirements due to early attainment. 

Early Action Compacts

EPA approved Early Action Compacts for 33 new federal ozone nonattainment areas in 2002. 

Those early action compacts required a signed agreement with EPA to 1) approve and submit local 

strategies designed to attain the federal standards before deadlines in the Clean Air Act and 2) to 

attain federal standards by prescribed dates. In exchange for these local commitments, EPA agreed 

to defer for a few years the formal nonattainment designation. The advantage to locals was early 

health benefits from local strategies and potentially avoiding the following nonattainment 

 

1

 This data was acquired at the three stations located in Sacramento County that have federal reference 

method monitors. The data is from 2004, 2005, and 2006. The average value is calculated according to 

procedures specified in Appendix N of Title 40, Code of Federal Regulations Part 50. The procedures 

require selection of the 98th percentile monitored concentration. For example, in 2006 the top seven 

readings were excluded from the calculation. 

2

 EPA Workshop, PM2.5 Implementation Rule, Chicago, Illinois, June 20, 2007 
Staff Report 

Rule 421 

September 7, 2007, Page 4 

consequences: 1) the requirement to meet a minimum level of emission reduction to demonstrate 

Reasonable Further Progress, 2) imposition of RACM - Reasonably Available Control Measures 

(local controls would still be required but additional flexibility in selection is provided), 3) additional 

requirements for locating new and modifying existing industrial and commercial sources, and 4) the 

need for PM2.5 motor vehicle emission budgets and associated Transportation Conformity 

demonstrations. 

EPA rules for the 1997 PM2.5 standards do not allow Early Action Compacts. Staff initiated 

discussions to request EPA staff establish this opportunity for the 2006 PM2.5 standards. Those 

2006 standards affected 38 new nonattainment areas throughout the United States including 

smaller cities and a few non-urban areas. After consulting with EPA headquarters staff, EPA 

Region 9 staff recently indicated that they would not consider this option. 

Early Attainment

EPA’s PM2.5 implementation rule incentivizes early attainment by suspending certain planning 

requirements (referred to as a "clean data policy") for areas that attain before their plans are due. 

The suspended requirements include some control measures and an attainment demonstration 

plan. The Clean Data Policy has been challenged3

 in court and there is no guarantee that we can 

rely on this provision when the time comes. 

Even if the "clean data policy" is overturned, early attainment will provide health benefits and could 

give the regional additional flexibility in determining which additional measures, if any, must be 

included in the PM2.5 plan. If the rule does not result in Sacramento attaining the standards before 

April 2012, then control measures that were excluded from our original SB 656 list would need to be 

reconsidered, and the threshold for dismissing a measure will be higher. Additional controls that 

would need to be reconsidered include: 

• Controls for non-agricultural open burning, including residential burning of vegetative 

waste 

• Controls for fugitive dust from bulk materials storage and handling 

• Design restrictions to reduce fugitive dust from new and modified paved roads 

• Control of fugitive dust from agricultural sources such as tilling, off-field operations, paved 

and unpaved roads, and livestock operations 

• Control of chipping and grinding operations, and co-composting with biosolids and/or 

manure 

Other measures adopted in control plans by other nonattainment areas such as the San Joaquin 

Valley APCD and South Coast AQMD but not yet implemented would need to be considered. 

These measures include: 

• Emission reductions from school bus fleets 

• More stringent control efficiency requirements for PM control devices such as baghouses, 

wet scrubbers, and electrostatic precipitators 

• Controls of agricultural and prescribed burning 

• Control of emissions from green waste composting 

 

3

 American Lung Association’s Nonbinding Statement of Issues, No. 07-1227 et al., National Cattlemen’s 

Beef Association v. Environmental Protection Agency (D.C. Circuit), July 26, 2007 
Staff Report 

Rule 421 

September 7, 2007, Page 5 

• More efficient residential furnaces 

State Mandates: The District is currently designated as a nonattainment area for the state PM10 

and PM2.5 standards. SB 656 required ARB to adopt a list of the most feasible and cost effective 

control measures to make progress towards state and federal PM10 and PM2.5 standards. Districts 

were then required to adopt an implementation schedule for measures by July 31, 2005. The 

District analyzed the particulate matter problems and adopted a schedule of control measures to 

help attain the state ambient air quality standards in July 2005. The following table lists scheduled 

control measures for wood burning fireplaces and wood burning heaters. 

If Cost-effective Emission Benefit 

Determined 

PM Control Measure 

Further 

Study 

Completed

Consideration by 

the Board 

If adopted, Full 

Implementation 

Date 

1 Require use of USEPA-Certified Phase 

II or equivalent devices 2006 2007 2008 

2 

Public Awareness Program with either 

a voluntary curtailment or mandatory 

curtailment 

2006 

2007, if mandatory 

curtailment 

needed 

2007 

3 Require replacement of non-certified 

units upon sale of property 2006 2007 2008 

4 

Restrict number of wood burning 

fireplaces allowed in new residential 

developments 

2006 2007 2008 

5 

Control of wood moisture content. 

Prohibit burning materials that are not 

intended for use in fireplace/heater. 

2006 2007 2008 

 

District Rule 417, adopted on October 26, 2006, implemented control measures 1 and 5, and 

partially implemented control measure 4 by prohibiting the installation of new uncontrolled wood 

burning fireplaces. Proposed Rule 421 implements control measure 2, Mandatory Curtailment. 

Control measures 3 and 4, which address replacement of noncertified units upon sale of property 

as well as density restrictions for new certified wood burning units, will be studied further after the 

effectiveness of Rule 421 is evaluated. Staff may recommend postponing consideration of these 

two measures if Rule 421 is adopted. 

SUMMARY OF REQUIREMENTS

Rule 421 applies to any person who operates a fire or solid fuel burning device. Rule 421 will: 

1. Prohibit wood and other solid fuel fires and the operation of a wood or other solid fuel 

burning fireplace, stove or insert when a mandatory curtailment is in effect; 

2. Require the Air Pollution Control Officer to declare a mandatory curtailment whenever 

he/she predicts the 24-hour average PM2.5 concentration will exceed 35 μg/m3

; and 
Staff Report 

Rule 421 

September 7, 2007, Page 6 

3. Specify the methods by which the Air Pollution Control Officer will notify the public of each 

mandatory curtailment. 

The rule only applies during the months of November through February. The rule does not apply to 

cookstoves, gaseous fueled fires, fireplaces, stoves or inserts, wood or other solid fuel burning 

conducted as part of a religious ceremony, or homes where the wood or other solid fuel burning 

device is the sole source of heat. 

Violations of the rule would result in penalties. First-time violators would pay an administrative civil 

penalty4

 of $50, with the option to attend a wood smoke awareness course in lieu of paying the 

penalty fee. Penalties for subsequent violations would be determined according to the District‘s 

Mutual Settlement Program. The proposed rule includes a provision for the District’s Board of 

Directors to approve an adjustment to the penalty fee for first-time violations as part of the annual 

budget process. 

The second version of the rule, Version B, allows the Air Pollution Control Officer to grant hardship 

exemptions to households where prohibiting wood or other solid fuel burning would cause economic 

hardship and the granting of the exemption would not have an adverse impact. In granting or 

denying the request for the exemption, the Air Pollution Control Officer would consider factors such 

as the location of the household, the monthly income and number of persons in the household, the 

types of fuels and heating devices in use, the monthly utility bills, the estimated wood (solid fuel) to 

be used on a Mandatory No Burn day, and any other relevant factors. The exemption would only 

be valid for one season and the Air Pollution Control Officer could rescind the exemption at any 

time if an adverse impact is identified or if he/she finds the information that was relied upon in 

granting the exemption is incorrect. 

2007 WOOD BURNING SURVEY

In an effort to gauge public awareness of fine particulate matter air quality problems and health 

impacts, and to gauge support and likely compliance with a curtailment program, a random 

telephone survey of Sacramento County residents was conducted by an independent research firm 

in April 20075

. The survey received responses from 499 county residents, including a subset of 139 

who would be classified as low-income residents based on federal guidelines. The margin of error 

for this survey was +/- 4.9%. Among the key findings are: 

• 71% of all respondents would support the adoption of mandatory curtailment restrictions. 

Among low-income residents, the percentage was nearly identical (73%). 

• 78% of respondents who burn wood indicated that they would be likely to comply with a 

mandatory curtailment. 

• 91% of respondents who burn wood indicated that they would be likely to comply with a 

voluntary curtailment request. However, of those wood-burning respondents who heard this 

past winter’s Spare The Air message, only 46% actually curtailed their wood burning. 

 

4

 Imposed under authority of California Health and Safety Code Section 42402.5. 

5

 The Final Report for the 2007 Wood Burn Research Study, prepared by Aurora Research Group, is 

included in Appendix D of this staff report. 
Staff Report 

Rule 421 

September 7, 2007, Page 7 

• 59% of all respondents heard the wintertime Spare The Air requests not to burn this past 

winter. Among low-income residents, the percentage was 57%. 

• Only 20% rated the area’s air quality as poor, and only 13% rated wood smoke as a very 

serious cause of wintertime air pollution. 

• No respondents indicated wood burning as their sole source of heat. 

• Ownership of at least one wood burning appliance was lower among low-income residents 

(34%) than among the overall population (54%). 

• Among those who reduced their burning of wood last winter, 46% did so because of air quality 

or health concerns, or because they heard a request not to burn. Among low-income 

residents, the percentage who reduced their wood burning for these reasons was much lower 

(26.7%). 

• The strongest response to suggested methods of communicating a mandatory curtailment 

episode was disseminating the information through news outlets, such as television and radio. 

EMISSIONS INVENTORY AND REDUCTIONS

Wood smoke is the single largest emissions source, 49%, as reported by the California Air 

Resources Board’s 2006 wintertime PM2.5 emissions inventory for Sacramento County. 

2006 Wintertime PM2.5 Inventory by Source6

Wood Smoke

48.9%

(8.37 tpd)

Farming

2.4%

(0.41 tpd)

Other Mobile

7.8%

(1.34 tpd)

Other Burning

2.2%

(0.38 tpd)

Other Sources

3.0%

(0.52 tpd)

Fugitive Dust

19.2%

(3.28 tpd)

Cooking

3.4%

(0.58 tpd)

Motor Vehicles

8.8%

(1.51 tpd)

Fuel Burning

4.2%

(0.73 tpd)

 

6

 California Air Resources Board, Emission Inventory, Emission Data, Criteria Emissions, Forecasted 

Emissions by Summary Category 2007 Almanac (Base Year 2006), Winter, PM2.5, 2006, Sacramento 

Metropolitan AQMD, www.arb.ca.gov/app/emsinv/fcemssumcat2007.php 
Staff Report 

Rule 421 

September 7, 2007, Page 8 

The California Air Resources Board is responsible for preparing the wood burning emission 

inventory for Sacramento County. The current CARB inventory (2006) estimates PM2.5 emissions 

to be 8.37 tons on an average winter day from wood burning in Sacramento County. CARB 

estimates are based on a 1987 survey conducted in Healdsburg, California that suggested that 0.28 

cords of wood is burned per household per year7

. 

Using Sacramento-specific data, Staff estimates that PM2.5 emissions from wood burning in 

Sacramento County are 2,732 - 4,280 tons per year and 22.8 - 35.6 tons on an average8

 winter day. 

This estimate is based on the UCB/CARB 2003 survey data for Sacramento (Houck) that indicated 

the usage of wood at 0.92 cords per year. The range of emissions is based on the number and 

percent of homes that burn from the 2003 survey (Houck) and the 2007 telephone survey (Aurora). 

If this range of emission estimates was used then the contribution of wood smoke to the overall 

PM2.5 inventory would be 72% - 80%. 

Staff received public comments questioning the high percentage contribution from wood 

combustion compared to other areas. When expressed as a percentage of a total inventory, 

Sacramento’s inventory may appear larger than areas with other dominant industrial or agricultural 

sources. But when expressed on a per capita basis, it is consistent with other areas with similar 

population and climate and lower than more rural counties nearby. The table below summarizes the 

emissions rates for several areas. 

County 

Total 

Emissions 

Inventory, 

Wintertime

(tons/day) 

Wood 

Smoke 

Emissions, 

Wintertime 

(tons/day) 

Wood Smoke 

Emissions 

per capita 

(lbs/personday) 

Wood Smoke 

Emissions 

per housing 

unit 

(lbs/housing 

unit-day) 

% PM2.5 

Inventory 

from 

Wood 

Smoke 

Sacramento County 17.09 8.37 0.012 0.032 49% 

Butte County 10.12 4.77 0.044 0.120 47% 

Fresno County 29.28 4.98 0.011 0.034 17% 

Placer County 11.96 6.53 0.040 0.094 55% 

Nevada County 11.96 9.54 0.193 0.394 80% 

Kern County 29.92 3.90 0.010 0.031 13% 

Contra Costa County 15.92 4.72 0.009 0.025 30% 

San Joaquin County 12.77 3.19 0.010 0.030 25% 

Seattle (King County) 

Washington n/a 9.32 0.010 0.024 63% 

Note: 

1. Emission Information for California counties came from California Air Resources Board, Emission Inventory, Emission Data, 

Criteria Emissions, Forecasted Emissions by Summary Category 2007 Almanac (Base Year 2006), Winter, PM2.5, 2006, 

www.arb.ca.gov/app/emsinv/fcemssumcat2007.php 

2. 2006 population data and 2005 housing units came from Census data, www.quickfacts.census.gov/qfd/states/06/06007.html

3. The 63% wood smoke contribution is reported in Puget Sound area, “Next Ten Years Fact Sheet – Fine Particulate Matter” 

4. The Kings County Emission Information came from email to Hao Quinn from Agyal Kwame, 8/27/07

 

7

 California Air Resources Board, Area Source Methodology, Section 7.1, Residential Wood Combustion, 

Revised July 1997 

8

 Based on a 120-day winter 
Staff Report 

Rule 421 

September 7, 2007, Page 9 

Additionally, data collected9 from the air monitoring stations on a small sample of high particulate 

matter days suggests that the directly emitted wood smoke portion of the ambient filter samples is 

37%. Some unknown fraction of the aerosol components (ammonium nitrate and ammonium 

sulfate) cannot be ascribed to any individual source category but would include some fraction of 

NOx from wood burning. Therefore, air monitoring data corroborates the CARB emissions inventory 

estimates. 

The primary effect of the proposed rule will be to reduce PM2.5 concentrations on peak days, 

reduce adverse health effects particularly for those in sensitive groups, and make progress to attain 

the state and federal annual and 24-hour health standards. 

The emission reductions have been calculated based on both the CARB emission inventory from 

above and based on the higher emission inventory with the usage patterns from the UCB/CARB 

2003 survey data or the 2007 telephone survey. The calculations in both cases assume a 

compliance rate of 78% based on the telephone survey. The San Joaquin Valley APCD assumed a 

compliance rate of 80% when they adopted their mandatory no burn rule. Actual air quality benefits 

from this program depend on several factors, including the accuracy of the PM2.5 forecasts and 

effectiveness of the public outreach efforts to educate wood burning residents, the actual 

compliance rates, and weather. Weather is the most significant factor in the buildup of pollution. 

Staff used Sacramento-specific survey data as an alternative to the CARB methodology. Emissions 

are based on the following demographic data. The ranges in the data are due to the differences in 

information between the previous survey (Houck) and the most recent phone survey (Aurora). The 

Houck survey reported fewer homes with wood burning devices, but a higher percentage of the 

homes indicated they used their device than the Aurora telephone survey. Based on these two 

data sources, in Sacramento County: 

• 155,600 – 195,800 residences have fireplaces 

• 79,100 – 91,900 residences have wood stoves 

• 26,400 – 30,600 residences have wood burning inserts 

• 2,000 – 15,100 residences have pellet stoves 

Of the homes with wood burning equipment: 

• 101,200 – 139,000 residences with fireplaces burn wood 

• 51,400 – 78,100 residences with wood stoves burn wood 

• 17,100 – 26,000 residences with wood burning inserts burn wood 

• 2,000 – 9,800 residences with pellet stoves burn pellets 

• 57% use wood burning fireplaces or fireplace inserts more for aesthetics 

• 43% use wood burning fireplaces or fireplace inserts more for supplemental heating 

The average wood usage per residence is based on Houck survey responses. 

• Fireplace Users - 0.92 cords per year 

• Wood Stove Users – 1.5 cords per year 

• Pellet Stove Users – 4,000 pounds per year 

The table below summarizes the inventory and potential emission reductions from both the CARB 

 

9 "Final Staff Report SB 656 Assessment and Control Measure Evaluation", SMAQMD July 28, 2005 
Staff Report 

Rule 421 

September 7, 2007, Page 10 

emission inventory and the inventory prepared from Sacramento-specific survey data. Detailed 

calculations and data sources are presented in Appendix C. 

Emission Inventory and Emission Reductions 

CARB Inventory 

Tons/day 

SMAQMD Estimates 

Pollutant Tons/day 

Inventory Reductions Inventory Reductions 

PM10 8.69 6.78 23.67 – 36.96 18.43 – 28.86 

PM2.5 8.37 6.53 22.8 – 35.6 17.75 – 27.8 

NOx 0.71 0.49 3.8 – 4.1 2.5 – 2.9 

CO 65.9 51.30 275 - 317 214 – 247 

COST IMPACT

Section 40703 of the California Health and Safety code requires that the District consider and make 

public its findings relating to the cost effectiveness of implementing an emission control measure. 

Cost to Businesses: Hotels and restaurants with solid fuel burning devices would have a cost 

savings from reduced wood use, because they burn wood for aesthetic purposes. Staff does not 

have information to quantify the impact, if any, to these businesses due to the loss of ambiance. 

There will be a cost impact to wood retailers, because mandatory curtailment will reduce the 

amount of wood burned by the public, and therefore, the amount of wood sold by retailers. The 

estimated cost of the wood products not burned on a mandatory curtailment day is $55,920 – 

$216,460 or $1,677,460 - $6,493,800 over the entire winter season. 

Cost to Public: The majority of the people affected by the rule burn wood for ambiance and would 

have cost savings from reduced wood use. For people who use wood as their primary or 

supplemental heat source, there will be a shift in costs from wood to an alternate source for heat. 

Anecdotal information from comments during public workshops suggests that some consumers may 

have reduced heating costs from using wood or pellets as a supplemental heat source. The data 

below shows that it costs less per unit of heat delivered to use natural gas or electricity than to use 

wood10. Reported cost savings may result from personal comfort choices and/or because 

supplemental sources heat main living areas while other rooms remain cooler than the home’s 

alternative heat source would provide, resulting in a net reduction in heat delivered. Staff cannot 

rely on anecdotal information to estimate community scale impacts. 

 

10 In the case that free wood is delivered to the residence at no cost, there would be an increase in fuel 

cost. 
Staff Report 

Rule 421 

September 7, 2007, Page 11 

Heating Device Thermal Efficiency Fuel Cost per MMbtu

Fireplace 7% $267.76 

Certified Wood Stove 63% $29.75 

Pellet Stove 76% $20.56 

Propane Fireplace 75% $27.67 

Natural Gas Fireplace 75% $15.07 

Electric Fireplace >99% $23.39 

Gas Central Heat & Air 80% $14.13 

Electric Central Heat & Air 100% $23.39 

Propane Central Heat & Air 80% $25.94 

Note: 

1. used as primary source of heat 

2. PG&E rates for natural gas (2007) 

3. SMUD rates for electricity (2006) 

4. Average cost of cord of wood = $215, average cost of pellets = $250/ton, and Cost of propane = $1.899/gallon

The average cost of heating a home with a wood stove for 30 days is $181, while the cost is $142 

for electricity and $92 for natural gas. 

Under Version B of the rule, if adopted, for households where it would be an economic hardship to 

not burn wood and the granting of an exemption would not cause an adverse impact, the rule allows 

the Air Pollution Control Officer to issue hardship exemptions. 

Overall Rule Cost Effectiveness: A cost effectiveness of the rule can be calculated by using the 

cost (lost sales for wood suppliers, program cost to the District). In this case the cost effectiveness 

is estimated to be $3.99 - $4.72 per pound of PM2.511. To put these costs into perspective, it is 

useful to compare the cost effectiveness for other District rules. District Rule 417, Wood Burning 

Appliances, cost $4.19/lb of PM2.5 in today’s dollar. It should be noted that most of the District’s 

existing rules are for controlling ozone precursors, usually VOC or NOx. Although this rule is not 

specifically a NOx reduction strategy it does achieve NOx reductions. The cost effectiveness of this 

rule on a NOx + PM2.5 basis is $3.66 - $4.39 per pound of NOx + PM2.5. The 2005 amendments 

to District Rule 411, NOx from Boilers, Process Heaters and Steam Generators cost $13.90/lb of 

NOx. The cost effectiveness of the gasoline dispensing regulations (Rule 449, Transfer of Gasoline 

into Vehicle Fuel Tanks; 12/17/1991 rule amendments) is at the higher end of the cost effectiveness 

range, costing $17/lb of VOC in today's dollars. Rule 452, Can Coating (8/21/1990 rule 

amendments), is at the low end of the range at a cost of $1/lb of VOC in today's dollars. 

Cost to the District: The implementation and costs to the District for Rule 421 fall into three 

general areas; 1) forecasting PM2.5 air quality, 2) public outreach to educate and inform individuals, 

and 3) enforcement/compliance. 

The first two areas will build on our long history and expertise in public outreach for ozone. Since 

1995, the District has managed and provided forecasting through a contractor for the summer 

 

11 The cost effectiveness estimate used the CARB inventory for the low end and SMAQMD inventory for 

the high end. 
Staff Report 

Rule 421 

September 7, 2007, Page 12 

Spare The Air program on behalf of the air districts of the Sacramento region. In 2006, the District 

and its forecast contractor expanded air quality forecasting to provide regional winter PM2.5 

forecasts, which included the Placer County and Yolo-Solano air districts. This phase of winter 

PM2.5 outreach aligned with the Spare The Air program by using the same forecasting team and 

associated contacts within the community. Basic public relations efforts such as press releases and 

faxes were utilized last season by District staff, but no enhanced forecasting was developed and no 

paid advertising or outreach were used. 

If Rule 421 is adopted, additional contract effort will be required to refine the forecasting tools to 

focus on forecasting Sacramento County PM2.5 violations of the federal 24-hour health standard, 

rather than the region’s air quality in general. Staff estimates the cost of this additional forecasting 

effort to be $28,000 the first year with approximately $8,000 being required for each subsequent 

year. 

In addition, significant additional staff time and media outreach efforts will be undertaken to educate 

the public about the health effects of particulate matter pollution, and Rule 421’s implementation in 

particular, to encourage compliance. This program will be called Check Before You Burn. 

Public outreach information about Check Before You Burn will appear on District Web sites and 

through the existing Air Alert notification program. Due to the mandatory nature of Rule 421, a 

more comprehensive outreach program will be undertaken, which may include direct mail, print 

advertisements and press releases in local and ethnic community newspapers, radio commercials, 

print materials in multiple languages distributed by volunteer community groups and businesses, 

and District compliance inspection staff. The program will also leverage awareness through free 

media opportunities including using existing contacts with local broadcast meteorologists. 

The total program cost for these comprehensive outreach efforts is estimated to be approximately 

$160,000 for the first year. Subsequent years should maintain this same level of outreach funding in 

order to achieve maximum awareness and compliance with Rule 421. 

Compliance with the rule will be determined by visual inspection to determine if solid fuel burning is 

occurring. Indoor use of burning devices will be detected by observing smoke from chimneys or 

flues. Financial penalties may be assessed for violations of Rule 421 based on the fee set in the 

rule and the District’s existing Mutual Settlement Program. The estimated staff resources for the 

enforcement/compliance effort are 0.4 FTE, specifically for the following. 

1) Surveillance by inspection staff on forecasted no burn days for at least 1 hour per day per 

inspection staff. 

2) Responding to all reported burning or smoke complaints from the public. 

3) Compliance school provided at no cost to first-time violators. This is currently anticipated to 

be given by the Business Environmental Resource Center under our existing contract for 

compliance assistance efforts. 

SOCIOECONOMIC IMPACT

CHSC Section 40728.5 requires a district to perform an assessment of the socioeconomic impacts 

before adopting, amending, or repealing a rule that will significantly affect air quality or emission 
Staff Report 

Rule 421 

September 7, 2007, Page 13 

limitations. The District Board is required to actively consider the socioeconomic impacts of the 

proposal and make a good faith effort to minimize adverse socioeconomic impacts. 

CHSC Section 40728.5 requires discussion of: 

1. The type of industry or business, including small business, affected by the proposed rule or rule 

amendments. 

2. The impact of the proposed rule or rule amendments on employment and the economy of the 

region. 

3. The range of probable costs, including costs to industry or business, including small business. 

4. The availability and cost-effectiveness of alternatives to the proposed rule or rule amendments. 

5. The emission reduction potential of the rule or regulation. 

6. The necessity of adopting, amending, or repealing the rule or regulation to attain state and 

federal ambient air standards. 

Type of industry or business, including small business, affected by the rule: Rule 421 applies 

to the use of solid fuel burning appliances and fires. This rule will affect small businesses, as well 

as the general public. Examples of small businesses affected are wood suppliers, restaurants, and 

hotels. Anyone in the general public who burns wood or other solid fuel will also be affected by this 

rule. 

Impact of Rule 421 on employment and the economy in the District: The industry most 

affected by this rule is wood suppliers. This includes wood lot dealers, and more decentralized 

wood sales, such as wood bundles bought at a grocery store. At present, there are only a handful 

of wood lots located in Sacramento. Wood product sales are expected to be reduced $1,677,460 – 

$6,493,800 per year from wood not being used. Some of this reduction will be diverted to an 

increase in natural gas use. No comments on employment impacts were received during the public 

meetings. 

There is an expected cost savings to the public. As discussed in the cost impacts section, any cost 

of using an alternative source for heat would be offset by the fact that the dollar cost per heat unit is 

greatest for wood among typical fuel sources. The average cost of heating a home with a wood 

stove for 30 days is $181, while the cost is $142 for electricity and $92 for natural gas. 

Range of probable costs of Rule 421: This rule in not expected to have any net cost increase 

to households for compliance with the rule. 

Availability and cost-effectiveness of alternatives to Rule 421: Alternatives to the proposed rule 

include: 

• Adopting different PM2.5 concentration thresholds for mandatory curtailment; 

• Relying on voluntary curtailment instead of mandatory curtailment; 

• Allowing certain classes of wood burning devices, certified wood or pellet stoves or 

inserts, to operate as part of an additional voluntary or on some mandatory curtailment 

days; and 

• Adopting alternative control measures such as requiring replacement of noncertified 

devices upon sale of property and/or limiting the number of devices allowed per acre. 
Staff Report 

Rule 421 

September 7, 2007, Page 14 

Threshold alternative 

An important aspect of the mandatory curtailment program is setting the level at which a curtailment 

is declared. A lower threshold will result in reducing adverse health effects and more curtailment 

days. 

In determining what threshold to set for the mandatory curtailment, the historical PM2.5 data for the 

last few years were examined to determine possible effects. The following table shows the number 

of days each winter that exceeded certain 24-hour thresholds. 

Days Above PM2.5 Thresholds from BAM Monitors 

Season 65 μg/m3 53 μg/m3 40.5 μg/m3 35 μg/m3

2004 2 2 12 23 

2005 4 6 15 20 

2006 3 6 28 37 

Average 2 5 18 27 

The thresholds above are tied to the following: 

 65 μg/m3

 – 1997 federal 24-hour standard 

 53 μg/m3

 – 127 AQI, 2006 level at which voluntary curtailment called 

 40.5 μg/m3

 – Equivalent to 100 on the current AQI scale, the dividing line between 

moderate air quality and unhealthy for sensitive groups 

 35 μg/m3

 – New 2006 federal 24-hour standard, 89 AQI 

Staff recommends setting the curtailment threshold to match the current federal 24-hour health 

standard. Using this criterion, a mandatory curtailment will be called when the 24-hour average 

PM2.5 concentration is predicted to exceed 35 μg/m3

. 

The cost effectiveness values of each of these alternative thresholds are nearly identical to the 

proposed threshold, because the emissions benefits and the majority of costs are proportional to 

reduction in wood use. The proposed threshold of 35 μg/m3

 is the federal 24-hour health standard 

for PM2.5 and therefore provides for protection of public health. The other options essentially allow 

continued burning on days that air quality is forecasted to be unhealthy even though wood burning 

significantly contributes to that poor air quality. 

Voluntary program alternative 

A key difference in the effectiveness of a voluntary curtailment versus a mandatory curtailment is 

the level of compliance. Questions about changes in wood burning behavior were included in the 

2007 Wood Burning Survey in an effort to gauge the level of compliance. While a similar number of 

respondents indicated they would comply with both a voluntary and mandatory curtailment (83% 

and 85%), the actual level of compliance with the voluntary curtailment was significantly lower. Of 

those wood-burning respondents who heard this past winter’s Spare The Air message, only 46% 

actually curtailed their wood burning. This translates into only a 27% reduction (46% of 59%) in 

wood burning on voluntary curtailment days. This compliance rate is not expected to bring 

Sacramento into compliance with the health-based standards. 
Staff Report 

Rule 421 

September 7, 2007, Page 15 

Certified devices alternatives 

Since 1992, EPA has required that certain wood stoves be designed to meet established emissions 

standards12. Manufacturer's brochures suggest that pellet stoves and inserts also emit less than 

EPA certified wood stoves. Three alternatives were considered 1) add a voluntary no burn 

component, or 2) create a two-stage mandatory no burn rule, or 3) allow certified devices to burn on 

all mandatory no burn days. 

Voluntary no burn program

The first alternative would expand the no burn program, by adding a voluntary no burn program that 

allows certified devices and pellet stoves to operate on days forecast to exceed a specified level 

below the mandatory no burn threshold, but recommends that non-certified devices not be 

operated. Staff evaluated a 30 μg/m3

 threshold. Staff anticipates that this would result in an average 

of 33 days per year (about 6 more than the proposed 35 ug/m3 threshold no burn days, albeit 

voluntary) for those without certified devices or pellet stoves. The San Joaquin Valley Unified Air 

Pollution Control District (SJVUAPCD) and Puget Sound, Washington both included this type of 

voluntary component. They both prohibit the use of all devices, including certified devices, at a 

poorer air quality levels. San Joaquin Valley established their program to address violations of the 

federal PM10 standards. Plans are due for the 1997 PM2.5 standards in 2008, and they have not 

yet addressed the 2006 PM2.5 standards. Puget Sound is not a federal nonattainment area and is 

not expected to be nonattainment for the new PM2.5 standards. The Board of Directors could direct 

staff to implement this type of voluntary program without regulatory language. 

Modified mandatory no burn program

The second alternative is to modify the mandatory no burn program to allow certified devices or 

pellet stoves to operate on either 1) days forecast to exceed 30 μg/m3

 but less than 35 μg/m3, or 2) 

some level above the recommended 35 μg/m3 level, but below a higher threshold, or 3) allow 

certified devices to operate on all mandatory no burn days. 

Mammoth Lakes and Denver established rules 12-20 years ago to address federal PM10 

nonattainment problems. Albuquerque also established rules at this same time but were not 

nonattainment for PM10. All three areas allow certified devices to burn on mandatory no burn days. 

 Their rules were put in place about the time EPA issued certification requirements. This early effort 

to educate consumers when certified devices were first appearing on the market may have eased 

implementation difficulties. None of these areas is expected to violate federal PM2.5 violations. 

Special requirements for certified devices are not recommended for several reasons: 

1. While certified devices and pellet stoves are designed to pollute less than fireplaces and 

non-certified wood stoves, their emissions are about an order of magnitude higher than 

gaseous fueled devices. 

Comparison of Emission Factors 

Technology PM2.5 Emission Factor 

(lb/mmBtu) 

Certified Wood Stove 1.85 

Pellet Stove 0.69 

Propane Fireplace 0.01 

 

12 EPA’s Standards of Performance for New Stationary Sources: Residential Wood Heaters 
Staff Report 

Rule 421 

September 7, 2007, Page 16 

Natural Gas Fireplace 0.01 

Electric None 

2. Certified devices and pellet stoves can smoke if not installed or operated properly. 

Prohibiting all wood smoke, whether from a certified device or uncontrolled fireplace, is most 

appropriate for air quality and equity reasons. 

3. Collectively, certified wood and pellet stoves and inserts comprise 7% of the wood burning 

emissions. This percentage will increase as new devices are installed or older devices 

replaced, particularly since no new fireplaces may be installed after October 2007, and new 

developments must use either gas fireplaces or certified equipment. All emissions 

reductions contribute to attainment of federal health standards. 

4. Although pellet stoves are easily recognizable to the public, certified wood stoves are not 

easily distinguished from non-certified wood stoves. To know whether you have a certified 

stove you either need to know when the device was purchased (after 1992), or check the 

model number of the stove (located on the back or side of the device) and look it up on 

EPA’s Web site. This may be difficult for some residents and would make enforcement 

more difficult. 

5. Independent public opinion surveys reported that only 13% of residents rate wood smoke as 

a very serious cause of wintertime air pollution. Public education staff and our consultants 

stress the importance of creating a simple message as a key to the success of Rule 421 

outreach efforts. Creating additional complexity will further burden an already difficult 

educational effort. 

6. Although manufacturers suggest that creating special provisions for certified devices will 

increase compliance, no data has been provided or is available that substantiates these 

assertions. 

7. Manufacturers also suggest that not allowing certified devices to operate on some or all no 

burn days reduces the incentive to replace dirty devices with cleaner burning alternatives. 

No data has been provided to substantiate that assertion. Replacing dirty devices with 

cleaner burning alternatives is fairly expensive. The capital and operational costs are likely 

to be more significant factors in determining whether to replace dirty devices, and the choice 

of which devices to select. The District's incentive program provides the greatest incentive 

to install gaseous fueled devices. Voucher data suggests that 60% of incentive program 

participants choose gaseous fueled devices. Staff can track this and propose modifications 

to incentives or rule requirements if participation levels drop. 

 

13 Installation costs are pretty similar $350-500 and additional material costs had a wide range from $250-

1000 depending on the specifics of the installation. Installation and material costs for electric fireplaces 

are 0-$75. 

 Cost of Devices Voucher incentive 13 Thermal Efficiency Fuel Cost 

$ per MMBtu Non-EJ EJ 

Wood Stove $600-2900 63% 29.75 $250 $400

Wood Insert $1100-3000 63% 29.75 $250 $400

Gas/Propane Stove $1000-2700 75% 27.67 $350 $500

Gas Insert $1400-3500 75% 15.07 $350 $500

Pellet Stove $1200-4100 76% 20.56 $350 $500

Pellet Insert $1400-3800 76% 20.56 $350 $500

Electric fireplace ~$300 >99% 23.39 $0 $0 
Staff Report 

Rule 421 

September 7, 2007, Page 17 

Additional Control Measure alternatives 

Two additional wood burning control measures were included on the SB 656 Further Study 

schedule. They include replacement of non-certified units upon sale of property, and density 

restrictions for all wood burning appliances. These measures are not mutually exclusive, and each 

can provide emissions reductions in addition to those provided by proposed Rule 421. If they are 

found to be feasible, these measures could be considered for adoption in 2010. Therefore, these 

alternatives were not included in Rule 421. 

The emission reduction potential of Rule 421: The proposed rule will achieve the following 

emission reductions (See discussion under Emissions Impact): 

Emission Inventory and Emission Reductions 

CARB Inventory 

Tons/day 

SMAQMD Estimates 

Pollutant Tons/day 

Inventory Reductions Inventory Reductions 

PM10 8.69 6.78 23.67 – 36.96 18.43 – 28.86 

PM2.5 8.37 6.53 22.8 – 35.6 17.75 – 27.8 

NOx 0.71 0.49 3.8 – 4.1 2.5 – 2.9 

CO 65.9 51.30 275 - 317 214 – 247 

Moreover, the rule may reduce the numbers of days that the county exceeds the federal 24-hour 

PM2.5 standard. 

The necessity of adopting, amending, or repealing the rule or regulation to attain state and 

federal ambient air standards: Rule 421 is necessary to comply with feasible and most effective 

control measures requirements of SB 656 and to provide emission reductions that contribute to 

attainment of the state and federal PM2.5 standards and state PM10 standards. 

OTHER FACTORS: 

Technological Feasibility: Staff evaluated the technological feasibility of the proposed rule. 

Mandatory curtailment programs have been implemented in the San Joaquin Valley Unified APCD 

and areas of Colorado, New Mexico, and Washington State, and have been demonstrated to be 

feasible. 

Enforceability: Compliance with the mandatory curtailment program will be enforced with visual 

inspection to determine if burning is occurring. Indoor use of wood burning devices will be detected 

by observing smoke from chimneys or flues. Fines of $50 would be issued to first-time violators, 

increasing for further violations. First-time violators would be allowed to attend an instructional 

class in lieu of paying the fine. Subsequent violations will be processed under the District’s existing 

Mutual Settlement Program. 

Public Acceptability: A number of districts have adopted similar measures, which have been in 

effect for several years (see table below). 

District or Location In Effect Since 

San Joaquin Valley APCD 2003 
Staff Report 

Rule 421 

September 7, 2007, Page 18 

Denver, Colorado 1987 

Puget Sound, Washington 1995 

Mammoth Lakes, California 1990 

Bernalillo County (Albuquerque), New Mexico 1995 

The April 2007 survey, by Aurora, of Sacramento County residents gauged support and likely 

compliance with a curtailment program. The survey indicated that 71% of all respondents would 

support the adoption of mandatory curtailment restrictions. Among low-income residents, the 

percentage for support was 73%. Additionally, 85% would likely comply with a mandatory 

curtailment. 

SECTION 40727.2(a) ANALYSIS OF RULE 421 

Section 40727.2(a) of the Health and Safety Code mandates that the District prepare a written 

analysis of the proposed Rule. Section 40727.2(a) also allows the District to put this analysis in a 

matrix form. The matrix analysis of Rule 421 is presented as Appendix A. 

PUBLIC COMMENTS 

Staff conducted eight public workshops throughout Sacramento County between July 23rd and 

August 1st. One of them included a structured presentation, on July 26, 2007. The other seven 

were held in an open house format to encourage conversational dialogue with affected residents 

and businesses. 

Workshop Location Date Time 

Tsakopoulos Library Galleria 

821 I Street, East Meeting Room, Sacramento 

July 23 6:00 p.m. 

La Sierra Community Center 

Gibbons Room 700 

5325 Engle Rd., Carmichael 

July 24 6:00 p.m. 

Rancho Cordova City Hall 

2729 Prospect Drive, Rancho Cordova 

July 25 6:00 p.m. 

SMAQMD District Office 

777 12th Street, 3rd Floor, Sacramento 

July 26 1:30 p.m. 

Laguna Creek High School 

Multipurpose Room 

9050 Vicino Drive, Elk Grove 

July 26 6:00 p.m. 

Orangevale Community Center 

Meeting Room B 

6826 Hazel Avenue, Orangevale 

July 30 6:00 p.m. 

Chabolla Center 

610 Chabolla Avenue, Galt 

July 31 6:00 p.m. 

Folsom Community Center, Ballroom 

52 Natoma Street, Folsom 

Aug. 1 6:00 p.m. 

Noticing for these public meetings included: 
Staff Report 

Rule 421 

September 7, 2007, Page 19 

• Letters to all elected officials in Sacramento County 

• Ad in the Metro Section of the Sacramento Bee 

• Notice to 15 newspapers for inclusion in the calendar sections 

• Notice to 18 radio stations and 10 television stations 

• Letters to 50 homeowners associations and 51 neighborhood associations 

• Notice on the District’s Web site 

• Notices by mail to the District’s list of parties interested in rule development 

• Notices also sent to senior centers, adult education centers, and community centers. 

In addition, staff conducted stakeholder meetings on August 6th and 8th. The stakeholder meetings 

were attended by the Asian Pacific Chamber of Commerce, the Cleaner Air Partnership, the 

Natomas Chamber of Commerce, the Buffalo Chips, and HDR. Staff was requested to present 

Rule 421 at the La Raza Network monthly meeting and that occurred on September 6, 2007. 

Staff received comments and questions at the open houses and stakeholder meetings as well as 

written comments through the mail and e-mail. Comments and responses are listed in Appendix E. 

Staff also presented Rule 421 at the city councils in Sacramento County. The table below lists 

those city council meetings. 

Council Meeting Date/Time 

City of Elk Grove August 22, 2007/6:00 pm 

City of Folsom August 28, 2007/6:30 pm 

City of Sacramento September 11, 2007/6:00 pm 

City of Isleton (Not confirmed) September 12, 2007/7:00 pm 

City of Citrus Heights September 13, 2007/7:00 pm 

City of Rancho Cordova September 17, 2007/5:30 pm 

City of Galt September 18, 2007/7:00 pm 

ENVIRONMENTAL REVIEW AND COMPLIANCE 

Rule 421 was created as part of the response to the requirements of Senate Bill 656 that the District 

implement cost-effective control measures for particulate matter emissions. Staff finds that the 

proposed rule is exempt from the California Environmental Quality Act as an action by a regulatory 

agency for protection of the environment (Class 8 Categorical Exemption, Section 15308 State 

CEQA Guidelines) and because it can be seen with certainty that there is no possibility that the 

activity in question may have a significant adverse effect on the environment (Section 15061(b)(3), 

State CEQA Guidelines). 

California Public Resources Code (Section 21159) requires an environmental analysis of the 

reasonably foreseeable methods of compliance. The proposed rule will not increase emissions and 

will not cause any significant adverse effects on the environment; therefore the Environmental 

Coordinator has concluded that no environmental impacts will be caused by compliance with the 

proposed rule. 
Staff Report 

Rule 421 

September 7, 2007, Page 20 

FINDINGS

The California Health and Safety Code, Division 26, Air Resources, requires local districts to comply 

with a rule adoption protocol as set forth in Section 40727 of the Code. This section has been 

revised through legislative mandate to contain six findings that the District must make when 

developing, amending, or repealing a rule. These findings, effective January 1, 1992, and their 

definitions are listed in the table below. 

 

Rule 421 – Required Findings 

FINDING FINDING DETERMINATION 

Authority: The District must find that a provision of law 

or of a state or federal regulation permits or requires the 

District to adopt, amend, or repeal the rule. 

The District is authorized to adopt Rule 421 by California 

Health and Safety Code (HSC) Sections 40001, 40702, 

40716, 41010, 41013 and 42402.5. [HSC Section 

40727(b)(2)]. 

Necessity: The District must find that the rulemaking 

demonstrates a need exists for the rule, or for its 

amendment or repeal. 

The District is required by HSC Section 39614 (SB 656) 

to adopt the most cost-effective local measures for 

controlling particulate matter from the list developed by 

CARB. Rule 421 implements a wood burning measure 

from the CARB list. [HSC Section 40727(b)(1)]. 

Clarity: The District must find that the rule is written or 

displayed so that its meaning can be easily understood 

by the persons directly affected by it. 

The District has reviewed the proposed rule and 

determined that it can be understood by the affected 

parties. In addition, the record contains no evidence that 

people directly affected by the rule cannot understand the 

rule. [HSC Section 40727(b)(3)]. 

Consistency: The rule is in harmony with, and not in 

conflict with or contradictory to, existing statutes, court 

decisions, or state or federal regulations. 

The District has found that the proposed rule does not 

conflict with, and is not contradictory to, existing statutes, 

court decisions, or state or federal regulations. [HSC 

Section 40727(b)(4)]. 

Non-Duplication: The District must find that either: 1) 

The rule does not impose the same requirements as an 

existing state or federal regulation; or (2) that the 

duplicative requirements are necessary or proper to 

execute the powers and duties granted to, and imposed 

upon the District. 

Subpart AAA of 40CFR Part 60 (Standards of 

Performance for New Residential Wood Heaters) sets 

standards for new wood heaters but does not apply to 

traditional fireplaces. Rule 421 does not duplicate the 

federal requirements because it requires curtailment of 

use of any fires or solid fuel burning device on certain 

days. [HSC Section 40727(b)(5)]. 

Reference: The District must refer to any statute, court 

decision, or other provision of law that the District 

implements, interprets, or makes specific by adopting, 

amending or repealing the rule. 

In adopting the proposed rule, the District is implementing 

the requirements of HSC Section 39614 (SB 656). [HSC 

Section 40727(b)(6)]. 

Additional Informational Requirements: In complying 

with HSC Section 40727.2, the District must identify all 

federal requirements and District rules that apply to the 

same equipment or source type as the proposed rule or 

amendments. 

The matrix included in Appendix A compares Rule 421 to 

the applicable federal and District requirements. [HSC 

Section 40727.2]. 
Staff Report 

Rule 421 

September 7, 2007, Page 21 

REFERENCES

1. Broderick, David R., and Houck, James E. 2003. “Emissions Inventory Improvement Program 

(EIIP) Residential Wood Combustion Coordination Project” 

2. Dominici, Francesca, Peng, Roger D., Bell, Michelle L., Pham, Luu, McDermott, Aidan, Zeger, 

Scott L., and Samet, Jonathan M. “Fine Particulate Air Pollution and Hospital Admission for 

Cardiovascular and Respiratory Diseases” The Journal of the American Medical Association, 

Vol. 295, No. 10, March 8, 2006. 

3. Houck, James E., Scott, Andrew T., Sorenson, Jared T., Davis, Bruce S., and Caron, Chris. “Air 

Emissions Comparisons Between Cordwood and Wax-Sawdust Firelogs Burned in Residential 

Fireplaces” 

4. Houck, James. 2003. “Results of Wood Burning Survey – Sacramento, San Joaquin, and San 

Francisco Areas, University of California Berkeley/California Air Resources Board – GIS Study” 

5. Morley Chavero, Dawn, Holobow, Naomi E., “2007 Wood Burn Research Study”, May 2007 

6. STAPPA-ALAPCO, EPA, Emissions Inventory Improvement Program. (EIIP) 2001. “Residential 

Wood Combustion”, Volume III, Chapter 2 

7. U.S. Environmental Protection Agency, Compilation of Air Pollutant Emission Factors, Volume I 

Stationary Point and Area Sources, AP-42, Section 1.4 – Natural Gas Combustion, 1998 

8. U.S. Environmental Protection Agency, Compilation of Air Pollutant Emission Factors, Volume I 

Stationary Point and Area Sources, AP-42, Section 1.9 – Residential Fireplaces, 1996 

9. U.S. Environmental Protection Agency, Compilation of Air Pollutant Emission Factors, Volume I 

Stationary Point and Area Sources, AP-42, Section 1.10 – Residential Wood Stoves, 1996 

10. 2006 Winter Emission Inventory for PM2.5, Sacramento County, 2007 CARB Almanac, 2006 

Baseline, extracted 8/23/2007 
Staff Report 

Rule 421 

Appendix A 

September 7, 2007, Page 22

Appendix A 

40727.2 Matrix 

 Comparative Requirements 

Elements of 

Comparison 

Specific 

Provisions Proposed Rule 421 Rule 417 

40CFR60 

Subpart AAA 

Exemptions Cookstoves 

Sole source of heat 

Religious Activity 

If Version B is 

adopted, Economic 

Hardship 

Gaseous fueled 

appliances 

Cookstoves Open masonry fireplaces 

constructed on site 

Boilers 

Furnaces 

Cookstoves 

Devices with air-to-fuel 

ratio > 35-to-1, minimum 

burn rate > 11 lb/hr, 

firebox > 20 cubic ft, or 

weight > 1,760 lb 

Averaging 

Provisions 

 none none none 

Units none g/hr g/hr 

 none Catalytic Units: 4.1 g/hr 

Non-Catalytic Units: 7.5 

g/hr 

Catalytic Units: 4.1 g/hr 

Non-Catalytic Units: 7.5 

g/hr 

Emissions 

Limits 

Compliance 

alternatives 

none Pellet stoves, masonry 

heaters 

none 

Operating 

Parameters 

 Prohibits operation on 

days with PM2.5 

concentration 

projected above 35 

μg/m3

. 

Prohibits burning trash 

and other specified 

fuels 

none 

Work Practice 

Requirements 

 none Wood advertised by 

retailers as “seasoned” 

or “dry” must contain 

less than 20% moisture. 

none 

Monitoring/ Recordkeeping none none none 

Records Frequency none none none 

Monitoring/ 

Testing 

Test Methods none Wood Moisture 

Content, ASTM D4442-

92 

Test methods: 

-PM: Method 28 

-Emissions Concentration, 

if a dilution tunnel 

sampling location uses: 

Method 5G 

-Emissions Concentration, 

if a stack location is used: 

Method 5H 
Staff Report 

Rule 421 

Appendix B 

September 7, 2007, Page 23

Appendix B 

SUMMARY OF PROPOSED RULE

Rule 421, Mandatory Episodic Curtailment of Wood and Other Solid Fuel Burning 

SECTION 

NUMBER PROPOSED LANGUAGE 

101 Sets the purpose of the rule to limit PM emissions from solid fuel burning in fires or 

in specified devices. 

102 Sets the rule applicability to anyone that operates a wood burning device or fires. 

103 Incorporates the District’s standard severability language in case the rule is 

challenged in court. 

110 Sets an exemption for gaseous fuel fired devices. 

111 Sets an exemption for cookstoves. 

112 Sets an exemption for wood burning devices that are the sole source of heat in a 

residence. 

113 Sets an exemption for fires conducted as part of a religious ceremony. 

114 in Version 

B of the rule Sets an exemption for persons who are granted a Hardship Waiver. 

201 Sets the definition of a cookstove as described in 40 CFR 60.531. 

202 Sets the definition of fire as a solid fuel fire not in a wood burning device. 

203 Sets the definition of a fireplace as any permanently installed masonry or factory 

built device designed to operate with solid fuel. 

204 Sets the definition of a pellet-fueled wood burning heater as any wood burning 

heater which is operated on compressed pellets of wood or other biomass material. 

205 Sets the definition of season to the entire four consecutive months of November, 

December, January, and February. 

206 Sets the definition of sole source as the only permanent source of heat that is 

capable of meeting the space heating demands of a residence. 

207 Sets the definition of solid fuel to any wood, non-gaseous, or non-liquid fuel 

consistent with Rule 417. 

208 Sets the definition of a wood burning device as any fireplace, wood burning heater, 

pellet-fueled wood burning heater, or any similar indoor or outdoor device burning 

any solid fuel used for aesthetic or space-heating purposes. 

209 Sets the definition of a wood burning heater as an enclosed, wood burning appliance 

capable of, and intended for space heating as described in 40 CFR 60.531. 

301.1 Prohibits the operation of a wood burning fire or wood burning appliance whenever a 

mandatory curtailment is in effect. 

301.2 Requires the Air Pollution Control Officer to declare a mandatory curtailment 

whenever he/she determines the 24-hour average PM2.5 concentration may exceed 

35 μg/m3

. 

401 Specifies the methods by which the Air Pollution Control Officer will notify the public 

of each mandatory curtailment. 

402 Sets an administrative civil penalty of $50 for first-time violations, pursuant to HSC 

Section 42402.5. Provides for an adjustment to this penalty if approved by the 

District Board of Directors. Subsequent violations will be subject to a penalty under 

the District’s Mutual Settlement Program, similar to violations of other District rules. 

403 in Version 

B of the rule, 

if adopted 

Allows the Air Pollution Control Officer to issue waivers for economic hardship if 

there is a documented compelling reason and the waiver will not have adverse 

impacts. 
Staff Report 

Rule 421 

Appendix C 

September 7, 2007, Page 24

Appendix C 

Rule 421, Mandatory Episodic Curtailment of Wood and Other Solid Fuel Burning 

Emissions Calculations

The baseline emissions are based on historical usage patterns. Emissions are calculated as 

follows: 

Emissions = (Number of Homes) x (fraction of homes w/ device) x (fraction of homes w/ device 

that burn) x (Average amount of wood burned per home) x (EFburning) 

This calculation is repeated for each type of device, and the totals are summed. These 

emissions are assumed to all be emitted during the winter season, which includes 120 days. 

The reduction from a day of mandatory curtailment is calculated by taking 1/120th of the total 

calculated emissions, and adjusting this amount by the expected compliance rate, based on 

survey data. The total reduction for the season is calculated as the daily reduction times the 

expected number of days of mandatory curtailment (30 days). 

The variables used and the calculations are summarized in the following tables: 
Staff Report 

Rule 421 

Appendix C 

September 7, 2007, Page 25 

Source

New Residence Construction 20000 Units per year Nevin, 2006

Total Residences 502142 Units SACOG Projections 12/16/04

% of Homes w/ fireplace 39% Houck, 2003

% of Homes w/ fireplace that burn wood 71% Houck, 2003

% of Homes w/ fireplace that burn Manufactured logs 35% Houck, 2003

% of Homes w/ stove that burn wood 85% Houck, 2004

% of Homes w/ firepit, chiminea 5%

Average Wood Usage Per Household that burns wood 0.92 cord/home Houck, 2003

Average Manufactured Log Use Per Household that 19 Log/yr Houck, 2003

Average Wood Use Per Household that burns wood 1.5 cord/home Houck, 2003

Average Pellet Use Per Household that burns wood 4000 lb/yr Houck, 2004

Average Wood Use Per firepit, chiminea 0.62 cord Yu

Percent of Wood that is Purchased 51.4% Houck, 2003

Heating Value of Wood 6,050 Btu/lb Representative of Certifed Units

Heating Value of Manufactured Log 15,700 Btu/lb Houck, Wax-Sawdust Firelogs

Uncontrolled Fireplace EF 34.6 lb PM10/ton of wood AP 42 1.9

Uncontrolled Stove EF 30.6 lb PM10/ton of wood AP 42 1.10

Controlled (non-catalytic) Fireplace EF 14.6 lb PM10/ton of wood AP 42 1.10

Manufactured Log EF 10.7 lb PM10/ton of log Houck, Wax-Sawdust Firelogs

Pellet Stove EF 8.8 lb PM10/ton of wood AP 42 1.10

NG PM10 EF 0.007 lb/MMBtu AP 42 1.4

NOx EF 2.6 lb/MMBtu AP 42 1.9

CO EF Fireplace 352.6 lb/ton of wood AP 42 1.9

CO EF Uncontrooled Stove 230.8 lb/ton of wood AP 42 1.10

CO EF Phase II Stove 140.8 lb/ton of wood AP 42 1.10

CO EF Pellet Stove 39.4 lb/ton of wood AP 42 1.10

Thermal Efficiency Fireplace 7% Houck, 1998

Thermal Efficiency Certified Stove 63% Representative of Certifed Units

Thermal Efficiency NG Fireplace 75% Houck, 1998

Incremental Cost to install Certified Fireplace Insert 2,500.00 $ John Crouch, HPBA

Incremental Cost to install NG Fireplace Insert 500.00 $ John Crouch, HPBA

Incremental Cost to install Electric Fireplace 400.00 $ John Crouch, HPBA

Cost of Wood (per Cord) 215.00 $ Staff Survey

Cost of Manufactured Log (per Log) 3.00 $ Staff Survey

Cost of NG ($/MMBtu) 11.30 $ Staff Survey

Cost of Electricity ($/kWh) 0.08 $ Staff Survey

Burn Rate of Wood in Fireplace 6.60 lb/hr Houck, 1998

Burn Rate of Manufactured Log in Fireplace 3.00 hr/log Houck, Wax-Sawdust Firelogs

Median Burn Rate Certified Fireplace Insert 3.16 lb/hr Representative of Certifed Units

Heat Input Rate NG Insert 30,000 BTU/hr Staff Survey

Volume Cord of Wood (exluding void space) 79 ft3/cord EIIP

Density of Pacific Hardwood 24 lb/ft3 EIIP

Weight of Manufactured Log 4.95 lb/log Broderick, 2003

Wood Burning Statistics & Information

Information
Staff Report 

Rule 421 Appendix C September 7, 2007, Page 26 Based on Previous Surveys 

Total Housing Units 502142 78%Threshold 35 μg/m3 Days 30

Wood Burning Appliance Types Fireplace Non-Certified Stove Certified Stove Pellet Stoves Total% 39% 22% 2% 0.4% # total 195835 110270 12252 2009 # total that burn 139043 93730 10414 2009 Total Cost $ amount of fuel used 31,409,645 30,227,869 3,358,652 803,427 6

$ 

$ amount of reduced fuel used 6,124,881 5,894,434 654,937 156,668 1

$ 

Total Uncontrolled Emissions (lb/yr) 4,230,440 4,078,485 216,216 35,351 

Total Reduction (lb/yr) 824,936 795,305 42,162 6,893 

Percent Reduction 19.5% 19.5% 19.5% 19.5% Overall Cost Effectiveness ($/ton) $ 

Overall Cost Effectiveness ($/lb) $ 

NOx Reduction (lb/yr) 84,738 72,773 8,086 10,810 

NOx from NG 2,141 19,812 2,201 597 

Net NOx Reduction 82,597 52,960 5,885 10,213 

CO Reduction (lb/yr) 8,408,534 5,998,571 406,604 30,864 

CO from NG 1,798 16,642 1,849 502 

Net CO Reduction 8,406,735 5,981,929 404,755 30,362 

CO2 Reduction (lb/yr) 82,537,568 88,367,167 8,663,448 2,312,424 

CO2 from NG 2,569,284 23,774,971 2,641,551 716,724 

Net CO2 Reduction 79,968,284 64,592,197 6,021,897 1,595,701 

Expected Compliance Rate
Staff Report 

Rule 421 Appendix C September 7, 2007, Page 27 Based on April 2007 Phone Survey 

Total Housing Units 502142 78%Threshold 35 μg/m3 Days 30

Wood Burning Appliance Types Fireplace Non-Certified Stove Certified Stove Pellet Stoves Total

% 31% 19% 2% 3.0% # total 155664 94905 10545 15064 # total that burn 101182 61688 6854 9792 Total Cost $ amount of fuel used 16,849,029 19,894,380 2,210,415 3,916,800 4

$ 

$ amount of reduced fuel used 3,285,561 3,879,404 431,031 763,776 

$ 

Total Uncontrolled Emissions (lb/yr) 2,421,327 2,684,242 186,088 172,339 

Total Reduction (lb/yr) 472,159 523,427 36,287 33,606 

Percent Reduction 19.5% 19.5% 19.5% 19.5% Overall Cost Effectiveness ($/ton) $ Overall Cost Effectiveness ($/lb) $ NOx Reduction (lb/yr) 84,738 47,895 6,959 52,701 

NOx from NG 2,141 13,039 1,449 2,911 

Net NOx Reduction 82,597 34,856 5,510 49,789 

CO Reduction (lb/yr) 8,408,534 3,947,941 349,946 150,464 

CO from NG 1,798 10,953 1,217 2,445 

Net CO2 Reduction 8,406,735 3,936,988 348,730 148,019 

Expected Compliance Rate
Staff Report 

Rule 421 

Appendix C 

September 7, 2007, Page 28 

Cost Effectiveness Based on CARB Inventory 

Total District Annual Cost $172,877.81

$ amount of fuel used $15,761,086.03

$ amount of reduced fuel used $3,074,070.84

Total Uncontrolled Emissions (lb/yr) 2,008,800

Total Reduction (lb/yr) 391,800

Percent Reduction 19.5%

Overall Cost Effectiveness ($/ton) $9,445.34

Overall Cost Effectiveness ($/lb) $4.72
Staff Report 

Rule 421 

Appendix D 

September 7, 2007, Page 29 

Appendix D 

2007 Wood Burn Research Study 
2618 Stoughton Way, Sacramento, CA 95827 

www.auroraresearchgroup.com

(916) 363-8682 

Sacramento Metropolitan Air Quality District 

2007 WOOD BURN RESEARCH STUDY

FINAL REPORT

MAY, 2007 

SUBMITTED BY: 

DAWN MORLEY CHAVERO & 

NAOMI E. HOLOBOW, PH.D. 

FOR
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 2 

2007 WOOD BURN RESEARCH STUDY

FINAL REPORT

MAY, 2007 

EXECUTIVE HIGHLIGHTS (4 PAGES).....................................................................................4

PROJECT BACKGROUND & OBJECTIVES..............................................................................8

RESEARCH METHODOLOGY ................................................................................................8

RESULTS & CONCLUSIONS................................................................................................10

INVENTORY OF HEATING DEVICES .................................................................................10

General Population Base Survey ........................................................................10 

Low-Income.........................................................................................................13 

Other Group Differences .....................................................................................16 

“BURNERS” VS. “NON-BURNERS” ................................................................................18

Incidence Rate ....................................................................................................18 

Distinctive Characteristics ...................................................................................19 

WOOD-BURNING ACTIVITY............................................................................................20

Frequency ...........................................................................................................20 

Reason for Use ...................................................................................................22 

Type of Fuel ........................................................................................................23 

Length of Burn.....................................................................................................25 

Reduced Usage...................................................................................................25 

AIR QUALITY ISSUES.....................................................................................................28

General Population Base Survey ........................................................................28 

Low-Income Group..............................................................................................30 

Other Group Differences .....................................................................................32 

AWARENESS OF SUMMERTIME SPARE THE AIR..............................................................33

General Population and Low-Income Groups .....................................................33 

Other Group Differences .....................................................................................34 

KNOWLEDGE OF PARTICULATE MATTER........................................................................35

General Population and Low-Income Groups .....................................................35 

Burners vs. Non-Burners.....................................................................................36 

Other Group Differences .....................................................................................36 

AWARENESS OF WINTERTIME NO-BURN REQUESTS ......................................................37
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 3 

WINTER 2006/2007 ACTUAL COMPLIANCE WITH VOLUNTARY NO-BURN REQUESTS......39

General Population and Low-Income Groups .....................................................39 

Burners Only .......................................................................................................40 

SUPPORT FOR VOLUNTARY NO-BURN RULE AND HYPOTHETICAL COMPLIANCE.............41

General Population..............................................................................................41 

Consistency between Actual Compliance Behavior and Hypothetical 

Compliance .....................................................................................................43 

Low-Income Group..............................................................................................44 

Burners vs. Non-Burners.....................................................................................45 

SUPPORT FOR MANDATORY NO-BURN RULE ................................................................46

General Population..............................................................................................46 

Main Reasons For Strongly Approving a Mandatory No-Burn Rule................47 

Main Reasons For Strongly Disapproving of a Mandatory No-Burn Rule .......49 

Low-Income Group..............................................................................................51 

Burners vs. Non-Burners.....................................................................................52 

Other Group Differences .....................................................................................53 

LIKELIHOOD TO COMPLY WITH A MANDATORY NO-BURN RULE......................................53

Owners of Wood-burning Devices.......................................................................53 

Consistency: Support, Hypothetical Compliance and Actual Compliance.......56 

Owner Burners vs. Owner Non-Burners..............................................................58 

Low-Income Group..............................................................................................58 

Other Group Differences .....................................................................................59 

COMMUNICATION STRATEGIES......................................................................................60

General Population..............................................................................................60 

Low-Income Results............................................................................................62 

Group Differences ...............................................................................................63 

AIR ALERT SUBSCRIPTIONS ..........................................................................................63

Group Differences ...............................................................................................64 

DEMOGRAPHICS ...........................................................................................................64

SUMMARY CONCLUSIONS AND RECOMMENDATIONS ......................................................68
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 4 

EXECUTIVE HIGHLIGHTS (4 PAGES) 

Inventory 

 The vast majority (92%) of Sacramento County residents surveyed heat their home with 

natural gas (63%) or electricity (29%). Three percent use wood as their primary heat 

source. 

 There were no respondents who indicated that wood was their sole source of heat. 

 Respondents who use wood as their primary fuel source to heat their home were more likely to own 

their home, and describe it as a single-family home than those who used other fuel sources. 

 Overall, more than half (54%) of all households have at least one wood-burning device. Half 

(50%) had an interior device and 9% an exterior one, including the 6% who owned both 

types. In general, only a third (34%) of low-income respondents owned a wood-burning 

device, significantly fewer than the general population as a whole. 

 One third (33%) of all respondents in the base study of Sacramento County residents were 

classified as “burners”: they owned wood or pellet burning devices (either indoors or 

outdoors), and they burned wood, pellets, or manufactured logs at least once this past 

winter. Significantly fewer “burners” were identified in the low-income group: approximately 

one in five (17%) were classified as burners. 

 There were only three demographic characteristics that distinguished burners from non-burners: home 

ownership (more burners than non-burners were owners rather than renters), type of home (more 

burners than non-burners lived in single family dwellings), and household income (more burners than 

non-burners lived in wealthier households). All other demographics did not distinguish burners from 

non-burners. 

 Last winter, 58% of the general population burners and 68% of the low-income burners lit 

wood, pellet or manufactured log fires at least once a week. 

 Wood was the most commonly consumed fuel in fireplaces (77%), fireplace inserts (87%), and wood 

stoves (100%) of the general population households. Additionally, 30% of pellet stove/insert users 

usually burned wood (instead of pellets) in their pellet stoves. Low-income respondents used similar 

types of fuel, namely wood. 

 Overall, about six in ten indoor burners (57%) used wood fires more for pleasure than for 

supplemental heating. 

 However, the reason for burning wood appears to be linked to the type device used: fireplace users 

were significantly more likely to burn wood for pleasure while wood stove users and pellet stove users 

were more likely to burn for supplemental heating. 

 On average, burners in the general population used 5 logs to fuel a typical wood fire that 

lasted almost 4 hours. However, fireplace users who burned artificial logs consumed 

significantly less fuel than wood burners yet achieved about the same length of burn. 

 Similar results were found among low-income burners: the average burn lasted 3.3 hours and consumed 

4.2 logs. 

 Half (50%) of those who owned wood-burning devices said they burned less wood last 

winter compared to a typical winter. 

 Three in ten interior device owners recalled occasions when they decided not to burn 

wood when they normally would have, and about half of them attributed their decision 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 5 

to air quality or environmental reasons (25%), health reasons (7%) or because they 

saw or heard a request not to burn (14%). 

 When asked specifically about air quality and health reasons, about half said they chose not to 

burn wood because of air quality (56%) and health reasons (46%). The median number of times 

that wood burns were avoided for air quality reasons was 4.5 and it was slightly higher (6 times) 

for health reasons 

Air Quality and PM Pollution Knowledge 

 A third of all respondents rated the quality of air in the area positively, but the majority (twothirds) felt local air quality was only “poor” or “fair”, indicating a broad recognition of air 

pollution in Sacramento County. 

 There is much room for educating the general public about the negative effects of residential 

wood-burning on wintertime air quality: approximately four in ten respondents felt woodburning was not a serious cause of air pollution. 

 Males were significantly more likely than females to say that residential wood-burning fires were “not at 

all serious” causes of air pollution (55% vs. 36%). 

 Only 16% of all respondents in the general population said they were “very knowledgeable” 

about particulate matter pollution. An additional 61% felt “somewhat knowledgeable”. Lowincome respondents claimed significantly less knowledge about PM pollution. 

 Wood burners were just as knowledgeable (or not) about particulate matter pollution as non-wood 

burners. 

 More males than females claimed to be “very” knowledgeable about PM pollution. 

 A higher percentage of respondents who claimed the least knowledge were: poorer, less well educated, 

not registered to vote, and lacking Internet access than their counterparts. 

Awareness of Summertime Spare The Air 

 Recognition of the summertime Spare the Air Program in Sacramento County is very high 

among the general population – nearly nine out of ten respondents in the base study were 

familiar with the voluntary driving reduction program. There was less familiarity among 

respondents in the low-income group, but it was still relatively high at 80%. 

Baseline Awareness of Wintertime No-Burn Requests 

 Awareness of the requests not to burn wood during the winter of 2006/2007 was the same 

across the general population, low-income respondents and burners as well as non-burners. 

It was fairly high, given that there was no paid advertising of the requests this past winter: 

59% of the respondents in the general population base survey and 57% of those in the lowincome group said they heard the wintertime no burn requests. 

 Older respondents were more likely to have heard the requests not to burn than younger respondents. 

Support for a Voluntary No-Burn Program and Likelihood to Comply 

 The vast majority of all respondents approved of a voluntary no-burn rule (85%) and said 

they would comply with it (93%) – a strong endorsement for a voluntary measure. However, 

these figures include respondents who do not own wood-burning devices or burn wood. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 6 

 Although support was slightly lower among the low-income group than among the general population of 

respondents, the majority (77%) approved of a voluntary no-burn measure and 86% said they would 

comply with one. 

 Perhaps the best reflection of levels of acceptance of a voluntary measure to request that residents not 

burn wood is between those who burned wood this year versus non-burners. Results indicated that the 

majority (83%) of those who burned wood this past winter also approved of a voluntary no-burn rule. 

The highest approval was among respondents who owned wood-burning devices but did not use them 

(93%). In terms of compliance, there were no differences – the vast majority (over 90%) in all groups 

said they would comply. 

Actual Voluntary Compliance in Winter of 2006/2007 

 Among those who were aware of the requests not to burn during the past winter, only 34% 

of the general population base survey respondents, and 41% of low-income respondents 

actually complied and voluntarily reduced the number of fires they burned. 

 Among the group of burners, of those who heard the no-burn requests, 46% complied and reduced their 

number of fires. In other words, nearly half of the Sacramento County residents who burned wood 

reduced the number of fires they burned this past winter, specifically because they heard the requests – 

but just over half chose to not refrain from burning. 

 A possible explanation is that those burners who did not comply do not believe that residential woodburning is a serious cause of wintertime air pollution or that there is a problem with the overall quality of 

air in the area. 

 Further analysis revealed a discrepancy between actual compliance behavior and 

hypothetical compliance (what respondents said they would do) -- the largest discrepancy 

occurring in the group of respondents who did not comply with the request not to burn but 

said they would. Those who did comply and also said they would comply were far more 

consistent. 

Support for a Mandatory No-Burn Regulation 

 Although approval was significantly lower than for a voluntary no-burn rule, the majority of all 

respondents (71%) nevertheless approved a mandatory no-burn rule. 

 Those who “strongly” approved of a mandatory no-burn rule did so mainly because of air quality and 

health concerns. 

 The 20% who “strongly” disapproved of a mandatory no-burn rule did so mainly because they don’t 

want their freedom limited by government regulation. 

 Approval of a mandatory no-burn rule was about the same in the low-income group as in the general 

population: 73% either somewhat or strongly approved a mandatory measure. 

 Not surprisingly, approval of a mandatory no-burn rule was significantly lower among burners (56%) 

than non-burners (78%) in the general population. 

Likelihood to Comply with a Mandatory No-Burn Regulation 

 Among those in the general population of Sacramento County respondents who owned 

wood-burning devices (whether or not they used them), over three-quarters (78%) said they 

would likely comply with a mandatory no-burn rule. 

 Respondents were significantly more likely to say they would comply with a mandatory no-burn rule 

than to approve of it, indicating that prior support may not be a necessary requirement for successful 

implementation of a mandatory rule. In other words, respondents may not like the regulation but the 

majority would hypothetically comply with it. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 7 

Discrepancy between Support for a Mandatory No-Burn Rule and Actual Behavior 

 Further analysis revealed approximately the same magnitude of discrepancy between what 

respondents who owned wood-burning devices said they would do voluntarily and what they 

actually did this past winter (about 60% less), regardless of whether or not they supported a 

mandatory no-burn rule. 

 However, actual levels of compliance this past winter did vary according to whether or not 

owners supported a mandatory rule: among those who approved of mandatory measures, 

37% actually reduced the number of fires they burned. This was significantly higher than the 

24% of respondents who complied but who disapproved of mandatory measures. 

 Nevertheless, because the majority (63%) of even favorably-disposed respondents of a mandatory noburn rule did not voluntarily reduce the number of fires they burned this past winter, if a mandatory 

regulation was implemented, it would probably have to be visibly and publicly enforced in order to 

increase levels of compliance. 

Communication Strategies 

 The general news media, such as TV, radio, and newspaper, would be the best way to let 

residents know whether or not they can burn wood on a particular day. 

 Preference for a recorded telephone message varied by a few demographic features (income, 

ethnicity, education, Internet access, type of dwelling and wood burn activity). Ethnicity influenced 

the level of positive ratings of e-mail and text messages. 

 There were no differences by demographics in terms of the positive ratings for the use of general 

media or posting information on the website. 

 Electronic billboards along the freeway and telephone calls were identified as other effective 

ways to advise the public about a no-burn day. 

 Eight percent said they would like to receive something in the mail. Although this would obviously not be 

a way to alert the public about a no-burn request for the next day, a closer look at the verbatim 

responses implies an opportunity for public education about air quality and no-burn days in general. 

These results were based on 401 telephone interviews conducted in April, 2007 with a random 

sample of Sacramento County residents, representative of the population as a whole. Results 

are accurate to within +/- 4.9%, 19 times out of 20. A total of 139 interviews were also 

conducted with a group of low-income (based on federal guidelines) residents. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 8 

PROJECT BACKGROUND & OBJECTIVES

The mission of the Sacramento Metropolitan Air Quality Management District 

(SMAQMD) is to protect public health and the environment through innovative and 

effective programs that aim to improve air quality in Sacramento County. The District 

conducts a Spare The Air Program that now has two seasonal components. The 

summer season runs from May 1 through October 31 and focuses mainly on reducing 

driving during the hot summer months. The winter season runs from November 1 to 

April 30 and focuses on reducing the amount of fine particulate matter (PM) pollution that 

is caused by burning wood in fireplaces, woodstoves, and outside fire pits and 

chimeneas. [The winter PM voluntary reduction program was not advertised to the 

general public to the same extent as the summer program in the 2006-07 season: it was 

advertised mainly through voluntary subscription to AirAlert messages and press 

releases).] A Spare The Air (STA) day/night is triggered when the air quality index 

(AQI) reaches or exceeds 127. When a winter STA day/night is called, the No Burn 

program urges residents to refrain from using their wood-burning devices. 

The objectives of the current study were to conduct interviews with a representative 

sample of Sacramento County residents as well as with a group of low-income (based 

on federal guidelines) residents in order to assess: 

− the current inventory as well as use of wood-burning devices, 

− baseline awareness of PM pollution and the District’s voluntary No Burn 

Program, 

− effectiveness of the No Burn Program in terms of encouraging residents not 

to burn wood on specific STA days, 

− support for (or opposition to) a voluntary No Burn Program, 

− support for (or opposition to) a mandatory No Burn Program, and 

− likely compliance with voluntary and mandatory curtailment program. 

RESEARCH METHODOLOGY

Aurora Research Group was contracted to conduct this public opinion research study. 

For the general population base study, random-digit-dialed (RDD) telephone interviews 

were completed with a representative sample of 401 Sacramento County residents. 

The District was also interested in understanding the opinions and behavior of lowincome residents, that is, the households that had earnings of $20,000 or less.1

 An 

oversample of 98 additional telephone surveys was therefore conducted, using a sample 

that specifically targeted the selected population of interest (ZIP codes with a high 

incidence low-income residents. These interviews were combined with the 41 interviews 

 

1

 Current federal poverty guidelines identify a family unit consisting of 4 persons and earning $19,350 or less as poor. 

2005 HHS Poverty Guidelines. Federal Register, Vol. 70, No. 33, February 18, 2005, pp.8373-8375.(Source: 

http://aspe.hhs.gov/poverty/05poverty.shtml) 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 9 

that were obtained in the base study, for a total of 139 completed interviews with lowincome residents. 

The margin of error for the study as a whole was + or – 4.9%, at the 95% confidence 

level. In other words, we are 95% sure that the true population parameters lie within +/- 

4.9% of the sample statistics. As an example, if a response category to a question were 

chosen by 50% of respondents, we would be 95% sure that the true population 

parameters would be between 45.1% and 54.9% (50.0% +/- 4.9%). The margin of error 

for the subgroup of low-income residents (139 surveys in total) is much larger (+/- 8.3% 

at the 95% confidence level). 

Aurora Research Group designed the questionnaire which addressed the previouslymentioned objectives, and SMAQMD staff approved the final survey. Most of the questions 

were asked in a closed-ended format, but three questions were asked as open-ended. 

Verbatim responses were captured and later categorized for quantitative analyses. 

(Transcripts of all the verbatim responses will be provided in the statistical binder.) The 

questionnaire was translated into Spanish and 6% of the general base study interviews were 

conducted in Spanish. The questionnaire was programmed for a CATI system and 

interviews took approximately 13 minutes on average to administer. Respondents were 

screened for age (adults at least 18 years old2

) and to confirm residency in Sacramento 

County. Interviewing took place between April 7 and April 25, 2007.

Methods of Analysis

Survey results were analyzed using univariate, and multi-variate statistical techniques. The 

type of analysis depended upon the kind of variable analyzed and the hypotheses that were 

generated through an examination of the initial results. Unless otherwise noted, frequency 

percentages cited in this document represent adjusted frequencies, meaning that 

percentages have been adjusted to account for any non-responses (refusals to answer) or 

non-qualified responses (questions not answered due to answers to previous questions). 

Researchers are interested in assessing whether or not the differences in observed 

percentages between certain groups of individuals are due to chance, or if they represent 

real differences among the subpopulations. Differences are identified by running statistical 

analyses and are discussed in the report. Statistical significance within crosstabulation 

tables was calculated using chi square (χ2) statistics. Tests of proportion were used to 

identify differences in responses between questions or groups of respondents. The level of 

significance was generally set to a p value of .01. 

Caveat: 

The sole purpose of this report is to provide a collection, categorization and summary of 

public opinion data. Aurora Research Group intends to neither endorse nor criticize the 

Sacramento Metropolitan Air Quality Management District; or their policies, products, board 

of directors or staff. The Client shall be solely responsible for any modifications, revisions, 

or further disclosure/distribution of this report. 

 

2

 In order to speak with someone under 18 years of age, by law we would need to get the parents’ written permission. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 10 

RESULTS & CONCLUSIONS

The survey results are organized and presented as follows: the inventory of wood-burning 

devices and their use is first presented. Included in this section a subpopulation of “burners” 

was identified. Within each section of the report, the overall base survey results based on the 

401 completed surveys with the general population of Sacramento County residents are first 

presented. Next, results from a group of low-income respondents are presented (41 surveys 

from low-income (under $20,000 per year) households in the base study were combined with 

an oversample of 98 surveys with low-income residents for a combined total of 139 

respondents in the low-income group) and any significant differences from the general 

population in the base study are discussed. This is followed by results which contrast 

households which burned wood this past winter (burners) with those who did not (nonburners). Finally, any statistically significant group differences or demographic characteristics 

(age, income, ethnicity, gender, internet access, the number of people living in the house, 

home ownership, the age of the dwelling, the type of dwelling, air alert subscription, voter 

registration, or education3

) are presented. In other words, up to 13 separate cross-tabulations 

will have been conducted for each question. If no group results are described, it is an 

indication that they were not significant differentiators for a particular question. Unless 

otherwise specified, the reported results exclude responses of “undecided” as well as refusals. 

The order of topics presented in the report was chosen as the most logical in terms of meeting 

the information requirement objectives of the study and does not necessarily conform to the 

order of the questions within the survey. 

INVENTORY OF HEATING DEVICES

General Population Base Survey

 1 The vast majority (92%) of Sacramento County residents surveyed heat 

their home with natural gas (63%) or electricity (29%). Three percent use 

wood as their primary heat source, although it was not found to be their 

sole source of heat. 

All respondents were asked to identify how they primarily heat their home. 

It can be seen in Figure 1 that natural gas was the fuel used most 

frequently, mentioned by six in 10 respondents (63%). Twenty-nine 

 

3

 The reader is referred to the demographic characteristics section near the end of this report to see how the 

demographics were categorized. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 11 

percent heat their home with electricity. Other fuels mentioned by fewer 

than 5% included: wood (2%) or a combination including wood (1%), a 

combination not including wood (2%), and propane (1%). In other words, 

3% use wood as a primary source of heat. One percent said they do not 

heat their house (but use blankets) and one percent was unsure. 

FIGURE 1 – PRIMARY HEAT SOURCE

(AMONG ALL RESPONDENTS) 

Gas

63%

Electricity

29%

Propane

1% No heat used

1%

Don't know

1%

Wood

2%

Combination -

including 

wood

1%

Combination -

no wood

2%

= 3% use

wood

Those who heat their home primarily with wood4

 were asked if wood was 

the only heat source available in their home or could they heat it by using 

another means if they preferred. All 6 respondents said their house was 

equipped with a gas heater that could be used. In other words, there were 

no households in which the sole source of heat was wood. 

 2 Overall, more than half (54%) of all households have at least one 

wood-burning device. Half (50%) had an interior device and 9% an 

exterior one, including the 6% who owned both types. 

Survey questions were asked to determine the incidence rate of Sacramento 

homes with indoor and outdoor wood-burning devices. The data were then 

combined to establish an overall percentage of respondents with at least one 

wood-burning device, regardless of its location. Results indicated that 54% of 

respondents had at least one wood-burning device inside or outside their 

home and the remaining 46% did not own a device that burns wood. More 

specifically, as shown in Figure 2, half of all respondents have an indoor

wood-burning device and 9% owned one outdoors, including the 6% that 

have both types. 

 

4

 This question was only asked of the 6 respondents who said their primary source of heat was wood and did not include 

those who said they use a combination of fuels, including wood. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 12 

FIGURE 2 – OWNERSHIP OF WOOD-BURNING DEVICES

(AMONG ALL RESPONDENTS)

No device

46%

Indoor 

owner only 

45%

Outdoor 

owner only

3%

Indoor and 

outdoor 

owner

6%

Outdoor 

Owners

9%

Indoor 

Owners

51%

 3 About three in ten residents (31%) have a wood-burning fireplace in their 

home and a further 16% have a wood-burning fireplace insert. 

Respondents were read a list of various indoor heating devices, including woodand gas-burning fireplaces, wood- and pellet-burning stoves, and fireplace 

inserts, and asked whether or not their home had one (or more). The most 

common indoor heating device found was the wood-burning fireplace, reported to 

be in 31% of the respondent homes, followed by gas-burning fireplaces (24%) 

and wood-burning inserts (16%).5

 The less common heating devices included 

wood stoves (5%) and pellet stoves (or inserts, 3%). 

FIGURE 3 – PERCENTAGE OF SACRAMENTO HOUSEHOLDS 

WITH INDOOR HEATING DEVICES

(AMONG ALL BASE STUDY RESPONDENTS, INCLUDING UNDECIDED RESPONSES)

29%

21%

16%

5% 3%

2%

3%

<1% <1%

<1%

0%

10%

20%

30%

40%

50%

WoodBurning

Fireplace

GasBurning

Fireplace

Fireplace

Insert

Woodstove Pellet

Stove or

Insert

Percentage of HH

Two devices

One device

31%

24%

16%

5% 3%

 

5

 There were 48 respondents in the base study and six in the low –income oversample who said they have a fireplace and a 

fireplace insert. Based on the assumption that they probably burn wood in the insert and not in the fireplace (without the 

insert), these records were recoded as fireplace insert users (only). 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 13 

 4 The most commonly-owned outdoor device was the outdoor fire pit 

– reportedly owned by 5% of respondents.

Respondents were also asked about any outdoor heating devices, specifically 

fire pits, chimeneas, outdoor fireplaces or other wood-burning devices. Overall, 

ownership of outdoor wood-burning devices was less widespread that of indoor 

wood-burning devices. As shown in the next chart, no more than 5% reported 

having any one of the outdoor wood-burning devices mentioned, with outdoor 

fire pits mentioned more frequently – by 5%. Three percent of those surveyed 

had a chimenea and a similar number (2%) had an outdoor fireplace. 

FIGURE 4 – PERCENTAGE OF SACRAMENTO HOUSEHOLDS 

WITH OUTDOOR HEATING DEVICES

(AMONG ALL BASE STUDY RESPONDENTS, INCLUDING UNDECIDED RESPONSES)

3% 2% 3% 5%

0%

10%

20%

30%

40%

50%

Outdoor Fire

Pit

Chimenea Outdoor

Fireplace

Other Outdoor

Wood-Burning

Device

Low-Income

 5 Like the general population, more than half of low-income 

respondents also use natural gas (55%) as a primary heat source 

and very few (2%) use wood. However, low-income respondents 

were more likely to use electricity (41%) than the general population 

(29%). 

The base study results were compared with the results of those who were 

identified as low-income respondents to determine any significant 

differences in the way they primarily heat their home. Results indicated, 

as shown in the next figure, that the majority of low-income respondents 

used natural gas, similar to the general population. However, low-income 

respondents were more likely to use electricity (41% vs. 29% of the 

general population). The proportion of residents who used wood as a 

primary heat source was nearly identical among both populations (3% of 

the general population and 2% of low-income respondents). 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 14 

FIGURE 5 – PRIMARY HEAT SOURCE: LOW-INCOME & BASE STUDY RESULTS

63% 55%

29%

41%

2%

3%

5% 2%

0%

20%

40%

60%

80%

100%

Base Study Low-Income

Gas Electricity Wood, including combination Other

*

 6 In general, only a third (34%) of low-income respondents owned a 

wood-burning device, significantly fewer than the general population 

as a whole (54%). 

Analyses were conducted to determine the percentage of low-income 

respondents that owned at least one wood-burning device, regardless of its 

location. Overall results indicated that only a third (34%) of low-income 

respondents had at least one wood-burning device inside or outside their 

home, and the majority (68%) did not. More specifically, results showed 

that: 

 29% of respondents have an indoor wood-burning device (only). 

 2% have an outdoor wood-burning device (only). 

 2% have both an outdoor device and an indoor device that burn 

wood. 

As shown in the next chart, the 34% of low-income households with woodburning devices was almost 20 points lower than the proportion of base 

study households with wood-burning devices, which was found to be a 

statistically significant difference. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 15 

FIGURE 6 – OVERALL PERCENTAGE OF HOUSEHOLDS 

THAT OWN A WOOD-BURNING DEVICE: BASE STUDY VS. LOW-INCOME

(INCLUDING UNDECIDED RESPONSES)

46%

66%

54%

34%

0%

20%

40%

60%

80%

100%

Base Study Low-Income Only

No Wood-Burning Device Has Wood-Burning Device

*

(* indicates a statistically significant difference) 

 7 More specifically, low-income respondents were significantly less likely 

to live in homes with indoor gas-burning fireplaces than the general 

population. 

In terms of the different types of indoor heating devices discussed, it can be 

seen in Figure 7 that low-income respondents were significantly less likely to 

own gas-burning fireplaces than the general population.6

 The differences in 

ownership of fireplace inserts, wood or pellet stoves were not found to be 

statistically different. 

FIGURE 7 – OWNERSHIP OF INDOOR HEATING DEVICES

(AMONG LOW-INCOME & BASE STUDY HOUSEHOLDS INCLUDING UNDECIDED RESPONSES)

4% 4% 3%

24%

3%

20%

8%

5%

16%

31%

0%

10%

20%

30%

40%

50%

WoodBurning

Fireplace

GasBurning

Fireplace

Fireplace

Insert

Woodstove Pellet Stove

or Insert

Low-Income Base Study

*

(* indicates a statistically significant difference) 

 

6

 Although the differences seem large, the percentage of low-income fireplace owners (20%) and fireplace insert owners 

(8%) were not statistically different those of the base study fireplace owners (31%) and fireplace insert owners (16%). 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 16 

 8 Similar to the general population, 5% of low-income residents owned 

outdoor heating devices. 

It can be seen in Figure 8 that ownership of outdoor wood-burning devices 

among low-income respondents did not vary significantly from that of the 

general population in terms the overall incidence rate or by specific 

apparatus. 

FIGURE 8 – PERCENTAGE OF LOW-INCOME & BASE STUDY HOUSEHOLDS 

WITH OUTDOOR HEATING DEVICES

(INCLUDING UNDECIDED RESPONSES)

5%

2% 1% 1% 1% 3% 2% 3% 5%

10%

0%

10%

20%

30%

40%

50%

Owns

Outdoor

Device

Outdoor

Fire Pit

Chimenea Outdoor

Fireplace

Other

Outdoor

WoodBurning

Device

Low-Income Base Study

Other Group Differences

 9 Respondents who use wood as their primary fuel source to heat their 

home were more likely to own their home, and describe it as a singlefamily home than those who used other fuel sources. 

In order to try and characterize households in Sacramento County that use 

wood7

 as a primary heat source from those that used other fuel sources, a 

series of chi-square analyses were conducted on the general population base 

study results, including all demographic features. Two attributes emerged as 

statistically important: home ownership and type of home. As shown in 

Figure 9, all (100%) who heated their home primarily with wood owned their 

home versus 72% of those who used non-wood sources; and 93% of wood 

users lived in a single-family home versus 78% of those who used non-wood 

fuels. 

 

7

 For these analyses, we included the respondents who mentioned wood as primary heat source, alone and in 

combination with other fuels. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 17 

FIGURE 9 – DISTINCTIVE DEMOGRAPHIC CHARACTERISTICS OF 

THOSE WHO PRIMARILY USE WOOD VS. OTHER FUELS FOR HEAT: 

GENERAL POPULATION BASE STUDY ONLY

28%

22%

78%

100%

7%

72%

93%

(0%

used 

wood) 0%

20%

40%

60%

80%

100%

Rent Own home All others

(condo,

apartment,

townhouse,

mobile home)

Single-family

detached

home Use Non-Wood Fuels

Use Wood

 10 Those who owned indoor wood-burning devices were more likely than nonowners to own their home, and describe it as a single-family home that was 

built more than 10 years ago. 

Additional chi-square analyses were also conducted on the general population 

base study results to differentiate households in Sacramento County that were 

equipped with indoor wood-burning devices from those that were not. Results 

indicated that only three of the twelve characteristics were significant: home 

ownership, type of dwelling and age of the structure. In other words, those who 

owned an indoor wood-burning device were more likely to own their home, and 

describe it as a single-family home that was built more than 10 years ago. No 

other demographic characteristics were significant. 

FIGURE 10 – DISTINCTIVE DEMOGRAPHIC CHARACTERISTICS OF 

INDOOR DEVICE “OWNERS” VS. NON-OWNERS: 

GENERAL POPULATION BASE STUDY ONLY

39% 36%

64%

30%

70%

84%

92% 89%

61%

8% 11%

16%

0%

20%

40%

60%

80%

100%

Rent Own home All others

(condo,

apartment,

townhouse,

mobile

home)

Single-family

detached

home

10-years or

less

More than 10

years

Non-Owners Owners
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 18 

There were no demographic characteristics that distinguished outdoor device 

owners from non-owners. In other words, outdoor device ownership was 

independent of respondents’ ethnicity, gender, age, income, education, 

number of household members, homeownership, type of home, and age of 

home. 

“BURNERS” VS. “NON-BURNERS” 

Incidence Rate 

 11 Overall, 64% of wood-burning device owners lit a wood fire last winter. 

More specifically, 63% of indoor device owners and 50% of outdoor 

device owners were classified as “burners.”

The criterion used to classify a “burner” was that respondents had to have 

either an interior or an outdoor wood or pellet-burning device, and had to 

have used it at least once this past winter. Multiple questions8

 were used in 

order to insure the accuracy of this dichotomy.9 Results indicated that the 

majority (64%) of wood-burning device owners burned wood last winter. 

The survey data were analyzed by type of device (indoor versus outdoor) and 

results indicated that at least half of the owners were also users or “burners.” 

Usage was slightly higher (63%) among indoor device owners than among 

outdoor users; however, the difference was not found to be statistically 

significant. 

FIGURE 11 – USAGE AMONG BASE STUDY OWNERS 

(INCLUDING UNDECIDED RESPONSES)

36% 27%

64%

50%

63% 50%

0%

25%

50%

75%

100%

Among All

Owners

Among

Indoor

Device

Owners

Among

Outdoor

Device

Owners

Non-Users (Have, But Do NOT Use)

Users (Have & Use)

 

8

 This includes questions about the type of fuel (questions 2.5a-d), the reason for burning (questions 2.6a-d), the frequency of 

use (questions 2.7 and 3.2) and the length of the burn (questions 2.8 and 2.9). 9

 For example, some respondents owned wood-burning appliances and said they burned wood, but in fact had never done so 

this past winter and so were re-classified as non-burners; respondents who did not have interior wood-burning appliances but 

had used outdoor wood-burning equipment were classified as burners; etc. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 19 

 12 One third (33%) of all respondents in the base study of Sacramento 

County residents were classified as “burners”: they owned wood- or 

pellet-burning devices (either indoors or outdoors), and they burned 

wood, pellets, or manufactured logs at least once this past winter. 

Significantly fewer “burners” were identified in the low-income group: 

approximately one in five (17%) were classified as burners. 

Figure 12 indicates that, in the base study, 33% of all respondents surveyed in 

Sacramento County were classified as burners, and the remaining 67% were 

non-burners. In the low-income only group, a significantly lower percentage of 

respondents at 17%, were classified as burners. This latter finding was 

interesting because the study design, which called for an oversample of lowincome households to be studied separately, was based on the hypothesis that 

lower-income residents might be more likely to burn wood than other residents, 

perhaps due to the cost of other heating sources among other reasons. This 

analysis indicates that this was not found to be true – respondents in the lowincome group were less likely to burn wood. 

FIGURE 12 – CLASSIFICATION OF “BURNERS” VS. NON-BURNERS: 

GENERAL POPULATION BASE STUDY VS. LOW-INCOME GROUPS

67%

17%

83%

33%

0%

20%

40%

60%

80%

100%

Base Study Low-Income Only

Non-burners Burners

*

* indicates a statistically significant difference 

Distinctive Characteristics

 13 There were only three demographic characteristics that distinguished 

burners from non-burners: home ownership (more burners than nonburners were owners rather than renters), type of home (more burners 

than non-burners lived in single-family dwellings), and household 

income (more burners than non-burners lived in wealthier 

households). All other demographics did not distinguish burners 

from non-burners. 

In order to try and characterize “burner” households in Sacramento County 

from those that did not burn wood, a series of chi-square analyses were 

conducted on the general population base study results, including all 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 20 

demographic features. Results indicated that only three of the twelve 

characteristics were significant: home ownership, type of dwelling and 

income.10 It can be seen in the next chart (Figure 13) that 84% of burners 

owned their own homes versus 66% of non-burners; 93% of burners lived 

in single-family detached homes versus 71% of non-burners; and 70% of 

burners reported household incomes of $50,000 or more versus 52% of 

non-burners. No other demographic characteristics distinguished burners 

from non-burners: neither gender, ethnicity, education, age, internet 

access, the number of people living in the house, the age of the house, air 

alert subscription nor voter registration were significant. In other words, 

males and females were just as likely to be burners as non-burners, as 

were older and younger residents, better educated and less-educated 

residents, etc. 

FIGURE 13 – DISTINCTIVE DEMOGRAPHIC CHARACTERISTICS OF 

“BURNERS” VS. NON-BURNERS

(GENERAL POPULATION BASE STUDY ONLY) 

34% 29%

71%

48% 52%

84%

93%

66% 70%

7%

30%

16%

0%

20%

40%

60%

80%

100%

Rent Own home All others Single-family

detached

home

Income under

$50,000

Income

$50,000 or

more

Non-burners Burners

WOOD-BURNING ACTIVITY

Frequency 

 14 Last winter, 58% of the general population burners and 68% of the lowincome burners lit wood, pellet or manufactured log fires at least once a 

week. 

Wood-burning device owners were asked to quantify how often they burned 

wood last winter using the following categories: most days, 2 or 3 times a 

week, about once a week, less than once a week, mainly on weekends, or 

 

10 For the purpose of this analysis, household income was dichotomized, using $50,000 as the split point. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 21 

something else.11 Results among indoor burners for both the general 

population and low-income groups are shown in Figure 14. Among indoor 

burners, the frequency of burning wood was comparable: more than half of 

the general population (58%) and the low-income group (68%) reported 

burning wood at least once a week. 

FIGURE 14 – FREQUENCY OF INDOOR WOOD-BURNING

(AMONG BASE STUDY & LOW-INCOME BURNERS EXCLUDING UNDECIDED RESPONSES)

16%

21% 26%

5%

21% 16%

5%

31% 16%

11% 16%

16%

0%

20%

40%

60%

80%

100%

Base Study Low-Income

Once a month or

less

Less than once

a week

Once a week

Mainly on

weekends

2-3 times a week

Most nights

The frequency of use was similar among outdoor burners, with 67% of the 

general population saying they had a wood fire outdoors at least once a 

week. It is interesting to note that 16% of indoor burners said they burn 

wood on most nights, while no outdoor burners said they burned wood 

outside that often. However, due to the small sample size of outdoor 

burners, this figure was not found to be statistically significant.

 

11 Responses to the frequency of wood-burning questions (2.7 and 3.2) were compared with the responses to other 

wood-burning activity questions for consistency in “do not use” responses. In most cases, the 15% of indoor device 

owners and the 58% of outdoor device owners who volunteered they “never” use their wood-burning device were 

categorized as “owners who do not use” as well as grouped with the “non-burners.” 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 22 

FIGURE 15 – FREQUENCY OF OUTDOOR WOOD-BURNING

(AMONG BASE STUDY BURNERS EXCLUDING UNDECIDED RESPONSES)

17%

17%

33%

17%

17%

0%

20%

40%

60%

80%

100%

Among Outdoor Users

Once a month or

less

Less than once

a week

Once a week

Mainly on

weekends

2-3 times a week

Most nights

Of the two low-income respondents who were outdoor burners, one 

reported burning mainly on the weekends and the other said it was less 

than once a month. 

Reason for Use

 15 Overall, about six in ten indoor burners (57%) used wood fires more for 

pleasure and ambiance than for supplemental heating. 

Respondents who burn wood, manufactured logs, or pellets were asked to 

categorize why they burn wood: more for pleasure and ambiance or more for 

supplemental heating. The same question was asked about each type of 

indoor wood-burning apparatus owned. The combined overall results 

indicated that the majority (57%) of those who burn wood do so more for 

pleasure than for warmth (43%). 

 16 However, the reason for burning wood appears to be linked to the type 

device used: fireplace users were significantly more likely to burn 

wood for pleasure while wood stove users and pellet stove users were 

more likely to burn for supplemental heating. 

Results by indoor device type are shown in the next chart (Figure 16). It can be 

seen that the majority of wood stove users (80%) and pellet stove users (87%) 

burned wood for supplemental heating, which is a significantly higher 

percentage then the 31% of fireplace users. In other words, the majority of 

fireplace users (69%) were more likely to burn wood for pleasure than for 

warmth. (Due to the small sample size, the proportion of respondents who 

have and use fireplace inserts was not found to be statistically different from 

the other groups.) 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 23 

FIGURE 16 - REASON FOR BURNING WOOD INDOORS

(AMONG GENERAL POPULATION INDOOR BURNERS EXCLUDING UNDECIDED RESPONSES) 

43%

69%

31%

87% 80%

54%

46%

13%

57%

20%

0%

20%

40%

60%

80%

100%

Overall Pellet Stove Woodstove Fireplace

Insert

Fireplace

Supplemental Heating Pleasure and aesthetics

 17 Low-income respondents tended to burn wood for the same reasons 

as the general population. 

Results of the reasons for burning wood by indoor device among the lowincome burners are shown in the next chart. However, due to the fact that 

there were fewer low-income burners, the differences were not found to be 

statistically significant. 

FIGURE 17 - REASON FOR BURNING WOOD INDOORS

(AMONG LOW-INCOME BURNERS EXCLUDING UNDECIDED RESPONSES) 

62%

54%

46%

100% 100%

67%

33% 38%

0%

20%

40%

60%

80%

100%

Overall Pellet Stove Woodstove Fireplace

Insert

Fireplace

Supplemental Heating Pleasure and aesthetics 

Type of Fuel 

 18 Wood was the most commonly consumed fuel in fireplaces (78%), fireplace 

inserts (87%), and wood stoves (100%) in the general population 

households. Additionally, 30% of pellet stove/insert users usually burned 

wood (instead of pellets) in their pellet stoves. Low-income respondents 

used similar types of fuel, which mainly involved wood. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 24 

Respondents who owned indoor wood-burning devices were asked to 

specify the kind of fuel they usually burned in each of their wood-burning 

appliances: wood, pellets, artificial manufactured logs, or something else. 

Results among the general population of burners are shown in Figure 18. It 

can be seen that wood was the most frequently consumed fuel in fireplaces 

(78%), fireplace inserts (87%), and wood stoves (100%). As one might 

expect, pellets were the most commonly used fuel (46%) among pellet 

stove (and insert) users, although 30% said they usually burn wood. 

FIGURE 18 – TYPE OF FUEL USED FOR INDOOR WOOD-BURNING DEVICES

(AMONG BASE STUDY USERS EXCLUDING UNDECIDED RESPONSES) 

78% 87%

100%

30%

16%

10%

10%

4% 10%

2% 2%

0%

25%

50%

75%

100%

Fireplace Fireplace Insert Wood Stove Pellet Stove or

Insert

Wood Art. Logs Wood & Art. Logs Pellets Other

Among the low-income group, wood was also the most commonly consumed 

fuel, as shown in the next chart. 

FIGURE 19 – TYPE OF FUEL USED FOR INDOOR WOOD-BURNING DEVICES

(AMONG LOW-INCOME USERS EXCLUDING UNDECIDED RESPONSES) 

75% 67%

100%

25%

13% 22%

75%

6%

6% 11%

0%

25%

50%

75%

100%

Fireplace Fireplace Insert Wood Stove Pellet Stove or

Insert

Wood Art. Logs Wood & Art. Logs Pellets Other
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 25 

Length of Burn

 19 On average, burners in the general population used 5 logs to fuel a 

typical wood fire that lasted almost 4 hours. However, fireplace users 

who burned artificial logs consumed significantly less fuel than wood 

burners yet achieved about the same length of burn. Similar results 

were found among low-income burners: the average fire lasted 3.3 

hours and consumed 4.2 logs. 

Those who burned wood or artificial logs were asked to quantify an average 

wood burn in terms of the number of hours as well as the number of pieces 

of wood (or manufactured logs) burned. Overall, wood burns ranged from 1 

to 15 hours, with a mean (or average) of 3.9 hours. In terms of fuel usage, 

users burned 1 to 16 logs of fuel, with an average of 5.1 logs. 

We conducted additional analyses on fireplace users in order to determine 

any differences in the length of burn by the type of fuel used.12 It can be seen 

in Figure 20 that fireplace users who burned artificial logs enjoyed a fire for 

about the same amount of time; however, they used significantly less fuel 

than wood-burning fireplace users (an average of 1.3 logs versus 5.75 logs). 

Additional analyses were conducted on the low-income burners to see if the 

length of their burns were more or less than the general population. As 

shown in the next table, the average burn among low-income burners lasted 

3.3 hours and consumed 4.2 logs. While these figures are slightly lower than 

the results of the base study, the differences were not found to be statistically 

significant. 

FIGURE 20 – LENGTH OF BURN BY HOURS & LOAD

AMONG BASE STUDY DEVICE USERS WHO BURN WOOD OR ART. LOGS 

(EXCLUDING UNDECIDED RESPONSES)

DESCRIPTION AVERAGE #

OF HOURS RANGE AVERAGE #OF LOGS RANGE

Overall Burners 3.9 hours 1 – 15 hrs. 5.1 logs 1 – 16 logs 

Fireplace Wood Burners 3.9 hours 1 – 15 hrs. 5.7 logs 1 – 16 logs 

Fireplace Artificial Log Burners 3.0 hours 2 – 4 hrs. 1.3 logs 1 – 3 logs 

Low-Income Burners 3.3 hours 2 – 6 hrs. 4.2 logs 1 – 8 logs 

Reduced Usage

 20 Half of those who owned wood-burning devices (50%) said they burned 

less wood last winter compared to a typical winter. 

All owners (regardless of usage) were asked to evaluate last winter’s usage 

in terms of being more, less or the same as a typical winter. Nine percent of 

 

12 Fireplace users were analyzed because it was the most common wood-burning device used, which provide more data 

for our analyses. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 26 

wood-burning device owners were unable to decide if their wood-burning 

activity changed last winter. These results were excluded from the data and 

the percentages were recalculated and are shown in Figure 21. Half (50%) of 

the owners said they burned less this past winter, while 7% said they burned 

more. The remaining 43% felt last winter’s wood-burning activity was similar 

to a typical winter. 

FIGURE 21 – WOOD-BURNING ACTIVITY LAST WINTER 

COMPARED WITH A TYPICAL WINTER

(AMONG BASE STUDY USERS EXCLUDING UNDECIDED RESPONSES)

More

7%

Same

43%

Less

50%

When asked to compare last winter’s wood-burning with that of a typical 

year, activity among low-income owners was similar to that of the general 

population: 45% burned less, half (50%) burned the same and 5% said 

they burned more last winter than a typical year. 

 21 Among those who owned indoor devices, three in ten recalled 

occasions when they decided not to burn wood when they normally 

would have. 

Respondents were asked if there were occasions last winter when they 

normally would have burned wood, pellets, or manufactured logs but 

decided not to. About three in ten (29%) owners said yes, while the 

majority said no (66%) or were unsure (5%). Among low-income 

respondents results were similar: 33% said there had been days they 

decided not to burn wood. Sixty-three percent said there were none and 

4% were undecided. 

 22 About half who decided not to burn attributed their decision to air 

quality or environmental reasons (25%), health reasons (7%) or 

because they saw or heard a request not to burn (14%). 

Those who decided to not burn on certain occasions were asked, in an 

open-ended format, to explain the main reason why they chose to not 

burn wood, pellets or manufactured logs on those occasions. Verbatim 

responses were captured and then later categorized for quantitative 

analysis. Air quality and environmental concerns was the most common 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 27 

reason given, mentioned by 25% of these respondents. Seven percent 

mentioned health reason and 14% recalled hearing or seeing a request 

not to burn wood. Categorized reasons are shown in the following chart. 

Verbatim comments will be presented in the statistical report. 

FIGURE 22 – REASON FOR NOT BURNING WOOD 

ON CERTAIN OCCASIONS LAST WINTER

(AMONG BASE STUDY USERS WHO CHOSE NOT TO BURN

EXCLUDING UNDECIDED RESPONSES)

No fuel 

available

7% No need

10%

Not enough 

time to enjoy

9%

Too much 

trouble

16%

Other

12%

Saw/heard 

request not to 

burn

14%

Health 

concerns

7%

Air quality/ 

Environmental 

reasons

25%

Among the 15 low-income respondents that decided not to burn wood last 

winter on certain occasions, 2 respondents said it was for air quality reasons, 

1 person did it for health reasons, and 1 person saw or heard a request not to 

burn. Two claimed not have any fuel that day, 1 person said it was too 

inconvenient, and 3 people said they did not have a need. Five others gave 

responses that did not fit into the categories chosen. Once again, all 

verbatim responses will be presented in the statistical binder. 

 23 When asked specifically about air quality and health reasons, about half 

said they chose not to burn wood because of air quality (56%) and 

health reasons (46%). The median number of times that wood burns 

were avoided for air quality reasons was 4.5 and it was slightly higher (6 

times) for health reasons.

Respondents were then asked to quantify the number of times they had 

decided not to burn wood, pellets, or manufactured logs last winter for air 

quality reasons and for health reasons. About half said air quality (56%) and 

health reasons (46%) had been part of their decisions not to burn on certain 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 28 

occasions and the other half said they had not (0 times). Results among those 

who had made a choice not to burn wood for air quality and health reasons are 

shown in the following table (Figure 23). It can be seen that those who chose 

not to burn on certain days for air quality reasons refrained from doing so a 

median of 4.5 days. Those who did not burn wood for health reasons chose 

not to burn wood a median 6 times 

FIGURE 23 – FREQUENCY OF CHOOSING NOT TO BURN WOOD

FOR AIR QUALITY & HEALTH REASONS

(AMONG BASE STUDY USERS WHO CHOSE NOT TO BURN 

EXCLUDING UNDECIDED RESPONSES)

REASON RANGE MEDIAN 

Air Quality 1 – 50 times 4.5 times 

Health 1 – 30 times 6 times 

AIR QUALITY ISSUES

General Population Base Survey

 24 A third of Sacramento County respondents rated the quality of air in the 

area positively, but the majority (two-thirds) of respondents felt local air 

quality was only “poor” or “fair.” 

In the telephone interview, respondents were first asked to rate the overall quality 

of air in Sacramento County, using a four-point scale: poor, fair, good, or 

excellent. As can be seen in the next figure, only 5% rated the quality of air as 

“excellent,” and a further 28% rated it at “good,” indicating that a combined total 

of 33% were positive in their evaluations. The majority (67%) gave negative 

evaluations: nearly half (47%) rated the overall quality of air in the area as “fair” 

and a fifth (20%) said it was “poor.” This indicates that the majority of the general 

population recognizes and accepts that air pollution in the Sacramento area is a 

fact. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 29 

FIGURE 24 – OVERALL ASSESSMENT OF SACRAMENTO AREA AIR QUALITY

(BASE STUDY RESPONDENTS EXCLUDING UNDECIDED RESPONSES) 

Excellent

5%

Good

28%

Poor

20%

Fair

47%

67% Negative

33% Positive

 25 There is much room for educating the general public about the 

negative effects of residential wood-burning on wintertime air 

quality: approximately four in ten respondents felt wood-burning 

was not a serious cause of air pollution. That being said, the fact 

that nearly the same proportion of respondents said that traffic was 

a very serious contributor to air pollution is an indication of the 

success of public education programs in general, and possibly of 

the effectiveness of the long-running Sacramento region 

summertime Spare the Air public education campaign. 

Respondents were next asked to rate how serious they thought various 

causes of wintertime pollution were as contributors to air pollution in 

Sacramento County. Results, including responses of undecided/don’t 

know13, are presented in Figure 25. It can be seen, first of all, that traffic

was considered to be the most serious cause of wintertime air pollution: 

nearly four in ten respondents (38%) said it was a “very” serious problem. 

Only 18% of all respondents felt that industry was to blame and 15% felt 

that agricultural burning was responsible. Residential wood-burning

fireplaces were seen as the least serious causes of wintertime air 

pollution: only one in ten respondents (13%) rated wood-burning as 

“very” serious. 

This indicates that further public education about the causes of wintertime 

air pollution is warranted. It also attests to the ability of successful public 

education campaigns to influence public perceptions, insofar as the 

 

13 Typically, in attitudinal surveys, the percentage of undecided/don’t know responses is low (between 0% and 4%). We 

chose to present the percentage of undecided/don’t know responses in Figure 2 because three questions resulted in a 

relatively high percentages (7% and 10%) of respondents saying they did not know, a volunteered response rather than 

an actual response category. These indicate specific areas where more public education on the causes of 

wintertime air pollution (industry, agricultural burning, and residential wood-burning) could be beneficial. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 30 

seriousness of traffic in causing air pollution (regardless of the season) is 

now well-entrenched. In the Sacramento area, the summertime Spare 

the Air program has been in effect for 12 years and, although it is not the 

only source of education, it is now highly recognizable among the local 

population in general.14 

FIGURE 25 – SERIOUSNESS: SOURCE OF WINTERTIME AIR POLLUTION

(BASE STUDY RESPONDENTS INCLUDING UNDECIDED RESPONSES) 

13

15

18

38

38

38

45

44

42

37

30

14

7

10

7

4

0% 20% 40% 60% 80% 100%

Wood-Burning

Fireplaces

Agricultural

Burning

Industry

Traffic

Very serious Somewhat serious Not at all serious Undecided

Low-Income Group

 26 Low-income respondents evaluated the quality of air in the area 

similarly to the general population: the majority (69%) felt local air 

quality was only “poor” or “fair.” 

Results of the evaluation of air quality in the area by the low-income 

group of respondents are presented in Figure 26. It can be seen that 

results are very similar to those of the general population in Sacramento 

County: 31% rated the quality of air as “excellent” or “good,” and the 

majority (69%) gave negative evaluations. 

 

14 See: SMAQMD 2006 Air Quality & Transportation Telephone Tracking Survey, Aurora Research Group, January 2007: 

two thirds (66%) of all respondents were familiar with the summertime Spare the Air program. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 31 

FIGURE 26 – OVERALL ASSESSMENT OF SACRAMENTO AREA AIR QUALITY 

(LOW-INCOME RESPONDENTS ONLY EXCLUDING UNDECIDED RESPONSES) 

Excellent

5%

Good

26%

Poor

23%

Fair

46%

69% Negative

31% Positive

 27 Low-income respondents were also similar to the general population in 

terms of how they rated the seriousness of the various causes of winter air 

pollution: traffic was viewed as the most serious contributor and 

residential wood-burning the least serious. 

It can be seen in Figure 27 that the low-income group of respondents felt that 

traffic was the most serious cause of winter air pollution in Sacramento County: 

44% rated it as a “very” serious contributor. This was followed by industry (25% 

rating it “very” serious) and agricultural burning (19%). Only 16% of low-income 

respondents felt that residential wood-burning was a “very” serious contributor to 

wintertime air pollution – in fact, nearly half (47%) said it was “not at all” serious. 

FIGURE 27 – SERIOUSNESS: SOURCE OF WINTERTIME AIR POLLUTION

(LOW-INCOME ONLY RESPONDENTS INCLUDING UNDECIDED RESPONSES) 

16

19

25

44

27

38

37

38

47

35

32

16

10

7

6

2

0% 20% 40% 60% 80% 100%

Wood-Burning

Fireplaces

Agricultural

Burning

Industry

Traffic

Very serious Somewhat serious Not at all serious Undecided
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 32 

Other Group Differences

 28 Registered voters were significantly more likely to rate the quality of air in 

the region accurately (that is, negatively); as were those aged between 35 

and 54 years. The youngest respondents were the least accurate in their 

assessments. No other demographic characteristics emerged – evaluations 

of air quality did not depend on gender, ethnicity, education, income, etc. 

To see if there were any features that distinguished those respondents who gave 

negative evaluations of air quality from those who gave positive evaluations, 

results were dichotomized (percent “poor + fair” versus percent “good + 

excellent”), and a series of chi-square analyses was conducted. Variables 

included in the analyses included: age, income, education, gender, ethnicity, 

home ownership, type of dwelling, age of dwelling, number of people in 

household, access to the internet, voter registration, air alert subscription, and 

whether the household was a wood burner or not. 

Only two features showed significant differences: voter registration and age. 

Significantly more respondents who were registered to vote evaluated the quality 

of air negatively (71%) than those not registered to vote (55%). Younger 

respondents (aged between 18 and 34 years) were the least likely to assess the 

quality of air in the region negatively (52%) – those between the ages of 35 to 54 

were more accurate in their assessment (73% said the air quality was poor or 

fair), as were the oldest respondents (68% negative.) A public education 

program about the air quality in the region that could target the younger 

adult population in particular could be useful. 

Further chi-square analyses (52 in total (4 questions x 13 demographic features) 

were run on each of the causes of wintertime air pollution to see if there were 

distinguishing demographic features as to the seriousness of each cause. There 

were only 4 analyses that yielded significant differences: 

• females were significantly more likely than males to say that traffic

was a “very serious” cause of wintertime air pollution (46% vs. 32%), 

• males were significantly more likely than females to say that 

residential wood-burning fires were “not at all serious” causes of 

air pollution (55% vs. 36%), 

• renters were more likely than owners to say that industry was a “very 

serious” cause of air pollution (31% vs. 14%), and 

• renters were also more likely than owners to say that agricultural 

burning was a “very serious” cause (25% vs. 13%). 

In short, because there were so few demographic differences, a public 

education campaign about the sources and seriousness of wintertime air 

pollution that is designed to target residents of all descriptions in 

Sacramento County should be effective. However, if there were a way of 

educating males in particular about the pollution problems associated with 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 33 

wood-burning, there could be added benefits, as they demonstrated a 

significant information gap. 

AWARENESS OF SUMMERTIME SPARE THE AIR

General Population and Low-Income Groups

 29 Recognition of the summertime Spare the Air Program in 

Sacramento County is very high among the general population – 

nearly nine in ten respondents in the base study were familiar with 

the voluntary program. There is less familiarity among the lowincome group, but it is still relatively high at 80%. 

Respondents were next asked how familiar they were with the voluntary 

driving reduction program called Spare the Air during the summer 

months.15 Figure 28 shows the results from both the general population 

base study and the low-income group of respondents. It can be seen, 

first of all, that among the general population in Sacramento County, the 

summertime program is highly recognizable: 63% of respondents said 

they were “very” familiar with the program and an additional 26% said 

they were “somewhat” familiar with it, indicating that a combined total of 

89% of all respondents were familiar with summertime Spare The Air. (It 

is interesting to note that the 63% of respondents who were “very” familiar 

with the program is identical to the level of general awareness of Spare 

The Air among Sacramento County residents during the summer of 

2006.16) Although fewer than half of the low-income respondents were 

“very” familiar with Spare The Air (47%), an additional 33% said they 

were “somewhat” familiar with the program for a combined total of 80% 

aware. This is a significantly lower percentage than in the general 

population, but it is still quite high. 

 

15 The exact wording of the question was: “During the summer months, that is, from May through October, you may have 

heard about a voluntary driving reduction program called Spare The Air, which is aimed at reducing the amount of 

ozone in the air caused by vehicles during particularly hot days with poor air quality. Does this sound not at all familiar, 

somewhat familiar, or very familiar to you?” 16 See “SMAQMD Final Report – Awareness of the 2006 Spare The Air Campaign”, Naomi E. Holobow, November 2006. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 34 

FIGURE 28 – FAMILIARITY WITH SUMMERTIME SPARE THE AIR 

DRIVING REDUCTION PROGRAM

(BASE STUDY VS. LOW-INCOME GROUPS EXCLUDING UNDECIDED RESPONSES)

63%

26%

33%

20%

47%

11%

0%

20%

40%

60%

80%

100%

Base Study Low-Income Only

Very familiar Somewhat familiar Not at all familiar

*

* indicates a statistically significant difference

Other Group Differences

 30 Recognition of the summertime Spare the Air Program in Sacramento 

County varied by a few demographic features (age, income, ethnicity, 

education, Internet access and home ownership). 

Further chi-square analyses were conducted to determine if there were any 

statistically significant differences in terms of demographic characteristics 

between respondents who were familiar with the summertime Spare The Air 

program and those who were not. Results can be described as follows: 

Respondents familiar (both somewhat and very) with the summertime 

Spare The Air program were significantly more likely to: 

- be homeowners (94% vs. renters, 75%); 

- be registered voters (93% vs. not registered, 71%); 

- have access to the Internet (93% vs. no access, 78%); 

- have at least a college education (96% vs. less than college, 83%); 

- be Caucasian (94% vs. other ethnicities, 75%) 

- have household incomes of $50,000 or more (92% vs. less than 

$50,000, 84%); and 

- be older than 35 years of age (93% vs. 18 to 34 years, 71%). 

No other significant differences were found – burners were just as 

familiar with Spare The Air as non-burners, males as familiar as 

females, etc. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 35 

KNOWLEDGE OF PARTICULATE MATTER

General Population and Low-Income Groups

 31 Only 16% of all respondents in the general population said they were “very 

knowledgeable” about particulate matter pollution, but an additional 61% 

felt “somewhat knowledgeable.” Low-income respondents claimed 

significantly less knowledge about PM pollution. 

Next, respondents were asked to rate how knowledgeable they 

considered themselves to be about particulate matter or particle 

pollution. Results from the general population base study as well as the 

low-income group are presented in the next figure. It can be seen, first 

of all, that few respondents in either group claim to be “very” 

knowledgeable about PM (16% in the general population and 12% in 

the low-income group), indicating that there is a good opportunity 

for a public information program to educate its residents about PM 

pollution. Secondly, although a substantial proportion in both groups 

claims to be somewhat knowledgeable, the fact that 23% and 33% 

claim no knowledge at all about PM pollution is an indication that the 

causes of wintertime air pollution need to be put more in the public eye. 

FIGURE 29 – LEVEL OF KNOWLEDGE ABOUT 

PARTICULATE MATTER OR PARTICLE POLLUTION: 

(BASE STUDY VS. LOW-INCOME GROUPS EXCLUDING UNDECIDED RESPONSES) 

* indicates a statistically significant difference

16%

61% 55%

33%

12%

23%

0%

20%

40%

60%

80%

100%

Base Study Low-Income Only

Very knowledgeable Somewhat knowledgeable Not at all knowledgeable

*
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 36 

Burners vs. Non-Burners

 32 Wood burners were just as knowledgeable (or not) about particulate matter 

pollution as non-wood burners. 

The self-reported level of knowledge about PM pollution from burners and nonburners in the general population base study are presented in the next figure. 

There were no significant differences between the two groups of respondents. 

Among burners, 20% said they were “not at all” knowledgeable. Two thirds 

(66%) claimed to be “somewhat” knowledgeable and only 14% claimed to be 

“very” knowledgeable about PM pollution. 

One possible interpretation of the results could be to speculate that because only 

14% of burners claimed to be “very” knowledgeable (and thus were willfully 

ignoring what they “knew” when they decided to burn wood this past winter 

anyway), the majority of burners (the remaining 86%) were not as knowledgeable 

and could therefore benefit from learning more about the effects of wood-burning 

on air pollution. 

FIGURE 30 – LEVEL OF KNOWLEDGE ABOUT 

PARTICULATE MATTER OR PARTICLE POLLUTION: 

(BURNERS VS. NON-BURNERS EXCLUDING UNDECIDED RESPONSES) 

14%

66% 59%

24%

17%

20%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Burners Non-burners

Very knowledgeable Somewhat knowledgeable

Not at all knowledgeable

Other Group Differences

 33 More males than females claimed to be “very” knowledgeable about PM 

pollution. A higher percentage of respondents who claimed the least

knowledge were: poorer, less well educated, not registered to vote, and 

lacking Internet access than their counterparts. 

Further chi square analyses revealed that: 

- more males said they were “very” knowledgeable compared to females 

(21% vs. females, 11%); 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 37 

- those not registered to vote were more likely to say they were “not at 

all” knowledgeable about PM pollution (41% vs. registered, 18%); 

- less educated respondents were more likely to say they were “not at 

all” knowledgeable (31% vs. college degree or higher, 12%); 

- more of those without Internet access said they were “not at all 

knowledgeable” (36% vs. have Internet access, 18%); and 

- more of those with household incomes of less than $50,000 were “not 

at all” knowledgeable (31% vs. $50,000 or more, 14%). 

AWARENESS OF WINTERTIME NO-BURN REQUESTS 

 34 Awareness of the requests not to burn wood during the winter of 2006/2007 

was the same across the general population, low-income respondents and 

burners as well as non-burners. It was fairly high, given that there was no 

paid advertising of the requests this past winter: 59% of the respondents in 

the general population base survey and 57% of those in the low-income 

group said they heard the wintertime no burn requests. (Some of this could 

possibly be due to a carry-over of awareness from the summertime Spare 

The Air program.) Levels of awareness should increase when the full 

residential no-burn public education program is launched with full media 

buy. 

Although there was no paid advertising to announce the nights throughout the 

2006/2007 winter when particulate matter pollution was forecast to reach 127 on 

the Air Quality Index (AQI) -- the “unhealthy for sensitive groups“ level -- there were 

several news stories on both television and radio as well as in the Sacramento Bee 

weather page that asked residents in the Sacramento area to refrain from using 

their wood-burning fireplaces and outdoor fire pits on certain nights. In addition, Air 

Alerts for Spare the Air nights were issued to those approximately 3,050 

Sacramento County residents17 who had registered to receive them for the summer 

Spare The Air season. Survey respondents were asked: 

“During this past winter, did you hear, read, or see any news stories, advertisements, 

or public service announcements about particulate matter pollution or poor air quality, 

and requests not to use wood-burning fireplaces and outdoor fire pits?” 

Excluding the respondents who were undecided or did not know, results 

indicated that 59% (+ / - 4.9%) of all respondents in the general population base 

survey and about the same percentage (57%) of those in the low-income group 

were aware of the requests not to burn during the past winter. Considering that 

there was no media buy this past winter, these are quite high levels of 

awareness. The next graph shows these two groups, and in addition plots the 

level of awareness among burners and non-burners in the base study. There 

were no significant differences among any of the groups. 

 

17 Per an e-mail from Lori Kobza, of the Communications Office of Sacramento Metropolitan Air Quality Management District, there

are a total of 5,512 Air Alert subscribers, 55% of which live in Sacramento County (3048 subscribers).
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 38 

FIGURE 31 – PERCENT AWARE OF REQUEST NOT TO BURN THIS PAST WINTER 

(BASE STUDY, LOW-INCOME GROUPS, BURNERS AND 

NON-BURNERS EXCLUDING UNDECIDED RESPONSES) 

59% 57% 58% 59%

0%

20%

40%

60%

80%

100%

Base Study LowIncome

Only

Burners NonBurners

Another factor to consider when assessing levels of awareness of a public 

education campaign is that some survey respondents might have a tendency to 

give the most socially-acceptable responses (that is, the assessed level of 

awareness could be an overestimate). The difficulty is to predict how many 

respondents this could represent. The evaluation of the summertime Spare The 

Air campaign18 has always included a Control group of respondents, that is, 

residents who are interviewed about non-Spare the Air days but are asked 

whether they recently heard a Spare The Air advisory asking them not to drive. 

The percent of respondents who say “yes” (and were therefore wrong) are then 

used as a correction factor and subtracted from results when emission reduction 

estimates are conducted. Our experience with the 2006 summer evaluation 

showed that the percentage of Control day respondents in Sacramento County 

who erroneously thought they heard a STA advisory ranged between 4% and 

24%, depending on the specific wording of the question. It is quite possible that 

the 59% of respondents who said they heard the wintertime no-burn requests is 

an overestimate, but without control-day interviewing, we cannot measure this 

extent of this effect. 

 35 Older respondents were more likely to have seen or heard the 

requests not to burn than younger respondents. 

Of the thirteen chi-square analyses, only one significant difference emerged: age 

was the only demographic feature that distinguished those who heard or saw the 

wintertime request not to use wood-burning fireplaces and outdoor fire pits. Of 

 

18 Aurora Research Group has conducted annual evaluations of the summertime Spare The Air campaign in the 

Sacramento Region for many years. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 39 

those respondents 55 years of age and older, 69% were aware, versus 53% of 

those aged between 35 – 54 years. The youngest group (aged between 18 and 

34 years) was the least likely to have seen the announcements: only 46% of 

these respondents were aware. 

WINTER 2006/2007 ACTUAL COMPLIANCE WITH VOLUNTARY 

NO-BURN REQUESTS 

General Population and Low-Income Groups

 36 Among those who were aware of the requests not to burn during the 

past winter, only 34% of the general population base survey 

respondents, and 41% of low-income respondents actually complied 

and voluntarily reduced the number of fires they burned. 

Respondents who indicated they had seen or heard requests not to use 

wood-burning fireplaces (59% of the general population of respondents and 

57% of the low-income group) were then asked if they actually reduced the 

number of fires they burned during the winter because of the requests. 

Results, presented in the next chart, indicate that voluntary compliance was 

quite low. In the general population of respondents in Sacramento County, 

only about a third (34%) of these respondents reduced the number of fires 

burned. In the low-income group, 41% complied, a percentage which is not 

statistically significantly different from the general population results. 

FIGURE 32 – COMPLIANCE WITH VOLUNTARY REQUEST NOT TO BURN 

(AMONG THOSE WHO HEARD THE NO BURN REQUESTS: 

GENERAL POPULATION BASE STUDY VS. LOW-INCOME GROUPS) 

34%

59%

41%

64%

0%

20%

40%

60%

80%

100%

Base Study Low Income Only

Compliance Non-Compliance

No statistically significant difference between the groups.
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 40 

Burners Only

 37 Actual compliance with voluntary no-burn messages was only 

approximately 50-50 among burners: of those who heard the noburn requests, 46% complied and reduced their number of fires. In 

other words, nearly half of the Sacramento County residents who 

burned wood reduced the number of fires they burned this past 

winter, specifically because they heard the requests – but just over 

half chose not to refrain from burning. 

We next looked at just the subpopulation of those who were classified as 

“burners” in the general population base study, that is, those who owned 

wood or pellet burning devices (either indoors or outdoors), and burned 

wood, pellets, or manufactured logs at least once this past winter. It has 

already been reported above that 58% of these respondents were aware of 

the requests not to burn wood. The next chart shows the compliance 

results among those who were aware of the announcements. It can be seen 

that nearly half, 46%, actually reduced the number of fires they burned last 

winter because they heard the requests. That being said, it also means that 

just over half of those who heard the requests actually did not reduce the 

number of fires they burned. 

FIGURE 33 – COMPLIANCE WITH VOLUNTARY REQUEST NOT TO BURN 

(AMONG THOSE WHO HEARD THE NO BURN REQUESTS: ONLY BURNERS) 

46%

54%

0%

20%

40%

60%

80%

100%

Only Burners

Compliance Non-Compliance

 38 Among burners, there were no significant demographic features that 

could be used to characterize voluntary compliers from non-compliers. 

In order to see whether there were any demographic features that could 

distinguish burners who complied with the voluntary no-burn notices from those 

who did not comply, a series of chi-square analyses were run on just the 

subpopulation of burners. Results indicated that there were no significant 

identifiers that could be used to characterize compliers from non-compliers: 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 41 

not gender, age, income, ethnicity, education, home ownership, age of 

neighborhood, or Internet access were significant. In other words, burners who 

complied with the voluntary measures had the same demographic profile as 

burners who did not comply. 

 39 A possible explanation is that those burners who did not comply do not 

believe that residential wood-burning is a serious cause of wintertime air 

pollution or that there is a problem with the overall quality of air in the 

area. 

In an effort to try and understand why some burners actually complied with the 

no-burn request they heard while others did not, we re-examined burners’ 

responses to the questions of overall air quality in the area and how they rated 

the seriousness of air pollution caused by residential wood-burning. Results, 

presented in the next figure, indicated that those who complied and reduced the 

number of fires this past winter were significantly more likely to rate the quality of 

air in the region negatively (72% gave ratings of “fair” or “poor”) and to say that 

residential wood-burning is a serious cause of air pollution (66% said “somewhat” 

or “very”) than were non-compliers (46% and 40%, respectively). In other 

words, there is an information credibility gap – and therefore an 

opportunity for a public education program to correct this disbelief. 

FIGURE 34 – ACTUAL 2007 COMPLIANCE BY RATINGS OF AIR QUALITY 

& SERIOUSNESS OF RESIDENTIAL WOOD-BURNING: 

(BURNERS ONLY) 

72%

66%

40%

46%

0% 20% 40% 60% 80% 100%

Complied

Did not

comply

Negative Ratings of Air Quality Wood Burning is a serious cause

SUPPORT FOR VOLUNTARY NO-BURN RULE AND HYPOTHETICAL 

COMPLIANCE 

General Population

 40 The vast majority of all respondents approved of a voluntary no-burn 

rule (85%) and said they would comply with it (93%) – a strong 

endorsement for a voluntary measure. However, these figures include 

respondents who do not own wood-burning devices or burn wood. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 42 

All respondents were asked whether they generally approved or 

disapproved of asking residents to voluntarily suspend non-essential 

woodstove and fireplace burning while there is poor air quality in the area 

where they live. They were then asked how likely they would be to comply 

if such a request were made.19 Results from the general population base 

study are presented in Figure 35. It can be seen, first of all, that the 

majority of all respondents approved of a voluntary no-burn rule: 59% 

“strongly” approved and a further 26% “somewhat” approved. Only 15% of 

all respondents disapproved – either “somewhat” (7%) or “strongly” (8%). 

Secondly, it can be seen that the vast majority of respondents in the 

general population claim they would comply with a voluntary request: 

nearly three quarters (74%) said they would be “very likely” to comply 

(significantly higher than the 59% who strongly approved), and a further 

19% said they would be “somewhat likely” to comply. Although 

representative of the attitudes of the entire population of residents in 

Sacramento County in general, these figures include respondents who do 

not own wood-burning devices or burn wood and who therefore would have 

no difficulty approving and complying with any voluntary measure. 

FIGURE 35 – SUPPORT FOR VOLUNTARY NO-BURN RULE 

AND LIKELIHOOD TO COMPLY

(BASE STUDY GROUP EXCLUDING UNDECIDED RESPONSES)

59%

26%

19%

74%

3%

7%

8% 4%

0%

20%

40%

60%

80%

100%

Approval of Voluntary

Rule

Likelihood to Comply

Strongly approve/Very Likely Somewhat approve/Somewhat likely

Somewhat disapprove/Somewhat unlikely Strongly disapprove/Not at all likely

85% 

approval

93% 

compliance

Figure 36 shows the proportion of respondents who said they would be likely 

to comply with a voluntary no-burn rule according to whether or not they 

approve of a voluntary program. It can be seen that among the general 

 

19 The exact wording of the latter question was: “And when residents are asked to voluntarily suspend non-essential 

woodstove and fireplace burning because of poor air quality, how likely are you to comply? Would you would you say 

not at all likely, somewhat unlikely, somewhat likely or very likely? 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 43 

population study of respondents, 97% of those who said they “somewhat” or 

“strongly” approved of a voluntary no-burn rule also said they would be 

“somewhat” or “likely” to comply with it. Among those who did not approve of 

the voluntary measure (only 15% of the general population), hypothetical 

compliance was significantly lower, at 65%. 

FIGURE 36– LIKELIHOOD TO COMPLY WITH VOLUNTARY NO-BURN RULE 

BY LEVEL OF APPROVAL

(GENERAL POPULATION BASE STUDY)

65%

97%

0% 20% 40% 60% 80% 100%

Disapprove

(Somewhat +

Strongly)

Approve

(Somewhat +

Strongly)

Likelihood to Comply with Voluntary Rule (Somewhat + Very)

* indicates a statistically significant difference between the groups 

Consistency between Actual Compliance Behavior and Hypothetical Compliance 

 41 Further analysis revealed a discrepancy between actual compliance 

behavior and hypothetical compliance (what respondents said they 

would do) – the largest discrepancy occurring in the group of 

respondents who did not comply with the request not to burn but said 

they would. Those who did comply and said they would be likely to 

comply were far more consistent. 

One final analysis of the general population base study compared actual 

compliance behavior with what respondents hypothetically said they would 

do. Figure 37 indicates that the largest discrepancy between actual

compliance behavior and hypothetical compliance occurred in the group who 

did not comply with the request not to burn (even though they said they had 

heard the requests not to burn): 92% of them said they would be likely (either 

“somewhat” or “very”) to comply with a voluntary no-burn rule -- only 8% (10 

respondents) of those who actually did not reduce the number of fires they 

burned (125 respondents in total) said they would not comply with a voluntary 

rule. There was much more consistency among the (albeit) smaller group of 

70 respondents who actually complied by reducing the number of fires they 

burned in the winter of 2006/2007: all but one of them (99%) said they would 

be likely to comply with a voluntary no-burn rule and did. 

*
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 44 

FIGURE 37 – ACTUAL 2007 COMPLIANCE BEHAVIOR 

BY HYPOTHETICAL BEHAVIOR: 

(RESPONDENTS IN BASE STUDY GROUP WHO HEARD REQUEST NOT TO BURN

EXCLUDING UNDECIDED RESPONSES) 

99%

92%

0% 20% 40% 60% 80% 100%

Complied

Did not

comply

Would be "Somewhat" or "Very" Likely to Comply with Voluntary Rule

Low-Income Group

 42 Although support was slightly lower among the low-income group 

than among the general population of respondents, the majority (77%) 

approved of a voluntary no-burn measure and 86% said they would 

comply with one. 

Results of approval for and likelihood to comply with a voluntary no-burn rule 

among just the low-income group of respondents are presented in the next 

figure. It can be seen that 77% of these respondents approved of a voluntary 

measure and a combined total of 86% said they would comply with it. 

FIGURE 38 – SUPPORT FOR VOLUNTARY NO-BURN RULE A

ND LIKELIHOOD TO COMPLY

(LOW-INCOME GROUP EXCLUDING UNDECIDED RESPONSES)

52%

25%

24%

11%

6%

62%

12% 8%

0%

20%

40%

60%

80%

100%

Approval of Voluntary Rule Likelihood to Comply

Strongly approve/Very Likely Somewhat approve/Somewhat likely

Somewhat disapprove/Somewhat unlikely Strongly disapprove/Not at all likely

77% 

approval

86% 

compliance
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 45 

Burners vs. Non-Burners

 43 Perhaps the best reflection of levels of acceptance of a voluntary 

measure to request that residents not burn wood is between those who 

burned wood this year versus non-burners. Results indicated that the 

majority (83%) of those who burned wood this past winter also 

approved of a voluntary no-burn rule. The highest approval was among 

respondents who owned wood-burning devices but did not use them 

(93%). In terms of compliance, there were no differences – the vast 

majority (over 90%) in all groups said they would comply. 

For the purpose of this analysis, the non-burner group was separated into 

two: those who actually owned wood-burning devices but never used them, 

and those who did not own wood-burning devices. Results of the approval for 

and the likelihood of complying with a voluntary no-burn rule among three 

groups of respondents (burners, owners but not burners, and non-owners) 

are shown in Figure 39. 

FIGURE 39-SUPPORT FOR VOLUNTARY NO-BURN RULE AND LIKELIHOOD TO COMPLY 

(NON-OWNERS, OWNERS BUT NOT USERS, & BURNERS, 

EXCLUDING UNDECIDED RESPONSES)

57% 58%

78% 81%

65%

26%

28%

25%

15% 15%

26%

66%

0%

20%

40%

60%

80%

100%

NonOwnerOwners

but Not

Burners

Burners NonOwnerOwners

but Not

Burners

Burners

Strongly approve/Very Likely Somewhat approve/Somewhat likely

83% 83%

93% 93% 96% 91%

It is interesting to note, first of all, that support and hypothetical compliance 

among those respondents who do not own wood-burning devices is not 

100% -- (17% did not approve and 7% would not comply), meaning that 

some of the residents who cannot burn wood, would, if they could. 

Support for Voluntary Rule Likelihood to Comply 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 46 

Secondly, although levels of approval and levels of hypothetical compliance 

within each group are not statistically different from one another, the very 

fact that there are differences at all indicates that there is a small number of 

individuals in each group who disapprove of the rule but say they would 

comply. Similarly there is a small number of individuals who approve of the 

rule but say they would not comply. In attitudinal survey research this is not 

an uncommon finding. 

Closer examination of a couple of the discrepancies within just the burner

group revealed that among the 17% of respondents who did not support a 

voluntary no-burn rule (22 individuals said they “somewhat” or “strongly” 

disapproved), half of them said they would comply, and in fact 9 individuals 

heard the requests not to burn this past winter and of these, 2 respondents 

reduced the number of fires they burned. Among the 9% of burners (or 12 

individuals) who said they would not comply with a voluntary reduction, 

nearly half (5 individuals, or 42%) said they approved of a voluntary rule, 7 

of them (or 58%) heard the no-burn requests this past winter, and 1 

respondent actually reduced the number of fires because of the request. In 

other words, there were gaps between some respondents’ attitudes, what 

they said they would do, and how they actually behaved. Fortunately, for 

the most part, these discrepancies were apparent within only a relatively 

small number of respondents. 

SUPPORT FOR MANDATORY NO-BURN RULE 

General Population

 44 Although approval was significantly lower (than for a voluntary no-burn 

rule), the majority of respondents (71%) nevertheless approved a 

mandatory no-burn rule. 

All respondents were read a description20 of a mandatory no-burn rule 

which some counties have already adopted, and were asked whether they 

approved or disapproved of it. Results, presented in the next figure, indicate 

that 46% “strongly” approved of a mandatory measure, and a further 25% 

of all respondents “somewhat” approved of it, for a combined approval 

rating of 71%. This is significantly lower than the 85% who approved of a 

voluntary rule, but still indicates that the majority of the general public would 

approve of a mandatory no-burn rule. That being said, there is also a fairly 

large polarized group of 20% of all respondents who were “strongly” 

opposed to mandatory legislation who could be quite vocal in their 

opposition. 

 

20 “Some counties in California have already adopted mandatory NO-Burn regulations for specific days during the winter 

when particulate matter is predicted to be unhealthy. A local agency is also considering adopting a mandatory No-Burn 

rule. However, gas fireplaces and residents whose only source of heating is wood-burning would be exempt from the 

regulation.” 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 47 

FIGURE 40 – SUPPORT FOR MANDATORY NO-BURN RULE 

(BASE STUDY GROUP EXCLUDING UNDECIDED RESPONSES)

46%

25%

9%

20%

0%

20%

40%

60%

80%

100%

Approval of Mandatory Rule

Strongly approve Somewhat approve

Somewhat disapprove Strongly disapprove

71% 

approval

Main Reasons For Strongly Approving a Mandatory No-Burn Rule 

 45 Those who “strongly” approved of a mandatory no-burn rule did so mainly 

because of air quality and health concerns. 

All respondents were then asked to give their main reasons for approving or 

disapproving of a mandatory measure. All responses were content-analyzed and 

categorized and the full verbatim transcripts will be presented in the statistical 

binder. Among the 46% of respondent who “strongly” approved, it can be seen in 

the next figure that the main reasons for approving a mandatory no-burn 

regulation were for air quality reasons and health concerns. 

FIGURE 41 – MAIN REASONS FOR “STRONGLY APPROVING” A MANDATORY NO-BURN RULE 

(GENERAL POPULATION BASE STUDY) 

10%

2%

3%

4%

7%

33%

40%

1%

0% 20% 40% 60% 80% 100%

Other

I don't burn wood

People can use other means to heat their

houses

People need helpt to comply with program

If it's their only way to heat they should be

exempt 

Environmental concerns

Health concerns

Air quality concerns
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 48 

To give a sense of the actual words respondents used, a few examples are 

included. First, some of the comments having to do with air quality 

concerns were: 

− “Anything that is better for the air is good. 

− Because of the smog and everything in the air. I think we need to have 

cleaner air than we do now. 

− Because we have to reduce air pollution. 

− Because we can't ignore the air quality in the valley, it continues to get 

worse and the things we know are contributing to the air quality should be 

addressed such as wood-burning fireplaces and fire pits. 

− Because wood-burning worsens our atmosphere and burning wood is NOT 

necessary. 

− Because you have to stop the pollution and if you stop it will help. 

− I am pro nature. Like to improve the air quality. 

− I feel that everyone has an opportunity to help improve our air quality 

therefore any individual effort such as not burning a fireplace that is not 

needed for heat should not be. 

− I like to breathe clean air, and I spend quite a bit of time outside, it is very 

evident when the air quality in Sacramento is poor. I am particularly 

irritated when I feel that people burn trash in their fireplaces. 

− I think the air quality is bad, and we need to look at what is making the air 

quality bad. If the only way to increase the awareness is to have this 

become mandatory, then they should do it. 

− It would help clean up the air. 

− I think that it is important to have good air quality and some days I don't 

want to and don't go outside due to the poor air quality. 

− If it's going to reduce particulate matter in the air and make it better I don't 

see why we can't all work together on it. 

− To reduce pollution. There is a need for it. 

− Just the air quality -- it's not getting better if we aren't helping to get it 

better. If you don't need a fireplace for your primary source of heat it is a 

luxury that is damaging the rest of us. 

− That there's probably too much air particulate -and it needs to be stopped. 

− The less you burn, the less air pollution there will be. 

− The poor quality of air to breathe and things can only get worse. We've 

come to a point where we have to do something as stringent as this. 

− To keep the pollution and particulate matter out of the air. 

− We have to get pollution under control and I think voluntary programs won't 

work. 

− Whatever we have to do for air quality is what we need to do unless you 

are an exception. 

− We need to do something about all the pollution.” 

A few of the supportive comments of mandatory legislation that had to do with 

health concerns included: 

− “Because I have asthma. 

− Because I don't have any health issues and it wouldn't be fair of me not to 

think of people who do have those health problems. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 49 

− Because my father has 25% lung capacity and he is on oxygen 100% of the 

time because of his emphysema. We monitor the air quality reports and he 

has to stay in on days when the air quality is bad. 

− For the purpose of everybody breathing, I would agree that they should 

regulate it. That is why we have rules, I have elderly parents and I know that 

My mother-in-law has lung problems. 

− I'm thinking of the children. And we want a healthy population. Without 

breathing this stuff in. 

− I go outside and smell smoke, and I'm prone to lung problems, so I approve. 

− I have two daughters who are asthmatic, and I think that we should do what is 

best for everybody. 

− I only have one set of lungs and pair of eyes, I have allergies and pollution 

irritates every one of these things. 

− I think everybody should be able to breath. I think wood-burning is a luxury 

and if we can't afford the luxury because of the damage it causes than giving 

up wood-burning stoves and fireplaces is a small thing to ask. 

− I understand the health risks to this. I'm healthy and I know that there are many 

people who are not. So just to have compassion for others. 

− It's not good for the people that have a problem breathing. 

− My wife died of pulmonary problems. 

− Not only from my own asthma, but as a teacher I see many children with 

breathing problems. 

− Well because of the whole particulate matter pollution and there are a lot kids 

now getting asthma from the wood-burning. 

− Well personally I believe there is quite a bit of particulate matter in the air. I 

personally have an allergy or sinus related issues and it basically only happens 

since I moved here and I attribute it to the particulate matter in the air. 

− When I go out and wood-burning stoves are on and fireplaces are going it 

really does get to me in my lungs.” 

Main Reasons For Strongly Disapproving of a Mandatory No-Burn Rule 

 46 The 20% who “strongly” disapproved of a mandatory no-burn rule did so 

mainly because they don’t want their freedom limited by government 

regulation. 

The next figure indicates that the most frequently given reason for 

“strongly” disapproving a mandatory no-burn rule is that respondents do 

not like government regulation (54% of responses), followed by a belief 

that wood smoke is not such a problem (21%). 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 50 

FIGURE 42 – MAIN REASONS FOR “STRONGLY DISAPPROVING”

A MANDATORY NO-BURN RULE 

(GENERAL POPULATION BASE STUDY)

7%

6%

12%

21%

54%

0% 20% 40% 60% 80% 100%

Other

Just don't like it

May be the only or cheapest

source of heat

Don't believe woodsmoke is

such a problem

Don't like government

regulation

A few examples of respondents who did not like government regulation include: 

− “A person should be able to do what he wants to do in his house. 

− Government intrusion. In general I don't see the Government needing to be 

involved in a matter like this that's not so serious. 

− I'm just a little bit tired of busybodies trying to tell people how to live. 

− I believe that people should be able to warm their houses however they like. 

− I don't like being nailed into something that can be turned out to bite me in 

the ass. What sounds good on Monday doesn't always sound so good on 

Tuesday. 

− I don't like the government telling me what I "HAVE" to do in my personal life. 

It is just too much. I believe in the volunteer method. 

− I don't think the government should tell you when and what you can burn. 

− I don’t think we should be forced to comply. 

− I still think there should still be a bit of a choice in there. It's that "No you 

can't that bothers me". 

− I think governments are getting too much control. 

− It's a political sham the majority of people have a fireplace you can burn 

wood in, now we are told when we can burn and when we can't. This is what 

happens when you have a state controlled by Democrats. 

− It is up to the people themselves, not have a regulatory commission dictate to 

them. 

− I don't think they should regulate that. 

− You have people out there who have wood-burning fireplaces and they 

should be allowed to use their property. If they want to adopt new building 

regulations for wood-burning but pre-existing homes with wood fireplaces 

should be exempt. 

− I don't want the government regulating my life. 

− I don’t like any more regulation. I think it should be voluntary. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 51 

− They are infringing on people's rights. 

− Whatever people want to do is their own business. 

− They have no right telling me I can't have a fire. If I'm trying to save money 

on my monthly bill you bet I'm going to light a fire. I don't see anybody 

paying my bills. 

And finally, a few examples from respondents who do not believe wood 

smoke is a problem: 

− “Because I believe the so called threat is over-exaggerated and not 

substantiated. 

− I don't see people driving less, which is the real cause of pollution. 

− I don't think that it is a major cause of air pollution. It's a very minimal cause, 

and for the few times I burn it's a negligible cause. 

− I haven't seen enough information to tell me that this is the primary cause of 

the high particulate matter in the winter. Equally, I don't see enough 

evidence that there are restrictions on industry and vehicles. 

− There are not enough wood-burning fireplaces to really make a difference. 

When they allow the farmers to burn thousands and thousands of acres of 

rice fields, and put tons of particulate matter into the air, my fireplace seems 

inconsequential. 

− We say burning furnaces causes more pollution than fireplaces. 

− There are other areas be focused on, such as auto exhaust and municipal 

diesel buses. 

− People need to conserve energy. There are other sources to be concerned 

about.’” 

Low-Income Group

 47 Approval of a mandatory no-burn rule was about the same in the lowincome group as in the general population: 73% either somewhat or 

strongly approved a mandatory measure. 

The levels of approval of a mandatory no-burn measure among low-income 

respondents are presented in Figure 43. Results were generally the same as 

those obtained in the base study, with approximately 73% of low-income 

respondents approving mandatory measures and the remaining 27% 

disapproving. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 52 

FIGURE 43 – SUPPORT FOR MANDATORY NO-BURN RULE 

(LOW-INCOME GROUP EXCLUDING UNDECIDED RESPONSES)

44%

29%

7%

20%

0%

20%

40%

60%

80%

100%

Approval of Mandatory Rule

Strongly approve Somewhat approve

Somewhat disapprove Strongly disapprove

73% 

approval

Burners vs. Non-Burners

 48 Not surprisingly, approval of a mandatory no-burn rule was 

significantly lower among burners (56%) than non-burners (78%) in 

the general population. 

Figure 44 shows the levels of approval of a mandatory no-burn measure 

among burners and compares them with non-burners in the general 

population. Results indicated that burners were significantly less likely 

than non-burners to approve of mandatory measures – only 33% 

“strongly” approved and another 23 “somewhat” approved, for a 

combined total of 56% approval. This contrasts with 78% of non-burners 

who approved of a mandatory no-burn rule. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 53 

FIGURE 44 – SUPPORT FOR MANDATORY NO-BURN RULE 

(BURNERS VS. NON-BURNERS GROUP EXCLUDING UNDECIDED RESPONSES)

33%

23%

13% 25%

7%

53%

14%

31%

0%

20%

40%

60%

80%

100%

Burners Non-Burners

Strongly approve Somewhat approve

Somewhat disapprove Strongly disapprove

78% 

approval

56% 

approval

* indicates a statistically significant difference between the groups 

Other Group Differences

 49 There were no other demographic features (than burners vs. nonburners) that distinguished respondents who approved mandatory 

no-burn measures from those who did not. 

The series of 13 chi-square analyses which were run to determine 

whether certain demographic features distinguished those who approved 

of a mandatory no-burn rule from those who disapproved did not yield any 

significant differences – the same proportion of males as females both 

approved and disapproved; as did respondents in older neighborhoods as 

well as newer neighborhoods; owners as well as renters; wealthier 

households as well as poorer households; etc. 

LIKELIHOOD TO COMPLY WITH A MANDATORY NO-BURN RULE 

Owners of Wood-burning Devices

 50 Among those in the general population of Sacramento County 

respondents who owned wood-burning devices (whether or not they 

used them), over three-quarters (78%) said they would likely comply 

with a mandatory no-burn rule. 

* 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 54 

In order to get as accurate a description as possible about projected 

levels of the likelihood of compliance with mandatory wintertime no-burn 

measures, only those respondents who owned wood-burning devices and 

thus had the capability of burning wood (whether or not they actually used 

them during the past winter) were asked to speculate on how likely they 

would be to comply with a mandatory no-burn rule if it were implemented 

in the Sacramento area. Just over half of the general population was 

owners (this included the 134 respondents who burned wood and the 82 

respondents who owned, but did not burn wood this past winter) and just 

under half were non-owners of wood-burning devices. Of the 54% of 

owners (216 in total), 60% said they would be “very” likely to comply with 

any mandatory no-burn regulation, and a further 18% said they would be 

“somewhat” likely to comply. In other words, among the group of 

respondents who have the capability to burn wood, 78% said they would 

comply with a mandatory no-burn measure. 

FIGURE 45 – LIKELIHOOD TO COMPLY WITH MANDATORY NO-BURN RULE 

(OWNERS OF WOOD-BURNING DEVICES ONLY EXCLUDING UNDECIDED RESPONSES) 

60%

18%

8%

14%

0%

20%

40%

60%

80%

100%

Owners of Wood Burning Devices Only

Very Likely Somewhat likely Somewhat unlikely Not at all likely

78% 

compliance

 51 Respondents who owned wood-burning devices were significantly 

more likely to say they would comply with a mandatory no-burn rule 

than to approve of it, indicating that prior support may not be a 

necessary requirement for successful implementation of a mandatory 

rule. In other words, respondents may not like the regulation but the 

majority would hypothetically comply with it. 

In order to show levels of approval of a mandatory no-burn measure in the 

same graph as respondents’ likelihood to comply with it, we re-calculated 

levels of mandatory support by including only those respondents who were 

asked the compliance question – namely, those who owned wood-burning 

devices. Results are shown in the next figure, along with the just-reported 

levels of compliance. It can be seen that respondents who owned woodburning devices were significantly more likely to comply with a mandatory 

no-burn rule (78%) than approve of it (66%). 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 55 

FIGURE 46 – SUPPORT FOR MANDATORY NO-BURN RULE 

AND LIKELIHOOD TO COMPLY

(OWNERS OF WOOD-BURNING DEVICES ONLY)

45%

21%

9% 18%

8%

60%

25% 14%

0%

20%

40%

60%

80%

100%

Approval of

Mandatory Rule

Likelihood to Comply

Strongly approve/Very Likely Somewhat approve/Somewhat likely

Somewhat disapprove/Somewhat unlikely Strongly disapprove/Not at all likely

66% 

approval

78% 

compliance

 52 Crosstabulations indicated that the majority of owners who approved of 

mandatory measures also said they would be likely to comply with them 

(87%). Significantly fewer owners who disapproved of mandatory 

measures would be likely to comply (62%). 

In order to see if the same discrepancies between attitudes and behavior that 

were found in the responses to voluntary no-burn measures also occurred in 

reactions to mandatory measures, we examined the fit between support for 

mandatory measures and likelihood to comply with them for the subgroup of 

respondents who were capable of burning wood (i.e. the same population of 

owners as just described above). Results, shown Figure 47, indicate that, 

among those who (“somewhat” or “strongly”) approved of a mandatory noburn rule, 87% said they would likely comply (“somewhat” or “very likely”) with 

it. Significantly fewer owners who disapproved of mandatory measures 

would be likely to comply (62%). In other words, and similar to what was 

found in the voluntary rule analysis, there was a small percentage of 

individuals who approved of mandatory measures but who said they would 

not comply with them (13%); and there was a larger percentage of 

respondents who disapproved of mandatory measures but nevertheless said 

they would comply with them (62%). 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 56 

FIGURE 47 – LIKELIHOOD TO COMPLY WITH MANDATORY NO-BURN RULE 

BY LEVEL OF APPROVAL OF MANDATORY MEASURE

(OWNERS OF WOOD-BURNING DEVICES ONLY) 

62%

87%

0% 20% 40% 60% 80% 100%

Disapprove

(Somewhat +

Strongly)

Approve

(Somewhat +

Strongly)

Likelihood to Comply with Mandatory Rule (Somewhat + Very)

* indicates a statistically significant difference between the groups 

Consistency: Support, Hypothetical Compliance and Actual Compliance 

 53 Further analysis revealed that, although the extent of the discrepancy 

between what respondents said they would do voluntarily and what 

they actually did was similar between those who approved of 

mandatory measures and those who disapproved of mandatory 

measures; compliance this past winter was significantly higher among 

those who approved of mandatory measures (37%) than among those 

who disapproved (24%). 

 54 However, because the majority (63%) of even favorably-disposed 

respondents of a mandatory no-burn rule did not voluntarily reduce the 

number of fires they burned this past winter, if a mandatory no-burn 

regulation were implemented, it would probably have to be visibly and 

publicly enforced in order to increase levels of compliance. 

In order to assess the levels of consistency between attitudes, hypothetical 

behavior and actual behavior, we separated those owners of wood-burning 

devices who did not support a mandatory no-burn rule from those who 

approved of it and within each of these two groups, examined their prior 

responses. The next two figures show the results of this analysis. 

It can be seen in figure 48 that among the group who disapproved of a 

mandatory no-burn rule, the majority (69%) of owner respondents approved

of a voluntary measure, and an even greater percentage (80%) said they 

would comply with a voluntary rule; however, only a quarter (24%) actually 

did reduce the number of fires they burned this past winter after hearing the 

voluntary requests. In other words, there was a fairly large gap between what 

these respondents said they would do and what they did (56% difference). 

*
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 57 

FIGURE 48 – OWNERS WHO DID NOT APPROVE OF A MANDATORY NO-BURN RULE: 

VOLUNTARY SUPPORT, HYPOTHETICAL COMPLIANCE AND ACTUAL COMPLIANCE 

69%

62%

24%

80%

0% 20% 40% 60% 80% 100%

Approve of Voluntary No-Burn Rule

Would comply with Voluntary NoBurn rule

Would comply with Mandatory NoBurn Rule

Actually Complied with Voluntary

Requests in Winter of 2006/2007

In terms of the group of respondents who approved of a mandatory no-burn 

regulation, the vast majority (92%) likewise approved of voluntary measures and 

nearly all (98%) said they would comply with a voluntary rule; however, only 37% 

of these respondents actually did reduce the number of fires they burned this 

past winter after hearing the voluntary requests. In other words, although support 

and predicted compliance was much higher among this group of owners, there 

was still a gap between what this otherwise favorably-disposed group of 

respondents said they would do voluntarily and what they actually did (61%). 

FIGURE 49 – OWNERS WHO APPROVED OF A MANDATORY NO-BURN RULE: 

VOLUNTARY SUPPORT, HYPOTHETICAL COMPLIANCE AND ACTUAL COMPLIANCE 

92%

87%

37%

98%

0% 20% 40% 60% 80% 100%

Approve of Voluntary No-Burn Rule

Would comply with Voluntary NoBurn rule

Would comply with Mandatory NoBurn Rule

Actually Complied with Voluntary

Requests in Winter of 2006/2007

- 56% 

- 61% 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 58 

Owner Burners vs. Owner Non-Burners

 55 Among owners of wood-burning devices, although levels of approval of 

mandatory measures were significantly different for burners and nonburners, levels of hypothetical compliance were the same. 

Significantly fewer owners of wood-burning devices who burned wood this past 

winter approved of mandatory measures (56%) than owners who did not burn 

wood (83%). That being said, Figure 50 shows that, regardless of whether or not 

they approved, the same percentage of burners as non-burners21 would be likely 

to comply with a mandatory restriction – among those who approved of 

mandatory measures, 83% of non-burners said they would likely comply with 

mandatory measures. This is not significantly different from the 91% of burners 

who approved and said they would comply. Similarly, among those who 

disapproved of mandatory restrictions, 64% of non-burners would nevertheless 

comply and 61% of burners said they would comply. 

FIGURE 50 – LIKELIHOOD TO COMPLY WITH MANDATORY NO-BURN RULE 

BY LEVEL OF APPROVAL OF MANDATORY MEASURE: 

(OWNER NON-BURNERS VS. OWNER BURNERS) 

61%

64%

83%

91%

0% 20% 40% 60% 80% 100%

Disapprove 

Approve 

Disapprove

Approve

Likelihood to Comply with Mandatory Rule (Somewhat + Very)

* indicates a statistically significant difference between the groups 

Low-Income Group

 56 Owners of wood-burning devices in the low-income group were not as 

likely to comply with a mandatory no-burn rule. 

 

21 This particular analysis of burners vs. non-burners is among owners of wood-burning devices only (i.e. those who were 

asked the mandatory compliance question). Previous analyses of burners vs. non-burners were based on a larger 

number of respondents as they included as non-burners the subset of the general population (185 respondents) who 

did not own any wood-burning devices and therefore did not burn wood this past winter. 

*

*

Owner

Burners 

Owner NonBurners 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 59 

The next figure shows the levels of hypothetical compliance with a 

mandatory no-burn rule among low-income respondents who owned 

wood-burning devices. It can be seen that only 59% of these 

respondents would be somewhat or very likely to comply with mandatory 

regulation, compared with 78% of owners in the general population. (It 

should be kept in mind, however, that the number of owners in the lowincome group is relatively small – this analysis includes only 44 

respondents.) 

FIGURE 51 - LIKELIHOOD TO COMPLY WITH MANDATORY NO-BURN RULE

(OWNERS OF WOOD-BURNING DEVICES ONLY: LOW-INCOME GROUP 

EXCLUDING UNDECIDED RESPONSES)

48%

11%

18%

23%

0%

20%

40%

60%

80%

100%

Owners and Burners: Low Income Group

Very Likely Somewhat likely Somewhat unlikely Not at all likely

59% 

compliance

Other Group Differences

 57 There were no demographic features that distinguished respondents 

who said they were likely to comply with mandatory no-burn 

measures from those who were not. 

The series of 13 chi-square analyses which were run on owners of woodburning devices to determine whether certain demographic features 

distinguished those who were likely to comply with a mandatory no-burn 

rule from those who were not likely to comply did not yield any significant 

differences – the same proportion of males as females would comply as 

would not, as would owners as well as renters, those from wealthier homes 

and poorer homes, better educated respondents as well as less educated 

respondents; etc. In other words, a public education campaign about 

PM pollution does not need to target specific demographics -- a broad 

outreach to all residents in Sacramento County should have an 

impact. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 60 

COMMUNICATION STRATEGIES

General Population

 58 The general news media, such as TV, radio, and newspaper, would be the 

best way to let residents know whether or not they can burn wood on a 

particular day. 

Respondents were read a list of possible ways that residents could find out about 

the air quality on a particular day and whether or not they could burn wood in the 

event that a mandatory no-burn rule was adopted. They were asked to rate each 

one in terms of how effective it would be for them personally, using a four-point 

scale: poor, fair, good, or excellent. As shown in Figure 52, the general news 

media was considered to be the most effective, with nearly half of those surveyed 

considering the TV, radio, or newspaper to be an “excellent” way to alert the 

public of a No-Burn Day. A further 37% said it would be a “good” way to reach 

them, for a combined total of 84% who held positive opinions about this 

communication strategy. This figure was found to be statistically significantly 

higher than the combined positive ratings towards the three other options 

mentioned: posting info on the website, 43%; emailed or text message on cell 

phone, 41%; or call to listen to a recorded message, 40%. 

FIGURE 52 - EFFECTIVENESS RATINGS OF 

COMMUNICATION STRATEGIES FOR NO-BURN DAYS

(AMONG BASE STUDY EXCLUDING UNDECIDED RESPONSES)

47

17 16 16

37

26 25 24

12

19 15 22

4

44 39 38

0%

20%

40%

60%

80%

100%

General News

Media

Posting Info on

Website

Emailed or Text

Message on Cell

Phone

Call to Listen to

Recorded

Message

Excellent Good Fair Poor

 59 Electronic billboards along the freeway and telephone calls were identified 

as other effective ways to advise the public about a No-Burn Day. 

Additionally, 8% suggested air quality information be sent via the mail. 

Respondents were asked to identify any other way they would prefer to receive 

information about the air quality to keep them informed about whether or not it is 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 61 

okay to burn wood on a particular day. Responses were captured in an openended format, cleaned and categorized for quantitative analysis. The majority of 

those surveyed (73%) offered no suggestions. Some respondents reiterated 

communication channels that had already been discussed (newspaper, 2%); TV, 

2%; radio,1%; and general media,1%). Other ideas were more creative and 

included: 

Eight percent said they would like to receive something in the mail. 

Although this would obviously not be a way to alert the public about a noburn request for the next day, a closer look at the verbatim responses 

implies an opportunity for public education about air quality and noburn days in general. 

 Several people who mentioned receiving information in the form of 

utility bill inserts said: 

− “A newsletter. Maybe something similar to a schedule. 

− By mail from PGE. 

− Inserts in utilities bills 

− The monthly utility bill could add some air quality information. 

− By mail through utility services.” 

 Other comments were more generic and included: 

− “Direct mail of all the dates and I would post on my refrigerator. 

− Door to door flyers mail drops 

− I didn't know this was such a big problem, so send it in the mail. 

− In the mail which is on paper which is a wood product. 

− Information with electric or gas bills would be a better way to inform me 

− Mail flyers. Have a place to sign the flyer, show that they read it, and mail it 

back and get like $5 for reading it. 

− Maybe a flyer or a postcard. 

− Memorandum by mail or by email. 

− Pamphlet. 

− Possibly a flyer or something sent in the mail.” 

Several respondents (3%) would like to receive a telephone call. Comments 

included: 

− “A phone message or a call on those days. 

− A telephone blast. 

− Automated phone book where you could call people to alert people. Generated 

by a computer. Look people up in the phone book to call them. 

− Call me. 

− Give me a phone call. 

− Recorded announcement for my phone. 

− They could call me. 

− They need to call me on the phone. 

− To call the people of the county. 

− Voluntary automated phone calls to people who have signed up.” 

A few people (3%) thought electronic billboards along the freeway would be 

effective. Comments included: 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 62 

− “Amber signs posted. 

− Billboards over the freeway, electronic billboards, like the ones used for 

construction, one will automatically read it when passing by one. 

− Billboards. 

− Displays on the highway. 

− Electronic billboards. 

− Highway signs. 

− Signs on freeway, flashing saying it is a no burn day. 

− Signs on the freeway like the Amber alerts to let people know. 

− The Amber Alert sign on the highway. 

− To do sign boards like the Amber Alert or all along the freeway.” 

Other suggestions for communicating No-Burn Days that were unique and could 

not be grouped into the same category included: 

− “A helicopter with a loudspeaker, but that would cause pollution itself. 

− A reminder that you will be notified about no burn days in the next three months. 

− By helicopter warnings. 

− E-mail on the computer; not just through the phone e-mail. 

− Flying a blimp, or signs on the buses. 

− Have a flag on capitol building - like city hall. 

− I would consider a pop-up on the internet service. A flag system also, 

something like what they used to have at the fire stations. 

− I would like to see it come through your thermostat on my house. A smart 

thermostat with display to show no wood-burning. 

− New year blimp 

− Notify people at work. 

− People who would carry signs around to let people know. 

− Posters. 

− Put up a tower and put lights on the top of it where green if you can burn and 

red when you can't. 

− Register homeowners with fireplaces. 

− Reverse 911 system to be used in emergencies. 

− Streaming news would be helpful. 

− Supermarket alert in supermarket or gas pump. Places we frequent a lot. 

Schools. A hot air balloon. 

− The internet is the best way. 

− They should give us a schedule in our area as to when we can burn wood or 

not burn it. 

− Through community groups. 

− Warning signal like an air raid signal. 

− You would have to send a no-burn officer to the door in order to contact me.” 

Low-Income Results

 60 Communication preferences among low-income respondents were 

very similar to those of the general population, with the general 

news media ranking the highest (82% gave favorable ratings). 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 63 

Eight in ten said that the general news media would be a “good” (37%) or 

“excellent” (45%) way of communicating information about air quality and 

no-burn days. A third of low-income respondents felt that posting on a 

website (34%) and sending an e-mail or text message (35%) were 

favorable options. About half (50%) favored a telephone number which 

they could call to hear a recorded message. 

Group Differences

 61 Preference for a recorded telephone message varied by a few 

demographic features (income, ethnicity, education, Internet access, 

type of dwelling and wood burn activity). Ethnicity influenced the level 

of those favoring e-mail and text messages.

The series of 13 chi-square analyses that were run on the general population 

to determine whether certain demographic features distinguished those who 

were gave positive evaluations of the various communication strategies from 

those who gave negative ratings did not yield any significant differences the 

use of general media or posting information on a website. 

Those who gave positive ratings (“good” or “excellent”) for receiving e-mailed

messages or text messages on a cell phone to alert them about no-burn days 

were more likely to: 

− identify their ethnic background as African American or Hispanic or 

Latino (both 63%) than Caucasian (35%). 

Those who gave positive ratings for a telephone number with a recorded 

telephone message in terms of being an effective communication tool were 

more likely to: 

− live in an apartment, condo, townhome, or mobile home (54% vs. a 

single-family home, 36%), 

− have less formal education (46% vs. have a college degree, 32%), 

− not currently access the Internet (54% vs. those who do, 35%), 

− have lower incomes (52% vs. 33% of those earning $50,000 or more), 

− not burn wood (45% vs. 30% of the burners), 

− identify their ethnic background as African American (56%) and 

Hispanic or Latino (65%) versus Caucasian (37%). 

AIR ALERT SUBSCRIPTIONS

 62 Five percent of those surveyed said they currently subscribe to Air 

Alert. Among the non-subscribers, about four-in-ten said they would be 

likely to do so in the future, with 17% saying they would be “very” likely.

Respondents were asked whether or not they subscribed to the District’s Air 

Alert notification system and 5% said they did. The 95% who were not 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 64 

current subscribers were asked: “How likely would you be to sign up for an email notification that would alert you to no-burn days?” As shown in the next 

figure, 17% would be “very” likely and an additional 24% would be 

“somewhat” likely. In other words, four-in-ten respondents said they would be 

likely to sign up for Air Alerts. The other 58% were not interested in the 

program. 

FIGURE 53 – SUBSCRIPTION TO AIR ALERT NOTIFICATIONS

(AMONG BASE STUDY EXCLUDING UNDECIDED RESPONSES)

Current 

Subscribers

5%

Somewhat 

likely

24%

Very likely

17%

Not at all 

likely

58% NonSubscribers

95%

Group Differences

 63 Two demographic characteristics distinguished current non-subscribers 

who would be likely to sign up for Air Alert from those who would not: 

access to the Internet and age of home. Likelihood to subscribe was 

independent of other respondent demographics, including age, 

education, income and burner vs. non-burner, etc.

The series of chi-square analyses were run to try to distinguish those who 

would be (“somewhat” or “very”) likely to sign up for Air Alert from those who 

would not among current non-subscribers. Results yielded two statistically 

significant differences. Those who were more likely to become Air Alert 

subscribers: 

− had access to the Internet (51% vs. not access it, 18%), and 

− live in homes that are less than 30 years old (50% vs. older 

homes, 28%). 

DEMOGRAPHICS

 64 The plurality of Sacramento base study respondents: were Caucasian, between 

the ages of 35 and 64, held a college degree, and had household earnings of at 

least $50,000. They were homeowners, living in single-family homes that were 

built at least 20 years ago, with at least one other person, and were registered to 

vote. 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 65 

The tables on the following pages indicate the demographic characteristics of the 

Sacramento base study residents and the group of low-income respondents who 

responded to the survey. While the percentages of non-responses by refusal are 

included in these tables, they were usually excluded from the analyses, unless otherwise 

stated. Within the base study column, pluralities are indicated in bold. 

The “other” responses given for type of occupation, ethnicity, and party affiliation can be 

found in the statistical binder. 

FIGURE 54: DEMOGRAPHIC CHARACTERISTICS OF RESPONDENTS

GENDER

PERCENT OF BASE 

RESPONDENTS

PERCENT OF LOWINCOME RESPONDENTS

Female 50% 59% 

Male 50% 41% 

Total 100% 100% 

AGE

PERCENT OF BASE 

RESPONDENTS

PERCENT OF LOWINCOME RESPONDENTS

18 – 24 3% 6% 

25 – 34 13% 13% 

35 – 44 18% 11% 

45 – 54 21% 12% 

55 – 64 19% 10% 

65 or older 23% 47% 

 Non-response (Refused) 3% 1% 

Total 100% 100% 

EDUCATION

PERCENT OF BASE 

RESPONDENTS

PERCENT OF LOWINCOME RESPONDENTS

High school or less 24% 56% 

Some college 30% 24% 

Trade/Vocational – No college 2% 4% 

College degree 26% 12% 

Post-graduate degree 17% 3% 

 Non-response (Refused) 1% 1% 

Total 100% 100% 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 66 

ETHNICITY

PERCENT OF BASE 

RESPONDENTS

PERCENT OF LOWINCOME RESPONDENTS

African-American 6% 11% 

Asian/Pacific Islander 5% 3% 

Caucasian 65% 51% 

Hispanic/Latino 13% 24% 

Something else 6% 8% 

 Non-response (Refused) 5% 3% 

Total 100% 100% 

VOTER REGISTRATION

PERCENT OF BASE 

RESPONDENTS

PERCENT OF LOWINCOME RESPONDENTS

Registered 78% 64% 

Not registered 21% 34% 

 Non-response (Refused) 1% 2% 

Total 100% 100% 

INTERNET ACCESS

PERCENT OF BASE 

RESPONDENTS

PERCENT OF LOWINCOME RESPONDENTS

None 27% 67% 

Yes 72% 33% 

 Non-response (Refused) 1% 0% 

Total 100% 100% 

TYPE OF DWELLING

PERCENT OF BASE 

RESPONDENTS

PERCENT OF LOWINCOME RESPONDENTS

Apartment 15% 35% 

Condo 2% 3% 

Townhome 2% 4% 

Single-family detached home 77% 48% 

Mobile home 2% 9% 

 Non-response (Refused) 2% 1% 

Total 100% 100% 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 67 

HOME OWNERSHIP

PERCENT OF BASE 

RESPONDENTS

PERCENT OF LOWINCOME RESPONDENTS

Rent or Lease 27% 51% 

Own 71% 47% 

Live with others 1% 0% 

 Non-response (Refused) 1% 2% 

Total 100% 100% 

AGE OF HOME

PERCENT OF BASE 

RESPONDENTS

PERCENT OF LOWINCOME RESPONDENTS

10 years or less 18% 3% 

11 – 20 years 8% 9% 

21 – 30 years 15% 3% 

31 – 40 years 16% 16% 

41 – 50 years 14% 21% 

More than 50 years 14% 32% 

 Non-response (Refused) 5% 15% 

Total 100% 100% 

# OF HOUSEHOLD MEMBERS

PERCENT OF BASE 

RESPONDENTS

PERCENT OF LOWINCOME RESPONDENTS

Live alone 21% 44% 

Two 35% 21% 

Three 16% 7% 

Four 14% 11% 

Five or more 13% 16% 

 Non-response (Refused) 2% 1% 

Total 100% 100% 

HOUSEHOLD INCOME

PERCENT OF BASE 

RESPONDENTS

PERCENT OF LOWINCOME RESPONDENTS

Under $20,000 10% 100% 

$20,000 to less than $50,000 25% 0% 

$50,000 to less than $100,000 32% 0% 

$100,000 or more 19% 0% 

 Non-response (Refused) 14% 0% 

Total 100% 100% 
Sacramento Metropolitan Air Quality Management District 

2007 Residential Wood Burn Research Study 

Final Results Report 

May, 2007 

Dawn Morley Chavero & Naomi E. Holobow, Ph.D. Page 68 

SUMMARY CONCLUSIONS AND RECOMMENDATIONS 

There is still much room for educating the general public about the negative effects of 

residential wood-burning on wintertime air quality: approximately four in ten respondents in 

Sacramento County felt wood-burning was not a serious cause of air pollution. 

One third (33%) of all respondents in the base study were classified as “burners”: they 

owned wood or pellet burning devices (either indoors or outdoors), and they burned wood, 

pellets, or manufactured logs at least once this past winter. Burners were significantly 

more likely than non-burners to: 

- be home owners (rather than renters,) 

- live in single family dwellings, and

- be wealthier (have household incomes greater than $50,000).

Although the majority of respondents in the general population supported mandatory 

curtailment restrictions, about one fifth (20%) said they “strongly” disapproved of 

mandatory regulation. The main reason given for the disapproval was an active dislike of 

being told what to do by the government. 

Respondents who owned wood-burning devices were significantly more likely to say they 

would comply with a mandatory no-burn rule than to approve of it, indicating that prior 

support may not be a necessary requirement for successful implementation of a 

mandatory rule. In other words, respondents may not like the regulation but the majority 

would hypothetically comply with it. 

That being said, there was some discrepancy between attitudes and actual behavior. 

Among owners of wood-burning devices who approved of mandatory measures, 37% 

actually voluntarily reduced the number of fires they burned this past winter. This was 

significantly higher than the 24% of respondents who complied but who disapproved of 

mandatory measures. 

However, because the majority (63%) of even favorably-disposed respondents of a 

mandatory no-burn rule did not voluntarily reduce the number of fires they burned this past 

winter, if a mandatory restriction were to be implemented, it would probably have to be 

visibly and publicly enforced in order to increase levels of compliance. 

The best way to let residents know whether or not they can burn wood on a particular day 

is via the general news media, such as TV, radio, and newspaper. 

These results were based on 401 telephone interviews conducted in April, 2007 with a 

random sample of Sacramento County residents, representative of the population as a 

whole. Results are accurate to within +/- 4.9%, 19 times out of 20. A total of 139 interviews 

were also conducted with a group of low-income (based on federal guidelines) residents. 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 98 

Appendix E 

Comments and Responses 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 99 

July 25th Board Meeting Oral Comments

Mary Ann Delaney (school nurse with the Folsom-Cordova district)

Comment: Every year there are more and more students with respiratory 

diseases such as asthma, brochiolitis, and chronic bronchitis. In 

the Folsom-Cordova district, parents of 1,500 students have 

reported that their children have respiratory illness or asthma. 

Nationally, 13% of school children have asthma, and they miss 

school twice as often as their healthy peers. Three schools in the 

Folsom-Cordova district have asthma rates between 16% and 18%. 

 Older women also experience adverse health effects from fine 

particulate matter. Exposing the developing lungs of children to 

particulate matter causes disease early in life and again later in 

life. I urge the Board to adopt the proposed rule to curtail wood 

smoke.

Response: Thank you for your support. 

Amy Ryan (Ryan Brothers Chimney Sweeping)

Comment #1: While I applaud the District’s change-out program, I am 

disappointed that EPA-certified devices were included in the 

proposed curtailment rule. People who took voluntary actions to 

reduce their wood smoke emissions should be rewarded for their 

efforts. 

Response: Special requirements for certified devices are not recommended for several 

reasons. 

1. While certified devices and pellet stoves are designed to pollute less than 

fireplaces and non-certified wood stoves, their emissions are about an order 

of magnitude higher than gaseous fueled devices. 

Comparison of Emission Factors 

Technology PM2.5 Emission Factor 

(lb/mmBtu) 

Certified Wood Stove 1.85 

Pellet Stove 0.69 

Propane Fireplace 0.01 

Natural Gas Fireplace 0.01 

Electric None 

2. Certified devices and pellet stoves can smoke if not installed or operated 

properly. Prohibiting all wood smoke, whether from a certified device or 

uncontrolled fireplace is most appropriate for air quality and equity reasons. 

3. Collectively, certified wood and pellet stoves and inserts comprise 7% of the 

wood burning emissions. This percentage will increase as new devices are 

installed or older devices replaced, particularly since no new fireplaces may 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 100 

be installed after October 2007, and all new developments must use either 

gas fireplaces or certified equipment. All emissions reductions contribute to 

attainment of federal health standards. 

4. Although pellet stoves are easily recognizable to the public, certified wood 

stoves are not easily distinguished from non-certified wood stoves. To know 

whether you have a certified stove you either need to know when the device 

was purchased (after 1992), or check the model number of the stove 

(located on the back or side of the device) and look it up on EPA’s Web site. 

 This may be difficult for some residents and would make enforcement more 

difficult. 

5. Independent public opinion surveys reported that only 13% of residents rate 

wood smoke as a very serious cause of wintertime air pollution. Public 

education staff and our consultants stress the importance of creating a 

simple message as a key to the success of Rule 421 outreach efforts. 

Creating additional complexity will further burden an already difficult 

educational effort. 

6. Although manufacturers suggest that creating special provisions for certified 

devices will increase compliance, no data has been provided or is available 

that substantiates these assertions. Compliance rates are difficult to predict 

and depend on a number of factors. 

7. Manufacturers also suggest that not allowing certified devices to operate on 

some or all no burn days creates a disincentive to replace dirty devices with 

cleaner burning alternatives. No data has been provided to substantiate that 

assertion. Replacing dirty devices with cleaner burning alternatives is fairly 

expensive. The capital and operational costs are likely to be more 

significant factors in determining whether to replace dirty devices, and the 

choice of which devices to select. The District's incentive program provides 

the greatest incentive to install gaseous fueled devices. Voucher data 

suggests that 60% of incentive program participants choose gaseous fueled 

devices. Staff can track this and propose modifications to incentives or rule 

requirements if participation levels drop. 

 

14 Installation costs are pretty similar $350-500 and additional material costs had a wide range 

from $250-1000 depending on the specifics of the installation. Installation and material costs for 

electric fireplaces are 0-$75. 

 Cost of Devices Voucher incentive 14Thermal Efficiency Fuel Cost 

$ per MMBtu Non-EJ EJ 

Wood Stove $600-2900 63% 29.75 $250 $400

Wood Insert $1100-3000 63% 29.75 $250 $400

Gas/Propane Stove $1000-2700 75% 27.67 $350 $500

Gas Insert $1400-3500 75% 15.07 $350 $500

Pellet Stove $1200-4100 76% 20.56 $350 $500

Pellet Insert $1400-3800 76% 20.56 $350 $500

Electric fireplace ~$300 >99% 23.39 $0 $0 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 101 

Comment #2: Ryan Brothers’ own survey indicated that 78% of their customers 

use their fireplaces for heat, mainly because of cost. Burning 

wood is still a cheaper source of heat than natural gas or 

electricity, and people prefer the even heat that wood produces.

Response: See response to Cynthia Marshall comment #1 

Earl Withycombe

Comment #1: Wood smoke contains many toxic air contaminants, similar to 

cigarette smoke and diesel particulate.

Response: Staff agrees and has included the potential reductions from these 

pollutants as additional benefits from proposed Rule 421. 

Comment #2: In my experience with the Mountain Counties air basin, the 

Truckee area dealt with many complaints about childhood asthma 

due to smoke from wood combustion. 

Response: Thank you for your comments. It is an important reminder that wood 

combustion contributes not only to ambient PM2.5 concentrations but 

can also contribute to poor indoor air quality for those residents that 

burn wood. 

Comment #3: PM2.5 pollution forms “hot spots” that are not readily transported.

Response: Dispersion modeling performed as part of the California Regional 

Particulate Air Quality Study15 indicated that the range of influence of 

PM emissions ranged from 15-50 kilometers. 

Note: Mr. John Crouch (representing Hearth, Patio and Barbeque Association) and Mr. 

Robert Cline (representing Duraflame) also testified and reiterated that testimony in 

subsequently provided written comments. Staff responses can be found under written 

comments. 

Public Workshop/Open House/Stakeholder Comments

Open House Tsakopoulos Library Galleria

July 23, 2007, 6:00 pm

Attendees: Amie Ryan Jack Dillon 

 Tony Hernandez Al & Cheryl Ferguson 

 

15 MacDonald, C.P, McCarthy, M.C., Dye, T.S., Wheeler, N.J.M., Hafner, H.R, and Roberts, P.T., 

“Transport and Dispersion during Wintertime Particulate Matter Episodes in the San Joaquin 

Valley, California,” Journal of the Air & Waste Management Association, volume 56, p. 961, July 

2006. 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 102 

 Herman T Mark Taviani 

 Mitchell Heller Earl Withycombe 

 Efren Guttierrez Jack Good 

Bill Pieper 

No written comments received. 

Open House La Sierra Community Center

July 24, 2007, 6:00 pm

Attendees: Mr. & Mrs. Jacob Schales Skip Ayres 

 Jim Tom P 

 Janice Holtgrave Scott Anderson 

 PJ Mocettini Carol Sando 

 Jean & Alec McAdam Carl & Beverly Tennis 

Francie Axtell Rusty Savard 

 Chris & Laurie Axtell Ann Shedd 

 Joyce Eastin Terri Friedman 

Comment received by e-mail from Joyce Eastin on July 30, 2007 

Comment: I believe the rule is a good idea. Sacramento has enough smog and 

poor air quality. Furthermore fireplaces are inefficient.

 

Response: Staff agrees and appreciates your support. 

Comment received by e-mail from Ann Shedd on August 7, 2007 

Comment: After attending the open house and reviewing the literature that was 

available, I am aware of the value of Rule 421. Hopefully, Rule 421 will 

be adopted. 

Response: Thank you for your support. 

Comment received by e-mail from Terri Friedman on August 8, 2007 

Comment: No more government regulations are needed. Strong public outreach 

with voluntary restrictions on high particulate days would work, as well 

as limitations on all PM sources not just wood fires. Also include a 

max number of days per season with restrictions perhaps 8-10 days. 

Main goal should be development of technology to filter particulates at 

the chimney so restrictions on burning would not be necessary.

Response: Sacramento County will be designated non-attainment for federal health 

standards for PM2.5 unless it reduced PM2.5 emissions. Because of the 

serious health consequences associated with nonattainment, we need to 

take action to reduce PM emissions. Education is a critical component of 

Rule 421 success. The Aurora public opinion survey reported only 27% 

reduction in wood burning from people hearing the voluntary request and 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 103 

reducing burning. Based on the success of mandatory programs in other 

areas, Staff recommends Rule 421 as the most effective way to lower 

emissions. 

 

 Limiting the amount of curtailment days would increase the number of days 

the District exceeds the 24-hour PM2.5 standard, and perpetuate the serious 

health impacts and our non-attainment status. 

 Technologies to reduce particulate emissions by 85% are available, such as 

EPA certified wood and pellet fireplace inserts, and free standing certified 

wood stoves and pellet stoves. Gaseous fueled devices are >99% cleaner 

than certified wood stoves. The District has a program to provide financial 

incentives to help people replace dirty devices, and Rule 417 requires any 

new wood burning devices to be controlled. However, the vast majority of 

existing wood burning devices are not controlled at this time; an estimated 

250,000 - 300,000 fireplaces and non-certified devices compared to 15,000- 

25,000 certified devices and pellet stoves. Because of the expense to 

replace or modify existing devices, replacement of dirty devices is expected 

to take some time. It is possible that with incentive programs, education and 

replacement of uncontrolled devices, with time fewer mandatory curtailment 

days may be called. 

Open House Rancho Cordova City Hall

July 25, 2007, 6:00 pm

Attendees: Stuart & Shirley Helfland 

 Gary Namisulk 

No written comments received 

Open House SMAQMD Office

July 26, 2007, 1:30 pm

Attendees: Armen Kamian Jennifer Finton 

 Steve Dulone Kathy Coulter 

 Yushuo Chang Yachun Chow 

 Tom Orr Annemarie Vincent 

 Nelson Fong Patricia Velaso 

 Amie Ryan 

Oral Comments from SMAQMD Open House

Comment #1: Doesn't San Joaquin exempt certified devices? 

Response: San Joaquin Valley air district issues 1) voluntary no burn requests, during 

which wood burning is discouraged except in the use of certified devices or 

manufactured logs; and 2) mandatory no burn requests, during which all 

wood burning is prohibited even in certified devices. 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 104 

Comment #2: Doesn’t this conflict with the incentive program? 

Response: There are roughly 25,000 certified wood and pellet stoves in Sacramento 

County, emitting over 350,000 pounds of particulate matter every year. 

These devices account for 7% of the emission reduction from Rule 421. On 

days when the weather causes smoke to collect near the ground, reducing 

every source of smoke improves the air quality. Staff considered several 

alternatives providing special consideration to certified devices. See the Staff 

Report discussion of Alternatives for a full discussion. Ultimately, staff 

decided to not recommend special provisions. 

 Staff has been clear that the healthiest choice for individuals and our 

community is to choose not to burn. People choosing to burn are 

encouraged to burn cleanly - the cleanest fuel is a gaseous fuel; either 

natural gas or propane. The District provides the greatest incentive for 

gaseous fueled devices. To avoid any potential confusion, we have modified 

the materials for our incentive program to more clearly state that individuals 

that choose to replace dirty devices with wood or pellet fueled alternatives 

will be prohibited from using those devices when weather conditions trap the 

pollution generated by those wood burning devices and contribute to health 

standard violations. 

Comment #3: How does ARB determine health impacts?

Response: ARB sponsors health studies and relies on dozens of other health studies to 

estimate health impacts. A fact sheet on ARB's information can be found at: 

http://www.arb.ca.gov/research/health/fs/PM-03fs.pdf

 EPA conducts similar reviews in setting federal PM2.5 standards. Here is a 

link that information: 

http://a257.g.akamaitech.net/7/257/2422/01jan20061800/edocket.access.gpo.gov/2006/pd

f/06-8477.pdf

 

 An EPA fact sheet of particulate matter health issues can be found at: 

 http://www.epa.gov/oar/particlepollution/pdfs/pm-color.pdf

Comment #4: What is the basis for health cost estimates? 

Response: See response to comment #3. ARB staff provided health cost data for 

Sacramento16. The effect for each health endpoint was calculated 

separately for each county; these county-wide values were then 

summed to produce aggregate Sac Metro results. 

Health impact calculations were based on the methodology used in 

CARB’s 2002 PM standard staff report, with an updated response 

function for premature mortality (Pope et al. 2002. Journal of the 

American Medical Association 287:1132-1141). 

 

16 E-mail from Linda Smith to Brigette Tollstrup, January 9, 2007 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 105 

Population values were taken from the year 2000 census. PM2.5 

calculations were based on 1999/2000 ambient air quality data. 

Comment #5: What about night time enforcement? 

Response: The District will actively enforce compliance with the rule. Inspections will be 

based on both complaints and random inspections. If necessary, night time 

enforcement will occur. 

Comment #6: What happens to repeat offenders? 

Response: Penalties for subsequent violations would be determined according to the 

District’s Mutual Settlement Program. 

Written suggestion received at the workshop from Jennifer Finton, Breathe California 

Suggestions: Include chemical composition of wood smoke and compare to other 

well-known toxic emitters, use graphics to show short and long term 

affects of PM2.5 on the body, explain manufactured logs’ contribution 

to PM2.5 as well as certified devices, consider targeted advertising in 

neighborhoods closest to PM monitors and those with similar 

characteristics, provide graphic illustration of combustion process, 

and create easy to use newsletters, PSA’s, alerts. 

Response: Thank you for your suggestions and we will consider them as we form 

messages to the public for the educational campaign. The monitoring 

station locations are selected to be representative of the broader community 

air quality levels as well as the immediate adjacent areas. Other parts of 

Sacramento County are expected to observe similar air quality. Staff has 

and will attended events in areas with high particulate concentrations to 

educate and inform them on the health impacts and alternatives to burn 

cleanly. 

Open House Laguna Creek High School

July 26, 2007, 6:00 pm

Attendees: Ted & Rita Holm Marilyn Flemmer 

 John Taylor Andrew Vaillancourt 

 Faron Schmidt Bill Thompson 

 

Written comment received at the open house from Bill and Debbie Thompson 

Comment: We are concerned about not being able to use our wood stove on 

“No Burn Days”. The stove is the source of heat for our home. 

Heating electrically is cost prohibitive for us and gas is not available. 

 We need to be able to use our stove. Please consider our situation 

and the many others in similar situations.
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 106 

Response: Staff is proposing an option for the Air Pollution Control Officer to issue 

hardship exemptions to households where prohibiting solid fuel burning 

would cause economic hardship and the granting of the exemption would 

not have an adverse impact. If the stove is the only source of heat for a 

home, it will be exempt from mandatory curtailment. Unless the wood is 

delivered at no cost, it generally costs less to heat a home with natural gas 

or electricity than with wood; even propane stoves/inserts are slightly less 

expensive to operate than wood. 

Open House Orangevale Community Center

July 30, 2007, 6:00 pm

Attendees: Davis & Kim Tennant Stacy Shank 

 Jennifer Kennedy Carol Evans 

 Bob & Jeannie Kegley Skip Ayres 

 Ted & Jaena Costa 

No written comments received. 

Open House Chabolla Center

July 31, 2007, 6:00 pm

Attendees: Thomas Young Steve Frank 

 City Councilperson Barbara Payne Supervisor Don Nottoli 

No written comments received. 

Open House Folsom Community Center

August 1, 2007, 6:00 pm

Attendees: Sharon & Ray Reed Bob Cline 

 Heather Kuklo Karen Wilson 

 Karen Pitts 

Written comments received from Karen Pitts 

Comment #1: The District should allow certified wood burning devices to burn 

during curtailment. The District is sending a mixed message by 

encouraging people to switch to certified wood burning devices and 

not allowing their use during mandatory curtailment. 

Response: The District is currently in non-attainment of PM2.5 standards, and is 

committed to reductions from sources of PM2.5. Additionally, burning 

wood releases a variety of toxic compounds into the air. 

 Staff realizes that even though we discourage all burning, even when a no 

burn day is not in effect, some may still choose to burn wood. Staff 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 107 

encourages those that choose to burn to do so as cleanly as possible. 

Certified wood burning devices are better than fireplaces and non-certified 

devices. 

 Staff discusses potential mandatory no burn requirements with incentive 

program participants. To further clarify this, staff has added a brief 

discussion of proposed Rule 421 requirements to the voucher and voucher 

application. 

 Replacing dirty devices with cleaner burning alternatives is expensive. 

The capital and installation costs are likely to be more significant factors in 

determining whether to replace dirty devices, and the choice of which 

devices to select. The District's incentive program provides the greatest 

incentive to install gaseous fueled devices. Voucher data suggests that 

60% of incentive program participants choose gaseous fueled devices. 

Comment #2: I am on a fixed income and can not afford to replace my gas heater.

Response: See response to comment from Laguna Creek High School workshop. 

Comment #3: Wood burning has a net zero effect on climate change since the 

greenhouse gas released when wood is burned would end in the air 

anyway through decay or burning or via chipping. I urge you to take 

into account the emissions rate of a wood stove, and the effects on 

climate change of natural gas before you make a one-size-fits-all 

ruling. 

Response: Rule 421 would achieve clear reductions in greenhouse gases by 

prohibiting wood burning in fireplaces for ambiance. Residents that use 

wood to supplement their central heating system may switch to another 

fuel source to replace the wood heat. That fuel may be natural gas, 

propane or electricity. 

 Burning wood for heat emits approximately two to five times more 

greenhouse gases than the replacement fuels. Some experts suggest that 

if the wood fuel is from a sustainable source that the wood burning 

 

17 Installation costs are pretty similar $350-500 and additional material costs had a wide range 

from $250-1000 depending on the specifics of the installation. Installation and material costs for 

electric fireplaces are 0-$75. 

 Cost of Devices Voucher incentive 17 Thermal Efficiency Fuel Cost 

$ per MMBtu Non-EJ EJ 

Wood Stove $600-2900 63% 29.75 $250 $400 

Wood Insert $1100-3000 63% 29.75 $250 $400 

Gas/Propane Stove $1000-2700 75% 27.67 $350 $500 

Gas Insert $1400-3500 75% 15.07 $350 $500 

Pellet Stove $1200-4100 76% 20.56 $350 $500 

Pellet Insert $1400-3800 76% 20.56 $350 $500 

Electric fireplace ~$300 >99% 23.39 $0 $0 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 108 

emissions may be considered "carbon neutral". 

 The California Air Resources Board (CARB) is conducting a public meeting 

in September 2007 to solicit input to develop a protocol on how to assess 

greenhouse gas impacts from forestry products. No approved CARB 

protocol is currently available. It is not clear whether the wood is obtained 

from a sustainable source for greenhouse gas purposes. It is also 

important to assess the relative impact from the immediate release of 

greenhouse gases from burning when compared to the longer term 

release of greenhouse gases if the wood were used for another purpose. 

 

Stakeholder Meeting Health Organizations

August 6, 2007, 8:30 am

Attendees: Heidi Endstay 

Comment: “No Burn Days” should be advertised like Spare the Air Days.

Response: If Rule 421 is approved, outreach will be similar to Spare The Air. Staff will 

inform the public of the rule and of the curtailment days, under a program 

titled “Check Before You Burn.” 

Comment: There are a lot of people that want to make changes to their home to 

be “green.” I think with an increased wood incentive program, more 

people would do it. 

Response: The next opening for the wood stove/fireplace change out incentive 

program begins September 1, 2007 and ends March 31, 2008. Depending 

on the device installed, the incentive available ranges from $75-$500. The 

highest incentive is for replacing with gaseous fueled devices in 

environmental justice communities. Some retailers may provide additional 

discounts. In addition, the District has partnered with the Community 

Resource Project to fully fund replacements in low-income households. 

Stakeholder Meeting Outdoor Organizations

August 6, 2007, 1:30 pm

Attendees: John Blue, Buffalo Chips 

 

Comment #4: So PM 2.5 is different than PM 10, correct? 

Response: Yes. PM10 particles are less than 10 microns in diameter (PM10). PM2.5 is 

a subset of PM10 including fine particles that are less than 2.5 microns in 

diameter (PM2.5). According to the U.S. Environmental Protection Agency 

(EPA), health studies have linked exposure to PM, especially fine particles 

(PM2.5), to several significant health problems. 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 109 

Comment: Is this new in the last 10 years? 

Response: Yes, the first PM2.5 standards were set by EPA in 1997 and recently 

updated in 2006. California also has health standards for PM2.5. 

Comment: Are BBQ’s included in the no burn restrictions?

Response: No. The rule does not apply to cooking, including BBQ’s. 

Comment: How much cleaner are pellet stoves? 

Response: Comparison of Emission Factors 

Technology PM2.5 Emission Factor 

(lb/mmBtu) 

Fireplaces 33.3 

Certified Wood Stove 1.85 

Pellet Stove 0.69 

Propane Fireplace 0.01 

Natural Gas Fireplace 0.01 

Electric None 

Stakeholder Meeting Business Organizations

August 8, 2007, 9:00 am

Attendees: Jon Jeisel, Cleaner Air Partnership 

 Lori Soldano, Asian Pacific Chamber of Commerce 

 Heinz Ludke, Natomas Chamber of Commerce 

Comment: South Natomas has wood burning stoves but North Natomas has a lot 

of gas stoves. I personally have a wood burning stove and I use it a lot, 

but I try to honor the no burn days. 

Response: Thank you for your support. 

Comment: Frankly, wood is very expensive. What’s the number of wood burning 

fireplaces out there? 

Response: The number of uncontrolled fireplaces ranges from about 150,000-200,000. 

For more information see the Emission Inventory section of the Staff report 

on page 7. 

Comment: We have 700 members and we can do the online link and the 

newsletter, but when someone comes and speaks it really hits you. 

Would you come to an event? 

Response: Staff would be glad to attend one of your events. 

Comment: Have we stopped rice burning? 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 110 

Response: Rice burning is only allowed for up to 25% of the crop, and only in the case 

of disease. 

Comment: “Celebrate Natomas” is coming up in September, and this would be a 

great way for you to do some outreach. Last year we had about 3,000 

people come out. 

Response: The District would be glad to have a representative attend your event. 

Comment: What are the restrictions on barbecues that burn on wood? 

Response: None, the rule does not apply to cooking, including BBQ’s. 

Comment: What about backyard fire pits and those types of things? 

Response: All types of outdoor wood burning devices and wood burning fires are 

subject to this rule. 

Comment: Have you thought about doing outreach to students in schools? 

Response: The District does air quality education to schools. 

Comment: I know some other arguments about this rule include quality of life and 

also that this could go a long way to protect our transportation 

funding. 

Response: Thank you for your suggestions. Transportation funding issues are complex 

and related to nonattainment designations. See the discussion of federal 

mandates in the staff report for more details. 

Comment: I was surprised to learn that 45% of air pollution is wood smoke 

Response: See answer to HPBA’s comment #2 on page 117 

Written Comments Received

Comments Received from Andrew Steckel, EPA on July 9, 2007 

Comment: This draft rule is important for regulating wood burning devices and 

we have no recommended changes. If adopted and submitted to us 

as drafted, we would likely propose to fully approve it.

Response: Thank you for your support. 

Comments received from letter from Cynthia Marshall dated July 25, 2007 

Comment #1: Although the rule will not apply to homes whose sole heat source is 

a fireplace, which could only be a handful of homes, the proposed 

rule will affect those of us who try to offset the high cost of using 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 111 

natural gas during the winter months. A half cord of oak at $250 will 

heat the complete front of my 1900 sq. ft. home during the winter 

months using my fireplace with a heatilator insert. This not only 

saves me hundreds of dollars in heating costs, actually if more 

people were using fireplaces, it would help save one of our waning 

natural resources which SMUD and PG & E have made quite clear 

we need to conserve! 

Response: If wood is the only source of heat to a home, then wood burning will be 

permitted. Residents who want to supplement their central furnace heat 

and reduce costs are encouraged to replace wood burning devices with 

gas or propane inserts and/or electric fireplaces. When you compare the 

fuel costs on a heat delivery basis, the fuel costs for these units are less 

than burning wood. The mandatory no burn rule would not apply to gas 

and electric fireplaces, but will affect certified wood and pellet stoves and 

inserts. 

 Thermal Efficiency Fuel Cost per MMbtu 

Fireplace 7% $267.76 

Certified Wood Stove 63% $29.75 

Pellet Stove 76% $20.56 

Propane Fireplace 75% $27.67 

Natural Gas Fireplace 75% $15.07 

Electric Fireplace >99% $23.39 

Assumptions used in calculation: used as primary source of heat, PG&E rates for 

natural gas (2007), SMUD rates for electricity (2006), average cost of cord of wood 

= $215, average cost of pellets = $250/ton, and Cost of propane = $1.899/gallon 

 There will be a version of the rule under consideration that includes an 

economic hardship exemption from the rule. If this version is adopted 

then the Air Pollution Control Officer will consider applications for such 

exemption and consider both the economic circumstances of the 

applicants and the health of neighboring residents when deciding whether 

to grant the exemption.

Comment #2: I have considered purchasing and having an insert installed to help 

curtail the PM from my fires, but until they are more affordable or 

there are significant rebates, they are not feasible at this time. 

Response: In your letter, you indicated that you have considered purchasing an EPAcertified insert to reduce PM emissions from your fireplace. Staff urges 

you to consider using a cleaner burning alternative, including a gas insert 

for your fireplace. There are a number of different options that you could 

consider to help supplement the heat for you house, as shown below. 

The costs in the table are reflective of the cost for the heating device. 

Depending on other factors in your home there would be installation costs 

and additional materials costs. 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 112 

 The District has a program to provide financial incentives for those who 

choose to replace their older wood burning devices with new, cleaner 

devices. The next phase of this program will start September 1, 2007 and 

continue through March 31, 2008. The table below shows some 

approximate cost information and voucher funding available. Also, 

depending on the retailer you use, there may be additional 

retailer/manufacturer incentives. 

 In addition, the District has partnered with the Community Resource 

Project to fully fund replacements in low-income households. You can 

find out more about the incentive program on the District’s Web site at 

http://www.airquality.org/woodstove/index.shtml. 

Comment #3: Sacramento’s air quality is 1000 times worse in the summer months 

when we are experiencing an inversion layer and that certainly can’t 

be blamed on wood burning fires. In fact, your entire list of 

significant health problems from PM are caused by year round poor 

air quality, not solely from wood burning fireplaces as your report 

would suggest.

Response: The air quality problems in our county are different in the summer and 

winter seasons. Poor air quality in the summer season is due to high 

concentrations of ground-level ozone, while the air quality problems in the 

winter season are caused by high concentrations of particulate matter 

(PM). The graph below illustrates the average monthly concentration of 

fine PM through out the year and as can be seen, the PM levels are the 

highest during the winter months. We agree that summertime ozone has 

serious health consequences. Many studies report that there are serious 

health consequences, aggravated asthma, heart attack, and even 

premature death, shortening lives by as much as 14 years, from 

particulate matter. Ozone’s impact on premature death is only recently 

being identified. Clearly, the combined health effects of both pollutants 

 

18 Installation costs are pretty similar $350-500 and additional material costs had a wide range 

from $250-1000 depending on the specifics of the installation. Installation and material costs for 

electric fireplaces are 0-$75. 

 Cost of Devices Voucher incentive 18 Thermal Efficiency Fuel Cost 

$ per MMBtu Non-EJ EJ 

Wood Stove $600-2900 63% 29.75 $250 $400

Wood Insert $1100-3000 63% 29.75 $250 $400

Gas/Propane Stove $1000-2700 75% 27.67 $350 $500

Gas Insert $1400-3500 75% 15.07 $350 $500

Pellet Stove $1200-4100 76% 20.56 $350 $500

Pellet Insert $1400-3800 76% 20.56 $350 $500

Electric fireplace ~$300 >99% 23.39 $0 $0 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 113 

require attention. 

The largest source of PM in the winter months is the burning of wood, and 

the proposed rule is the most effective control measure to reduce PM 

concentrations. Voluntary curtailment will not result in emission 

reductions sufficient for Sacramento County to achieve federal and state 

air quality standards for PM. 

Comment received from e-mail from Laurie Pirini on July 31, 2007 

Comment #1: I am a hearth retailer from South San Francisco and I would like learn 

more about how I can help the counties in my area learn about the 

incentive funds you have developed to change out old and dirty wood 

stoves to cleaner wood stoves.

Response: Only Sacramento County residents are eligible for our incentive funds. 

Information about our program can be found at: 

http://www.airquality.org/woodstove/index.shtml

 The Bay Area Air Quality Management District covers the San Francisco 

area. You can reach them at 

 Bay Area Air Quality Management 

939 Ellis Street 

San Francisco, CA 94109 

(415) 771-6000 

 http://www.baaqmd.gov/

Seasonal PM2.5 Pollution

PM2.5 Levels Are Highest in November, December, January and 

February

0.00

5.00

10.00

15.00

20.00

25.00

30.00

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Average Monthly PM2.5 Concentration (μg/m3)
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 114 

Comment #2: When you have “No- burn” days, should it only apply to those folks 

with non-EPA certified devices? 

Response: See response to Comment #1 from Karen Pitts on page 106. 

Comment received from e-mail from Scott Waldmire on July 31, 2007 

Comment #7: I support the adoption of the rule. I have complained about smoky 

winters for at least 15 years. Wood smoke irritates my eyes, nose, and 

lungs. 

Response: Thank you for your support. In addition to the health concerns noted above, 

people with heart problems are also at risk. Serious health effects, including 

premature death have been attributed to particulate matter pollution, 

including wood smoke, have been identified through a number of health 

studies. Young children and the elderly are particularly at risk, but healthy 

people are also impacted. 

Comment received from e-mail from Al Bradley on July 31, 2007 

Comment: Many folks in Oak Park have limited income and their homes are 

modest in size and their fireplaces do provide a way to heat their home. 

 Proposed Rule 421 unfairly targets those who are poor or who need 

their money for other needs. Perhaps an exception from the rule could 

be included for those who have furnaces but choose to use wood to 

balance their budget. 

Response: The Aurora study reported that low income residents are less likely to own 

wood burning devices or to burn wood. Our study shows it costs less to use 

other fuel sources. However, Staff has included in the proposed rule a 

hardship exemption for qualified candidates as an option for the Board of 

Directors to consider. 

Comment received from e-mail from Dan Jacobson on August 1, 2007 

Comment: I am against the rule going into effect. People should be allowed to 

burn in their fireplaces as well as make popcorn and cook. If you want 

to cut down on this type of pollution, do not allow anymore homes to 

be built with fireplaces!

Response: The District adopted Rule 417 in 2006 that banned the installation of 

uncertified wood burning devices in homes and business in Sacramento 

county beginning on October 26, 2007. 

Comment received from e-mail from Ross Westpaal on August 2, 2007 

Comment: We don’t need more government regulations; find another way to solve 

this problem!
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 115 

Response: The District is mandated to reduce the amount of particulates in the air. 

There in no one solution to the problem and many other sources including 

cars and trucks are already controlled. However, the PM2.5 levels in the 

county are still above the federal guidelines because wood burning is largely 

unregulated. Staff recommends this rule as the most effective way to 

achieve a significant reduction in ambient PM2.5 levels with the least impact. 

Comment received from Alex Krichevsky, CARB on August 2, 2007 

Comment: ARB Staff has reviewed the rule and, based on the information 

available to us at this time, we have no comments. 

Response: Thank you. We have appreciated having ARB health staff available at 

public meetings to answer health questions. 

Comment received from e-mail from Kathie Schievelbein on August 3, 2007 

Comment: I am opposed to the implementation of Rule 421. I purchased a wood 

stove two years ago to reduce my winter heating bills. I did 

considerable research before deciding to go with a wood stove to help 

heat my home and still give me the ambiance a fire brings on a winter 

day. There has been a significant reduction in the cost of my heating 

bill. I conserve energy where possible, car pool to work and 

telecommute once per week. When a notice is issued to not burn, I 

comply without hesitation.

Response: Staff appreciates your efforts to conserve energy and reduce pollution. 

Sacramento County is not in compliance with federal 24-hour PM2.5 

standards, and state PM10 and PM2.5 standards. Accordingly, we must 

reduce emissions, particularly on days with the highest PM concentrations. 

Staff believes this rule is the most effective measure to do so. 

Comment: I found the Aurora research report inconclusive. Education should be 

the driving force to change public attitudes not mandatory no-burn 

regulation. Enforcement programs are ineffective. Please keep the 

voluntary no-burn days in effect and implement awareness programs 

to educate and fully encourage voluntary no-burn days.

Response: District staff has, and will continue to educate the public on the wood smoke 

issues and what people can do. However, the District violates the federal 

24-hour PM2.5 standard, and is therefore obligated to consider rules to 

reduce particulate emissions. The Aurora study reported that 27% reduction 

in wood smoke emissions resulted from voluntary program last year. That is 

not sufficient to meet air quality standards. 

 Mammoth Lakes and the San Joaquin Valley are two examples of areas 

reporting air quality improvements after implementing mandatory no burn 

programs. 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 116 

Comment received from e-mail from Charlea Moore on August 3, 2007 

Comment: I would really appreciate having a workshop closer to Elverta, Ca. 

Response: Staff contacted the commenter to share the information that was available to 

the public at the open houses. 

Comment received from Andrew Gwin on August 7, 2007 

Comment: I’m an elderly with seasoned wood available to me at no charge. Tour 

buses, by the dozens leave California daily to casinos; up to 10,000 can 

travel to Arco, thousands of cars can travel all for their recreation. Let 

me have my fireplace. Let’s all “play on a level field.” 

Response: Buses and cars have been regulated for many years to reduce the 

particulate matter emissions. Wood burning emissions are largely 

unregulated. Reducing wood burning only on those days that air quality 

exceeds the health standards can protect your health and the health of the 

community. Staff is proposing an option for the Air Pollution Control Officer 

to grant hardship exemptions to households where prohibiting solid fuel 

burning would cause economic hardship and the granting of the exemption 

would not have an adverse impact. 

Comment received by e-mail from Simon and Cathy Sucharski on August 9, 2007 

Comment: We are concerned about the application of Rule 421 to certified wood 

burning and pellet fireplace inserts. We installed a wood burning 

insert two years ago to burn wood more efficiently and to reduce the 

emissions from our fireplace. We believe it is unfair that those of us 

that have installed such devices will be restricted as if we were burning 

an open fireplace. We request that the board include a provision to 

allow the use of certified devices and pellet stoves/inserts. 

Response: See response to Comment #2 from the oral comments at the July 26, 2007 

open house at the SMAQMD office on page 104. 

Comment received from John Ryan on August 10, 2007 

Comment: If the AQMD is going to have monetary incentives for people to change 

out their old appliances, and then ask them not to burn this becomes a 

disincentive. The Board should consider exempting EPA certified and 

pellet stoves from the rule. 

Response: See response to Comment #2 from the oral comments at the July 26, 2007 

open house at the SMAQMD office on page 104. 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 117 

Comments received by e-mail from John Crouch, HPBA on August 10, 2007 

Comment #1: We believe that stating the rule “might” help avoid designation is 

spurious.

Response: The Legal Mandates section (page 3) of this staff report has been revised to 

clarify the options for avoiding certain requirements that would come with a 

designation of nonattainment. 

Comment #2: We do not believe the percentage of PM2.5 attributed to wood smoke is 

accurate. If it is, does the rule go far enough? 

Response: The California Air Resources Board is responsible for preparing the wood 

burning emission inventory for Sacramento County. CARB estimates are 

based on a 1987 survey conducted in Healdsburg, California that suggested 

that 0.28 cords of wood is burned per household per year. More recent 

surveys19 in Sacramento indicate usage is 0.92 cords per year. If this data 

were used the contribution would be 72%. To properly compare 

Sacramento’s wood smoke emissions to other areas, it’s necessary to 

convert inventory percentages, which can be affected by emissions in other 

categories, and total emissions in tons/day to a per person or per housing 

unit emission rate. The table below summarizes the emission rates for 

several areas. The comparison shows that Sacramento’s emissions are 

reasonable given its population and climate20 

County 

Total 

Wintertime 

Emissions 

Inventory 

Wood Smoke 

Wintertime 

Emissions 

(tons/day) 

Wood Smoke 

Emissions 

per capita 

(lbs/personday) 

Wood Smoke 

Emissions per 

housing unit 

(lbs/housing 

unit-day) 

% PM2.5 

Inventory 

from Wood 

Smoke 

Butte County 10.12 4.77 0.044 0.120 47% 

Sacramento County 17.09 8.37 0.012 0.032 49% 

Fresno County 29.28 4.98 0.011 0.034 17% 

Placer County 11.96 6.53 0.040 0.094 55% 

Seattle (King County) 

Washington n/a 9.32 0.010 0.024 63%21

Nevada County 11.96 9.54 0.193 0.394 80% 

Kern County 29.92 3.90 0.010 0.031 13% 

Contra Costa County 15.92 4.72 0.009 0.025 30% 

San Joaquin County 12.77 3.19 0.010 0.030 25% 

 Additionally, data collected22 from the air monitoring stations on a small 

 

19 Houck, James. 2003. “Results of Wood Burning Survey – Sacramento, San Joaquin, and San 

Francisco Areas, University of California Berkeley/California Air Resources Board – GIS Study” 

20 Emission information for California counties came from PM2.5 2006 winter emissions from 2007 

CARB Almanac at www.arb.ca.gov/app/emsinv/fcemssumcat2007.php. 2006 population data and 

2005 housing units came from Census data, www.quickfacts.census.gov/qfd/states/06/06007.html

21 Puget Sound area, “Next Ten Years Fact Sheet – Fine Particulate Matter” 

22 “Final Staff Report SB 656 Assessment and Control Measure Evaluation”, SMAQMD, July 28, 

2005 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 118 

sample of high particulate matter days suggests that the directly emitted 

portion of the ambient filter samples is 37%. Some unknown fraction portion 

of the aerosol components (ammonium nitrate and ammonium sulfate) 

cannot be ascribed to any individual source category, but would include 

some fraction of NOx from wood burning. 

 The District is committed to achieving all federal and state PM standards. 

This rule is not the only measure being considered to reduce PM2.5 

emissions. SB 656 measures included other wood burning reduction 

strategies. This rule is expected to have the most impact, and may achieve 

enough reductions by itself. If it does not, additional wood smoke measures 

and other PM measures will be considered. 

Duraflame comments

Comment #1: Targeted Rule Compliance is overstated. Rule will likely result in 

curtailment every weekend and major holiday in the winter. This will 

cause non-compliance. The stated 78% compliance rate is flawed, as it 

is drawn from all household capable of burning wood and not from 

“burners”. 

Response: The historical data does not indicate any pattern that would indicate that 

curtailment days would occur in any greater concentration on weekends or 

holidays. Roughly 56% of the days over the threshold were weekdays, while 

44% were on weekend days. There was no discernable pattern concerning 

holidays. The largest contributing factors to PM levels are temperature and 

weather patterns, which are subject to much fluctuation. 

 As was noted in Aurora’s report, although levels of support for the adoption 

of a mandatory no burn rule were different between burners and nonburners, the levels of hypothetical compliance were relatively the same 

between burners and non-burners. When San Joaquin Valley APCD 

adopted their mandatory no burn rule they assumed a compliance rate of 

80%. Staff has taken the 78% compliance rate from Aurora’s phone survey. 

The rule estimates have been based on the number of households that 

would have a wood burning device and an average wood usage per home. 

Some households burn very little wood and some households burn 

significantly more wood than the average. It is appropriate to use the Aurora 

hypothetical compliance rate for households that own a wood burning 

device. The commenter did not provide an alternative rationale or data 

source for compliance rates. 

Comment #2: Promoting increased use of natural gas, as a substitute for wood 

burning, will result in a dramatic increase of non-renewable green 

house gas emissions. Since the State of California has recently 

mandated significant decrease in green house emissions over the next 

ten years, the district’s current policy to promote an increase in natural 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 119 

gas fireplaces and heating stoves is flawed policy that is likely to face 

further limitation or regulation in the near future. 

Response: State law, AB32, California Global Warming Solutions Act of 2006 requires23

the state board to consider the time period for the emissions, 

"If applicable, the greenhouse gas emission reduction occurs over 

the same time period and is equivalent in amount to any direct 

emission reduction required pursuant to this division" 

and ensure that greenhouse gas regulations do not interfere with efforts 

to achieve health-based air quality standards. AB3224 specifically states 

that the state board shall, 

"Ensure that activities undertaken pursuant to the regulations 

complement, and do not interfere with, efforts to achieve and 

maintain federal and state ambient air quality standards and to 

reduce toxic air contaminant emissions." 

 Therefore, AB32 health-based requirements are consistent with Rule 421 

objectives since reduction in wood burning contributes significantly to PM2.5 

air quality problems and Rule 421 is necessary to attain federal and state 

ambient air quality standards for PM2.5. 

 See also the response to Comment #3 from Karen Pitts for a discussion of 

greenhouse gas emissions in general. 

Comment #3: The District should offer compliance incentives, such as allowing clean 

burning devices to be used during curtailment. Other districts have 

been able to offer two stage programs, and advocate use of 

manufactured fire logs.

Response: See response to Comment #2 from the oral comments at the July 26, 2007 

open house at the SMAQMD office on page 104.

 Based on the analysis done during the Rule 417 adoption, staff does not 

endorse manufactured fire logs. If Duraflame feels their new products have 

changed their burning profile, they may submit emission test results for the 

new products for additional consideration. 

Comment #4: The emissions inventory is incorrect. Why is the 2007 survey not used 

to calculate emissions? 

Response: Staff has revised the staff report to better describe the emissions 

calculations including using data from the 2007 Wood Burning Survey. 

Sacramento specific survey results suggest that the emissions inventory is 

 

23 Health and Safety Code Section 38652(d)(3) 

24 Health and Safety Code Section 38562(b)(4) 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 120 

higher than prior CARB estimates. 

 See also response to Comment #2 from John Crouch, HPBA, page 117 

Comment #5: Further analysis is required. It is unrealistic to assume that this rule 

alone will meet the federal PM2.5 standard. 

Response: Mammoth Lakes and SJVUAPCD reported 30% improvements in air quality 

following implementation of similar mandatory no burn rules. A 30% 

improvement in air quality is needed for Sacramento to attain. This data and 

the significant contribution from wood smoke indicate that reductions in 

wood smoke are critical to Sacramento's attainment efforts in the near term. 

 Air quality is determined by complex interaction between weather conditions 

and emissions. It is impossible to project the future of those variables with 

certainty. As to whether this rule alone is successful enough to result in 

attainment, that remains to be seen, but if one strategy can do it, information 

currently available to staff suggests that this is it. 

Comment #6: A higher threshold will raise compliance rates. SJVAPCD uses a 

higher threshold and exempts manufactures logs from curtailment on 

voluntary days. 

Response: Staff would welcome information that substantiates this assertion. However, 

a threshold higher than 35 μg/m3 will mean that some days that are predicted 

to exceed the federal air quality standards will not benefit from reduced 

wood burning and may result in Sacramento being designated nonattainment. SJVACPD’s curtailment program was developed to help attain 

the federal PM10 standards (but used the 1997 PM2.5 standards for 65 

ug/m3

 health standard as a basis for the threshold.) The SJVAPCD does 

exclude manufactured logs from voluntary no burn days, but prohibits 

burning manufactured logs on mandatory no burn days. 

Comment Received by e-mail from David Smith on August 28, 2007 

Comment: While I understand the need to manage particulate matter on certain 

cold days, I find it highly deceptive to publish your notice of the 

hearing to address what is essentially the curtailment of using one’s 

wood burning fireplace during periods of low air quality. While I 

understand the that Board is attempting to cover other, lesser 

known devices other than a fireplace, the Notice should have at 

least included wording illustrating the most common example: the 

wood burning fireplace. At least tell the public what’s really being 

done, and don’t hide the purpose in some bureaucratic euphemism 

that is meaningless to many. 

Response: Staff re-titled the rule to make it clear that the rule applied to more than 

just wood burning but also included pellets and manufactured logs. 

However, in response to this comment, staff proposes to revise the rule 

title to "wood and other solid fuel" burning. 
Staff Report 

Rule 421 

Appendix E 

September 7, 2007, Page 121 

Comment Received by e-mail from LJ Laurent on August 28, 2007 

Comment: Excellent idea to curtail burning as required for air quality. I think 

this rule should be extended to more months because the air quality 

is a health issue during more months than November through 

February. Please recommend extending the times this rule applies. 

We need it. 

Response: Thank you for your support. Staff proposes to address only late fall and 

winter months only because data shows this is when particulate matter is 

at its highest. In addition, see the graph of monthly air quality data 

provided in response to Comment #3 for Cynthia Marshall’s comment 

dated July 25, 2007 on Page 112. 

Comment Received by e-mail from Lea Brooks on September 3, 2007 

Comment: I strongly support this rule. I am a longtime bicycle commuter and 

am very concerned about the health effects of particulate air 

pollution from wood burning. The pollution is very noticeable 

during my commute to and from work on the American River 

Parkway bike trail and in my neighborhood during the winter 

months. I very much appreciate the AQMD’s efforts to control this 

pollution. 

Response: Thank you for your support and contributions to reduce pollution through 

your commuting choice. 

Comment received by mail from Sacramento Area Bicycle Advocates on September 5, 

2007 

Comment: The Sacramento Area Bicycle Advocates strongly supports 

measures to combat particulate and all other forms of air pollution 

year round. Engaging in frequent and long durations of physical 

activity, cyclists experience poor air quality first hand. Poor air 

quality not only turns existing cyclists into victims, it discourages 

potential cyclists. 

Response: Thank you for your support and contributions to reduce pollution through 

your commuting choice.