A-1 

Appendix A. Copies of all written comments 

From: Alene Lindstrand [mailto:collie_mamma@msn.com] 

Sent: Friday, April 10, 2015 3:16 PM

To: Ekrem, Joanna (ECY)

Subject: Wood and pellet stove new requirements 

Joanna Ekrem,

 I am writing to you because I am greatly unhappy with new countywide woodstove 

burning ban standards recently lowered by the EPA. After attending a public 

meeting held here in Spokane April 2nd, it is outrageous to even begin to 

comprehend, as we were told, that Spokane County needs to meet EPA statewide 

standards EVEN THOUGH WE HAVE HAD NOT BEEN OUT OF COMPLIANCE since 1995, and 

additionally, Washington state has the highest clean air standards in the 

nation!! So, we need to meet even stricter and more draconian rules "just 

because." This does not make sense to meet some standard you've been exceeding 

all along! 

 Let's get serious here: this will put a big burden on those who use the 

renewable resource of wood to heat their homes, primarily, and also as a backup. 

What's the burden for them? Lowered particulate matter BY MORE THAN HALF will 

result in practically ALL banned burning days, just a very few. Exemptions COST 

money. Fines COST money. Ripping out and replacing new, DoE standards for 

woodstoves COST A LOT of money, selling a non-compliant wood stove will be FINED 

at $10,000. How can the DoE be taken seriously when they aren't using any 

reasonable standards or measurements (because we already exceed standards that 

they want even lower) "just because." Where's the SCIENCE? and I am not 

referring to modeling, which is only one tiny part of a multitude of data that 

needs to be gathered and processed, along with peer reviewed scientific data. We 

were told this new standard will be for the "health" of the people. Again, 

where's the scientific data, and who put it together (name, degrees, books 

written, bias held)? Where's the discussion of long term consequences, such as, 

NO ONE will be able to use a wood stove by 2020 since the standards will be 

stricter than nature even. Is the DoE attempting to play God, is nature is not 

"good" enough for them? Good management and the best scientific uses WILL look 

at long term consequences, and that is not being done. I would be happy to have 

your explanation since there was nothing reasonable explained at the meeting.

 My goal is to attempt to communicate with you clearly, but I have a strong 

suspicion that, while my words are defined in Webster's Dictionary, the DoE's 

words have quite different meanings and I don't know their definitions. 
A-2 

 Please DO NOT enforce these lowered impossible standards upon us because we 

ARE in ambient air compliance and PEOPLE MUST COME BEFORE a bureaucracy's rules 

that don't make any sense and don't HAVE THE FACTS behind the rules.

Sincerely,

Alene Lindstrand, Realtor, SRES

Century 21 Beutler & Assoc.

509-869-7657

Realtor To The Young At Heart!
A-3 

From: Bill Demers [mailto:redoakarts@yahoo.com] 

Sent: Wednesday, March 18, 2015 10:10 PM 

To: ECY RE AQComments; ECY RE AQComments 

Subject: Wood burning stoves in Spokane County 

My name is William N Demers, PO Box 30217, 10220 S. Sharon Rd. Spokane, WA 99223

I am 55 years old and suffer from severe Osteo and Rhumatoid Arthtitis and Neuropathy from 

Guliiian-Barre' Syndrome. In fact these malady's are severe enough to make me disabled with 

SSDI my sole source of income. In Winter I am at times restricted to a wheel chair.

I depend on my wood stove for heat as a form of documented medical treatment for pain relief. 

Internationally wood heat is well known remedy for pain relief. I am unable to receive pain relief 

comparable with wood heat. I use an EPA certified stove and burn dry wood so as to prevent 

smoke. But in the end I will not comply with any regulations attempting to stop me from using 

my stove for pain relief. Because of my fixed low income wood heat is the only remedy I can 

afford. Candidly the only way the State can stop me from burning wood for pain relief is to take 

me away in a body bag.

Benefits of Heat Therapy for Lower Back Pain

Benefits of Heat Therapy for 

Lower Back Pain

Explore how heat therapy interacts with the 

body to alleviate pain as well as options on 

how to apply heat therapy to help alleviate 

many types of lower back pain.

View on www.spine-health.com Preview by Yahoo
A-4 

From: Bill Demers [mailto:redoakarts@yahoo.com] 

Sent: Saturday, March 21, 2015 2:10 PM 

To: Bellon, Maia (ECY); Bellon, Maia (ECY) 

Cc: Mrs Lieitz; fcbetts@q.com; ramremfg@aol.com; mpjanson@msn.com; hrpigmee@asisna.com; 

evandboss@aol.com; soquinn@spokanecounty.org; mpepper4@hotmail.com; 

bettyboop4344@yahoo.com; tayeetah@hotmail.com; jbeach@capitalpress.com; Gordon & Linda; 

Dennis Bly; Rene Holiday; Cody Raulston; Scott Neilsen; John Simmons; Peter Davenport; Mike & 

Connie Smith; Holy, Jeff; khempaulson@msn.com; Toni; thegadys@gmail.com; djmoore@pionnet.com; 

skoogzoo@yahoo.com; jim@reiffmolding.com; kskoog@pendoreille.org; steve@snrcompany.com; 

razsqh@stjohncable.com; weezelhead@comcast.net; rholaday7@gmail.com; Blake, Brian; 

mikebaker2781@msn.com; radcen52@yahoo.com; secretary@okanogancountyfarmbureau.com; Steve 

Neill; Cindy Alia; Pat L. ; editor@westernagreporter.com ; dboleneus@infomine.com ; Glen Morgan; 

edit@rangemagazine.com ; Mike Lashaw; Baumgartner, Michael; Grady Houger; capper@wsu.edu ; Jude 

Capper; Mike Poulson; dkgoodwin@reagan.com ; Derek Dill; Pamela Leslie; bj672bbq@gmail.com ; Dan 

and Gloria Clark; Alene Lindstrand; Jim Wentland; dkhansen631; chance Gowan; hudsont@wsu.edu ; 

jmorrow@ij.org ; Tip Hudson; ECY RE AQComments; zinniadaze@gmail.com; Russell Emtman 

Subject: Another document that shows how Political Agendas supersede science in policy in Washington 

State 

Dear Director Bellon, Spend the time and a few tax dollars to read and learn the truth about 

Global Warming, then implement knowledge/science driven decisions while directing your 

agency. The current agenda driven policies of DOE waste money, energies and produce a 

worsened environment. Not to mention a despicable assault on Liberty.

AMS Journals Online - Journal of Climate - 0(0): - PDF

AMS Journals Online - Journal of 

Climate - 0(0): - PDF

If you are not a journal subscriber and you 

wish to purchase an article or use other 

features on the site, you must first Register at 

AMS. Benefits of registration ...

View on journals.ametsoc.org Preview by Yahoo

Thanks

Bill Demers
A-5 

From: Bryce Morrison [mailto:brycemorrisonspokane@gmail.com] 

Sent: Tuesday, March 03, 2015 1:01 PM 

To: Ekrem, Joanna (ECY); ECY RE AQComments 

Subject: FW: Infrastructure_Rules_and_Programs_SIPs 

Because I noticed that the ecy.wa.gov website did not automatically include your email address, I am resending the below message to you as well, since you were mentioned in the message. 

If you have any information which we should distribute to our neighborhood in Spokane, please let me 

know. If you would like to arrange for a local contact in Spokane to speak at our neighborhood council 

regarding any changes that would impact them, I would like to connect you with our neighborhood 

council and steering committee’s president.

Thank you, 

Bryce Morrison 

Secretary, Emerson-Garfield Neighborhood Council 

From: Bryce Morrison [mailto:brycemorrisonspokane@gmail.com] 

Sent: Tuesday, March 3, 2015 12:55 PM 

To: carl@spokanecleanair.ccsend.com

Cc: lahu461@ecy.wa.gov; jekr461@ecy.wa.gov; acau461@ecy.wa.gov; 

mchambers@spokanecleanair.org

Subject: Infrastructure_Rules_and_Programs_SIPs 

Regarding the http://www.ecy.wa.gov/programs/air/sips/plans/infrastructure.htm webpage and the 

Message sent by Carl (carl@spokanecleanair.ccsend.com) regarding the Notice of Public Comment 

Period on State Air Quality Plan, sent on Monday, March 2nd (included below), I believe it would be 

helpful to direct the public (including myself) to a less formal explanation of how the proposed changes 

would impact the general public. 

If there would be any changes that would impact the public (such as the use of the burning conditions 

website), perhaps an article could be posted on our neighborhood’s website, or a speaker could be 

invited to give a presentation at our monthly neighborhood council meeting (averaging 40 attendees). 

Thank you, 

Bryce Morrison 

Below is the email I am referring to: 
A-6 

March 2, 2015

Public Notice/Comment Period on State Air Quality Plan

Ecology is seeking comments on a proposed revision to an air quality plan, called a State 

Implementation Plan (SIP). The proposed revision is to update Spokane Regional Clean Air 

Agency's revised regulations for solid fuel burning devices in the Washington SIP. This revision to 

the SIP is required to meet federal requirements from the U.S. Environmental Protection Agency, 

and is designed to reduce wood smoke emissions and maintain compliance with federal air quality 

standards within Spokane County. 

You may review and comment on the proposed plan revision March 2, 2015 through April 3, 2015.

The document is available for review 

at:http://www.ecy.wa.gov/programs/air/sips/plans/infrastructure.htm. 

To comment on the plan revision or to request a public hearing:

 email AQComments@ecy.wa.gov

 mail comments to: Joanna Ekrem, Air Quality Program, Washington State Dept. of

Ecology, P.O. Box 47600, Olympia, WA 98504-7600

For more information or to request a public hearing, contact Joanna Ekrem at (360) 407-6826 or 

joanna.ekrem@ecy.wa.gov. Requests for a public hearing must be received by March 23, 2015. 

If a hearing request is received by the deadline, it will be held at 9:30 a.m. on April 2, 2015, at 

Spokane Regional Clean Air Agency office: 3104 E. Augusta Avenue, Spokane, WA 99207. If a 

hearing request is not received, Ecology will announce a cancellation of the April 2 hearing on its 

public involvement calendar.

For more information visit www.SpokaneCleanAir.org or 

http://www.ecy.wa.gov/programs/air/sips/plans/infrastructure.htm.

Forward email

This email was sent to brycemorrisonspokane@gmail.com by mchambers@spokanecleanair.org | 

Update Profile/Email Address | Rapid removal with SafeUnsubscribeTM | Privacy Policy.
A-7 

Spokane Regional Clean Air Agency | 3104 E. Augusta Avenue | Spokane | WA | 99207
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From: Christine Keck [mailto:ckeck12@yahoo.com] 

Sent: Monday, April 06, 2015 3:03 PM 

To: ECY RE AQComments 

Subject: SFBD rule to EPA for approval in Washington's SIP? 

Dear Sirs:

Should Ecology submit the revised SFBD rule to EPA for approval in Washington's SIP?

I say -NO!

I am not happy with the attempt to force such strict particle emission standards upon us who have 

wood burning products to heat our homes.

I have been a very careful wood as an energy source use all of my over 60 years. I have been and still am 

as careful to burn cleanly as possibly can manage. It is part of our areas culture, my preference as to 

heating style and the extreme measure you are considering would put my family in GREAT financial 

burden to try to change to a non-wood source of heat. All human consumption on planet earth is NOT 

all harmful and should not be treated as such. A more REALISTIC amount of particulate is what I am 

asking you to look into for regulations. The EPA tends to go to extremes and behaves to the public as if 

they(epa) are always the only way and the public are just dummies. We are not and we can only do so 

much in reality. 

Please do not just "jump off the deep end " as the saying goes and automatically go along with any new 

rules-think and research how much as a real breathing person not just a graph I can do to burn clean 

but still be warm!

Thank you,

Christine Keck
A-11

From: zapox6@afo.net [mailto:zapox6@afo.net] 

Sent: Friday, April 10, 2015 3:50 PM

To: Ekrem, Joanna (ECY)

Subject: Regarding air quality standards in Spokane County

Dear Ms. Ekrem:

I attended your hearing on April 2nd regarding the adoption of the EPA SIP 

revision plans that the EPA is requesting for approval in Spokane County. I 

appreciate the information you gave us and the opportunity to input my opinion. 

Since Washington State and Spokane County are currently within the particulate 

levels that the EPA has put in place, I fail to see why our citizens here should 

be pressured to meet new lower standards that are unscientifically substantiated 

as a threat to our health. In my view, we do not need any more "Burn bans" in 

Spokane County. We do not need to force people to tear out stoves or other wood 

or pellet burning devices that keep them warm. We do not need inspectors knocking 

on the doors of our citizens because the color of the smoke coming out of their 

chimneys is "suspect". 

This constitutes an over zealous government abusing the rights of our citizens to 

privacy and freedom from needless harassment from agency officials. 

There is real danger in our county submitting the SIP revision plan that EPA is 

requesting for their approval. Please don't do it!!! (Right now Spokane County 

is NOT under EPA authority on the SIP implementation plan.) Your staff admitted 

at the hearing that SHB2326 (passed in 2012) gives to DOE "enforcement 

capabilities" thru working with "other agencies" including the County Sheriff's 

Department. There are also fines possible for selling a stove alluded to in one 

of the D.O.E. brochures titled "Which wood burning devices can be sold in 

Washington?". A citizen could be fined as much as

$10,000 for selling a non compliant stove. (Most stoves sold commercially in 

recent years are complying with the current 4.5 standard NOT the "new" 2.0 

standard. Many of us have purchased these stoves recently, and they were not

cheap.) 

New lower EPA standards went into affect nationwide April 3, 2015. 

(Washington already has the highest clean air standards in the nation.) Stove 

emissions--which includes pellet stoves-- must currently be below 4.5 grams of 

particulates per hour --the new standards will be lowered every year to 2.0 grams 

of particulates per hour by 2020....such a tiny amount according to local 

scientist Dave Boleneus as to be laughable as being labeled "dangerous". (Where 

is you science?) Consequently, no one will be able to use a wood stove by then. 

I am very, very concerned about this issue. SPOKANE 

COUNTY ALREADY MEETS OR EXCEEDS CURRENT NATIONAL AMBIENT AIR QUALITY STANDARDS. 

DOE and SCRPA inspections will be possible after Jan. lst 2016, and stoves could 

be torn out of private homes or rendered inoperable as in Oregon. This could be 

done without the "due legal processes" that are guaranteed not only under our 

U.S. Constitution but under our State Constitution. Remember, you are supposed to 

be protecting the citizens of Spokane County, not harassing and hurting them. 
A-12

Cindy Zapotocky--Spokane County Citizen 

1728 E. Rockwood Blvd.

Spokane, Wa 99203

509-534-5707 
A-13
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From: Clarice Ryan [mailto:clariceinmt@gmail.com]

Sent: Thursday, April 09, 2015 2:03 PM

To: Ekrem, Joanna (ECY)

Subject: SPOKANE CAPR ALERT: Wood stoves Restricted

Dear Joanna,

WA STATE DEPARTMENT OF ECOLOGY

We in Montana strongly urge opposition to restrictions on use of wood burning 

stoves. Low income families would be seriously harmed by stringent requirements 

which might force them to purchase new stoves or even to refrain from wood heat. 

Apparently CO2, smoke, ash and burned animal carcasses from wildfires of USFS 

OVERGROWN forests are not being considered a problem from a pollution 

standpoint.

However, firewood collectors (not allowed to collect dead fuels from these 

federal forests) attempt to find enough firewood elsewhere to sell to customers 

struggling to reduce their heating costs. Now federal restrictions prevent 

homeowners from benefitting from burning the waste from dead and dying forests 

that could be providing heat for their homes. Limits on use of firewood for 

heat, in my mind constitutes and injustice to citizens by their own government, 

for no valid constructive reason. 

If concerns over missions from these stoves, is being largely based upon CO2 

production, we should acknowledge that it is far below what is happening 

naturally in the environment: forest fires, volcanoes, and respiration by all 

living creatures on earth. The science has not yet proven that global warming 

has been caused by CO2, or even that Climate Change has resulted from it. 

Climate has changed since the formation of the earth and the origins of humanity 

living on it. All of these unproven concepts are negatively impacting the 

economy of our communities and the entire country, basically the world.

Clarice Ryan

253 Pine Needle Lane

Bigfork, Montana, 59911 406- 837-6929

________________________________________________________________________--

WOOD STOVE STANDARDS IN SPOKANE ARE ABOUT TO CHANGE: Your input is urgently 

needed by this Friday, April 10th. See attached the CAPR Spokane letter that was 

submitted at the Spokane County Clean Air Agency hearings recently. See also the 

excellent video made by John Charleston of one of those hearings....

THE STATE DEPARTMENT OF ECOLOGY WILL ONLY TAKE COMMENTS THROUGH THIS COMING 

FRIDAY APRIL 10TH......SEND EMAILS TO Joanna.ekrem@ecy.wa.gov Thanks Clarice. You 

will also be impacted, since the EPA has national standards which will be 

inflicted on everyone.....even if you live in a pristine area of Montana. Check 

out the federal register Feb 3, 15 notice about wood stoves by the EPA.

I hope you will attend our May 22 dinner an workshops.

Gloria
A-18
A-19

From: David Boleneus [mailto:boleneus@gmail.com]

Sent: Friday, April 10, 2015 10:13 AM 

To: Holy, Jeff; Parker, Kevin; Shea, Matt; Judith.warnick@leg.wa.gov; Baumgartner, Michael; Schoesler, 

Mark; Doug@SenatorEricksen.com; Ekrem, Joanna (ECY); Dan and Gloria Clark; redoakarts@yahoo.com

Subject: pm 2.5 

I submitted similar comments to Ecology yesterday re: the lowering of particulate material size on wood 

stoves from pm 10 to pm2.5. Here I have made some changes and so am re-submitting them again with 

corrections. Today is the deadline for submitting comments. This process seems ill-publicized and 

hurried? Is that with conscious intent so as not too involve too many that would be as enraged as I if they 

were given the opportunity to understand the impact of this new standard?

Topic item:-emission level greater than 35 microgram per cubic meter (ug/m3) is considered a 

violation of the clean air act, or pm>2.5 represents a violation.

I have many and very serious complaints about this limit but I will try here to include all. I don't have 

time to do my job, which my employer prefers, do your job too, and counter or submit all comments in 

organized prose, so here goes. 

What is the limit, one or both: 35 ug/m3 or pm2.5? (there are more questions below)

You mentioned that emissions that exceed the limit of 35 micrograms per cubic meter are in violation of 

the clean air act but in your next breath you say the limit is pm 10 or pm>2.5. A microgram is a measure 

of mass where the pm 2.5, which is 2.5 microns (a millionth of a meter) is a measure of length. Do you 

know this difference? You confuse these measures. They are not the same. 

Also if you are confused, as seems apparent from your casual acceptance of this limit, which I consider 

extremely egregious, it is also then impossible for you to communicate the very serious concerns and 

the meaning of this limit to the public. 

The first point I want to make is your agency’s cavalier use of this limit of 35 ug/m3 and pm 2.5. Your 

use of these figures is so loose that people are led to believe that its “no big deal" or that it’s of "no 

significance" when it is exactly the opposite. Well it is significant. It’s a really big deal and you do not 

communicate just how incredibly small this particle is. It is so big a deal that this limit will be impossible 

to meet. I do not believe you have a mental concept of how small is this amount. You certainly have not 

communicated this to the public, completed any due diligence, a cost analysis, an analysis of the impact 

upon people, or compared it to other particles or said what impact this will have on peoples 

lives. People want to know what they cannot do it they must meet this standard. Do you know this? 

For example, compared to a cubic meter of rock of average density, since you use this measure, is about 

2600 kg (kilograms or 2.9 tons), the cubic meter of rock contains 2,600 billion micrograms if my 

calculation is correct, but in your third breath you say, without knowing this, that 1/74,000,000,000th 

(one 74 billionth) of this ton represents a violation of the law. What!! Just because today's analytical 

equipment in the laboratory can measure to this level doesn't mean its logical. This demonstrates the 

total ignorance of your words. You believe you can say this but it is obvious you are lacking knowledge of 

its relevance. 
A-20

For example, pollen particles range from 10 to 150 microns. So are you going to fine the food producer 

with your next ruling because pollen particles are larger than pm2.5, say, for apples the largest agric. 

crop in Washington, when the pollen particle from his/her orchard exceeds your pm 2.5? Are you going 

to fine wheat and corn farmers for growing food in the Columbia Basin when the wind blows to carry 

dust away that exceeds pm2.5? Are you going to fine people for using antiperspirant when its particles 

are larger than pm2.5 which they always are? Are you going to fine people when they exhale or sneeze 

when such particles are larger than pm2.5? Are you going to fine people for using coffee or cayenne 

pepper or yeast to make bread because coffee dust or cayenne pepper or yeast particles exceed pm2.5? 

Here are other examples of particle sizes, mold spores-3 microns, end of needle 1230 microns, moss-150 

microns, fertilizer-10 microns, cayenne pepper-15 microns, saw dust-30 to 4000 microns, dust mites-30 

microns, coffee-5 to 400 microns, cement dust-3 to 300 microns, mold-10 to 30 microns, red blood cells5 to 10 microns, mustard-6 to 10 microns, antiperspirant-6 to 10 micros, sand that fell in Spokane from 

Mt St Helens-1230 microns, hair-200 microns, a dot on this page-615 microns, face powder-30 microns, 

copier toner-15 microns, yeast-1 to 50 microns, insecticide dust-10 microns, liquid droplets from your 

breath or sneeze-0.5 to 5 microns, pollen from corn in Washington grown for food, anthrax spores-5 

microns, dust from farm fields in Washington that grow wheat for food that keeps families' in business 

reaching Spokane when the wind blows-10 to 400 microns .....and best of all is that your home vacuum 

cleaner only captures particles larger than 40 microns. 

I am a farmer and I am concerned and so should be you. 

The last two examples show how ridiculous is the pm 10 standard, while you so cavalierly promote the 

pm2.5. 

If a mother is baking in this kitchen using flour or dad is frying bacon, both are exceeding this standard 

for pm2.5 

Do you plan on stopping all of these particles now that the limit is pm2.5? Where does this stop? Is any 

logic engaged? 

So I want to know if you plan on presenting citations to all of these sources after the fireplaces, wood 

stoves? Is it then on to the orchardists, the wheat farmers...? These examples show just how ridiculous 

is this plan. This plan does not represent reality. It is a dream. 

I also want to know what devices can or cannot be used to meet your standard. You mention 

woodburning stoves yet give examples of other devices, certified and uncertified stoves, pellet stoves, 

oil furnace, coal furnace, gas furnace, fireplace. I want you to conduct courses at colleges on how to 

understand these limits so that people can appreciate and have the time to think about it. I want you to 

broadcast all the negatives about what you are doing, not just the "feel good" attitudes that now we 

are protecting the public when they are instead being swindled. 

I also want to know what devices can or cannot be used in time of emergency, in time of an other ice 

storm or during a electrical outage, in time when the Governor orders we pay more for fuel to battle 

non-existent climate change that many cannot afford that fuel. Will you then fund the poor to pay for 

fuel from the Governor's new tax? He intends his tax to stop climate change (how ridiculous, again) but 

it would then be a Robin Hood tax of the rich to give to the poor. What will be the policy on all of this? 

We are told to toe the line on the pm2.5 but what about these other situations. 
A-21 

I want to see the data that is used to monitor Spokane's air. Is it secret? I want to see it. I want to 

examine and analyze it. I want the raw data, not data massaged first then made available. I want to see 

an explanation of the data, the data, and how decisions are made by its use. You need to broadcast 

where the data is made available. 

I am not asking you these questions for you just to provide answers. I am telling you that you must do 

this. You must do this if you serve Washington. It is your duty to serve Washington. 

Frankly, I do not understand why I must waste my time telling you how ridiculous are these standards. 

This is a perfect example of how people in government have now exceeded their level of competence in 

dealing with such matters. To people knowledgeable, it should be so plain that our state should 

reject this standard outright without needlessly involving the public. You have lost sight of your job of 

serving people of the state of Washington and instead serve the EPA. 

It appears to me, by your apparent cavalier acceptance of this standard, that rather than serve 

Washington, you instead acquiesce to extortion by the EPA? 

David Boleneus 

Spokane, WA 

5094689062 

boleneus@gmail.com
A-22

From: Dave Boleneus [mailto:dboleneus@infomine.com] 

Sent: Thursday, April 09, 2015 1:54 PM 

To: ECY RE AQComments 

Cc: rehinman1@msn.com; fhb_geo@comcast.net; Dan and Gloria Clark; Bill Demers; Dan Boleneus 

Subject: air quality comment 

Topic item:-emission level greater than 35 microgram per cubic meter (ug/m3) is considered a 

violation of the clean air act, or pm>2.5 represents a violation.

I have many complaints about this limit but try here to include all. I dont have time to submit all 

comments in organized prose, so here goes.

What is the limit, one or both: 35 ug/m3 or pm2.5?

You mentioned that emissions that exceed the limit of 35 micrograms per cubic meter are in 

violation of the clean air act but in your next breath you say the limit is pm 10 or pm>2.5. A 

microgram is a measure of mass where the pm 2.5, which is 2.5 microns (a millionth of a meter) 

is a measure of length. Do you know this difference? You confuse these measures also as if they 

are one in the same. They are not the same.

The first point I want to make is your agency’s cavalier use of this limit of 35 ug/m3 and pm 2.5. 

Your use of these figures is so loose that people are led to believe that its “no big deal or that 

it’s of no significance. Well it is. It’s a really big deal and you do not communicate just how 

incredibly small this particle is. It is so big a deal that this limit will be impossible to meet. I do 

not believe you have a mental concept of how small is this amount. You certainly have not 

communicated this to the public or compared it to other particles or said what impact this will 

have on peoples lives. People want to know what they cannot do yet meet this standard.

For example, compared to a cubic meter of rock, since you mention this measure, is about 1000 

kg (2.5 tons), the cubic meter of rock contains 3 billion micrograms if my calculation is correct, 

but in your third breath you say that 1/3,000,000,000th of this ton represents a violation of the 

law. What!! This demonstrates the total ignorance of your words. You believe you can say this 

but without knowledge of its relevance.
A-23

For example, pollen particles range from 10 to 150 microns. So are you going to fine the food 

producer with your next ruling, say apples the largest ag crop in Washington, when the pollen 

particle from his/her orchard exceeds your pm 2.5? Are you going to fine wheat and corn 

farmers for growing food in the Columbia Basin when the wind blows to carry dust away that 

exceeds pm2.5? Are you going to fine people for using antiperspirant when its particles are 

larger than pm2.5? Are you going to fine people when they exhale or sneeze when such 

particles are larger than pm2.5? Are you going to fine people for using coffee or cayenne 

pepper or yeast to make bread because coffee dust or cayenne pepper or yeast exceeds 

pm2.5?

Here are other particle sizes, mold spores-3 microns, end of needle 1230 microns, moss-150 

microns, fertilizer-10 microns, cayenne pepper-15 microns, saw dust-30 to 4000 microns, dust 

mites-30 microns, coffee-5 to 400 microns, cement dust-3 to 300 microns, mold-10 to 30 

microns, red blood cells-5 to 10 microns, mustard-6 to 10 microns, antiperspirant-6 to 10 

micros, sand that fell in Spokane from Mt St Helens-1230 microns, hair-200 microns, a dot on 

this page-615 microns, face powder-30 microns, copier toner-15 microns, yeast-1 to 50 

microns, insecticide dust-10 microns, liquid droplets from your breath or sneeze-0.5 to 5 

microns, anthrax spores-5 microns, dust from farm fields in Washington reaching Spokane 

when the wind blows-10 to 400 microns .....and best of all is that your home vacuum cleaner 

only captures particles larger than 40 microns. 

The last two examples show how ridiculous is the pm 10 standard. 

So I want to know if you plan on presenting citations to all of these sources? These examples 

show just how ridiculous is this plan. This plan does not represent reality. It is a dream.

I also want to know what devices can or cannot be used to meet your standard. You mention 

woodburning stoves yet give examples of other devices, certified and uncertified stoves, pellet 

stoves, oil furnace, coal furnace, gas furnace, fireplace.

I also want to know what devices can or cannot be used in time of emergency, in time of an 

other ice storm or during a electrical outage, in time when the Governor orders we pay more 

for fuel to battle non-existent climate change that many cannot afford that fuel. Will you then 
A-24

fund the poor to pay for fuel from the Governor's new tax? What will be the policy on all 

of this? We are told to toe the line on the pm2.5 but what about these other situations.

I want to see the data that is used to monitor Spokane's air. Is it secret? I want to see it. I want 

to examine and analyze it. I want the raw data, not data massaged first then made available. I 

want to see an explanation of the data, the data, and how decisions are made by its use. You 

need to broadcast where the data is made available.

Frankly, I do not understand why I must waste my time telling you how riduculous are these 

standards. To most it should be so plain that our state should reject it outright without 

needlessly involving us.

This email is intended only for the persons named in the message header. Unless otherwise indicated, it contains information that is private 

and confidential. If you have received it in error or no longer wish to receive this or similar electronic communication, please visit 

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A-25

From: Dave Boleneus [mailto:dboleneus@infomine.com] 

Sent: Thursday, April 09, 2015 9:15 AM 

To: Ekrem, Joanna (ECY) 

Subject: Wood stoves 

Checking out at the store, the young cashier suggested to the much older lady that she should bring her own grocery 

bags, because plastic bags are not good for the environment.

The woman apologized to the young girl and explained, "We didn't have this 'green thing' back in my earlier days."

The young clerk responded, "That's our problem today. Your generation did not care enough to save our environment 

for future generations."

The older lady said that she was right -- our generation didn't have the "green thing" in its day. The older lady went on 

to explain:

Back then, we returned milk bottles, soda bottles and beer bottles to the store. The store sent them back to the plant 

to be washed and sterilized and refilled, so it could use the same bottles over and over. So they really were recycled. 

But we didn't have the "green thing" back in our day.

Grocery stores bagged our groceries in brown paper bags that we reused for numerous things. Most memorable 

besides household garbage bags was the use of brown paper bags as book covers for our school books. This was to 

ensure that public property (the books provided for our use by the school) was not defaced by our scribblings. Then 

we were able to personalize our books on the brown paper bags. But, too bad we didn't do the "green thing" back 

then.

We walked up stairs because we didn't have an escalator in every store and office building. We walked to the grocery 

store and didn't climb into a 300-horsepower machine every time we had to go two blocks.

But she was right. We didn't have the "green thing" in our day.

Back then we washed the baby's diapers because we didn't have the throw away kind. We dried clothes on a line, not 

in an energy-gobbling machine burning up 220 volts. Wind and solar power really did dry our clothes back in our early 

days. Kids got hand-me-down clothes from their brothers or sisters, not always brand-new clothing.

But that young lady is right; we didn't have the "green thing" back in our day.

Back then we had one TV, or radio, in the house -- not a TV in every room. And the TV had a small screen the size of 

a handkerchief (remember them?), not a screen the size of the state of Montana. In the kitchen we blended and 

stirred by hand because we didn't have electric machines to do everything for us. When we packaged a fragile item to 

send in the mail, we used wadded up old newspapers to cushion it, not Styrofoam or plastic bubble wrap. Back then, 

we didn't fire up an engine and burn gasoline just to cut the lawn. We used a push mower that ran on human power. 

We exercised by working so we didn't need to go to a health club to run on treadmills that operate on electricity.

But she's right; we didn't have the "green thing" back then.

We drank from a fountain when we were thirsty instead of using a cup or a plastic bottle every time we had a drink of 

water. We refilled writing pens with ink instead of buying a new pen, and we replaced the razor blade in a r azor 

instead of throwing away the whole razor just because the blade got dull.

But we didn't have the "green thing" back then.

Back then, people took the streetcar or a bus and kids rode their bikes to school or walked instead of turning their 

moms into a 24-hour taxi service in the family's $45,000 SUV or van, which cost what a whole house did before 

the"green thing." We had one electrical outlet in a room, not an entire bank of sockets to power a dozen appliances. 

And we didn't need a computerized gadget to receive a signal beamed from satellites 23,000 miles out in space in 

order to find the nearest burger joint.

But isn't it sad the current generation laments how wasteful we old folks were just because we didn't have the "green 

thing" back then?

Please forward this on to another selfish old person who needs a lesson in conservation from a smart ass young 

person.

We don't like being old in the first place, so it doesn't take much to piss us off... Especially from a tattooed, multiple 

pierced smartass who can't make change without the cash register telling them how much.

Vivian West

David Boleneus

Geologist, MS LG
A-26

CostMine Div. of InfoMine USA Inc. 

100 North Mullan Road #102, Spokane, WA 99206

T 509.328.8023 F 509.328.2026

dboleneus@infomine.com

This email is intended only for the persons named in the message header. Unless otherwise indicated, it contains information that is private 

and confidential. If you have received it in error or no longer wish to receive this or similar electronic communication, please visit 

cem.infomine.com for more information. InfoMine Inc. Suite 900, 580 Hornby Street, Vancouver, BC, Canada V6C 3B6 | +1 604 683 2037 | 

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A-27

From: Dennis Reed [mailto:hangardad@gmail.com] 

Sent: Thursday, April 09, 2015 10:44 AM 

To: Ekrem, Joanna (ECY) 

Subject: Wood Stove Standards 

To All, 

The wood stove industry has done an incredible job of improving the efficiency of their products over 

the last 15 years and new technology is continuing to advance. I've seen no scientific data published that 

would support any tightening of wood stove standards in the Spokane area, let alone Eastern 

Washington, the Inland Empire, the West Plains, North Idaho or any other designated research area. I 

see this as another taxing authority trying to justify their annual budget and punish residents who 

already pay too much tax. It's time to get financially organized and consider moving out of this state. 

Never in my life have I use the term "Ex-Pat". May be it's time. And don't even talk to me about "carbon 

footprint" another one our government's big lies. 

--

Kind regards, 

Dennis Reed 

509-990-3188 
A-28

From: Dan and Gloria Clark [mailto:gclark@air-pipe.com] 

Sent: Tuesday, March 17, 2015 4:19 PM 

To: Ekrem, Joanna (ECY) 

Subject: Re: public hearing request for wood stove burn ban in Spokane County 

Joanna,

Thank you for setting up an additional evening meeting. 

Gloria 

From: Ekrem, Joanna (ECY) 

Sent: Tuesday, March 17, 2015 4:13 PM

To: Dan and Gloria Clark 

Cc: Julie Oliver ; Margee Chambers 

Subject: RE: public hearing request for wood stove burn ban in Spokane County

Hi Gloria, 

Thank you for your interest. We had a meeting this afternoon and decided to hold an additional public 

hearing on April 2 at 6pm at Spokane Regional Clean Air Agency: 3104 E. Augusta Avenue, Spokane WA 

99207. We will still also hold one at 9:30 am on April 2. The public comment period is extended an 

extra week through April 10. 

Please let me know if you have any questions or would like to discuss this in more detail. Over the next 

couple days, we will be updating our public involvement calendar and website and will send out e-mail 

notifications to let members of the public know about these changes. 

Best Regards, 

Joanna 

Joanna Ekrem

 | Air Quality Program | 

 | WA State Dept of Ecology |

| Telephone 360.407.6826 | 

From: Dan and Gloria Clark [mailto:gclark@air-pipe.com] 

Sent: Tuesday, March 17, 2015 4:00 PM 

To: Ekrem, Joanna (ECY) 

Subject: Re: public hearing request for wood stove burn ban in Spokane County 

Hello Joanna, 

Have you scheduled an evening meeting to accommodate working folks? I need to know soon. 

Thanks, 

Gloria Clark 

From: Ekrem, Joanna (ECY)
A-29

Sent: Wednesday, March 11, 2015 10:02 AM

To: Dan and Gloria Clark 

Subject: RE: public hearing request for wood stove burn ban in Spokane County

Gloria, 

Thank you for your request by e-mail and voicemail to change the time of the public hearing and extend 

the public comment period. I tried to give you a call you back but you did not answer. We are 

considering your request and will let you know what we decide. Please let me know if you have any 

questions or would like to learn more about what Ecology is accepting comment on. Also I want to let 

you know that the notice of the public hearing is publicly accessible on Ecology’s website, public 

involvement calendar, and we sent out several notifications. 

Joanna 

From: Dan and Gloria Clark [mailto:gclark@air-pipe.com] 

Sent: Monday, March 09, 2015 10:21 PM 

To: Ekrem, Joanna (ECY) 

Subject: Re: public hearing request for wood stove burn ban in Spokane County 

Joanna, 

The meeting needs to be changed to an evening format, so hard working folks can attend. Which date in 

the evening will work for you? 

Cordially, 

Gloria Clark 

From: Ekrem, Joanna (ECY) 

Sent: Monday, March 09, 2015 5:42 PM

To: Dan and Gloria Clark 

Subject: RE: public hearing request for wood stove burn ban in Spokane County

Hi Gloria, 

Thank you for letting me know. 

Joanna 

From: Dan and Gloria Clark [mailto:gclark@air-pipe.com] 

Sent: Monday, March 09, 2015 5:15 PM 

To: Ekrem, Joanna (ECY) 

Subject: Re: public hearing request for wood stove burn ban in Spokane County 

Joanna, 

I just wanted to let you know my email address is gclark@air-pipe.com, not gclark@sir-pipe. Sorry for 

my mistake. 

Gloria Clark 
A-30

From: Ekrem, Joanna (ECY) 

Sent: Monday, March 09, 2015 3:55 PM

To: Dan and Gloria Clark 

Subject: RE: public hearing request for wood stove burn ban in Spokane County

Gloria, 

Thank you, I received your request for a public hearing. The public hearing will be held at 9:30 a.m. on 

April 2, 2015, at Spokane Regional Clean Air Agency office: 3104 E. Augusta Avenue, Spokane, WA 

99207. 

Joanna 

Joanna Ekrem

 | Air Quality Planner |

 | WA State Dept of Ecology |

| Telephone 360.407.6826 | 

From: Dan and Gloria Clark [mailto:gclark@air-pipe.com] 

Sent: Monday, March 09, 2015 3:07 PM 

To: Ekrem, Joanna (ECY) 

Subject: public hearing request for wood stove burn ban in Spokane County 

Dear Joanna Ekrem: 

Please let this serve as notice that Spokane citizens would like to have a public hearing regarding a burn 

ban on wood stoves in Spokane County. Please write back to let me know that you got this email and the 

details of where and when a public hearing is going to be held. DOE’s website said no public hearing 

would be held unless it was requested. 

Sincerely, 

Gloria Clark 

Spokane CAPR Secretary 

gclark@sir-pipe.com
A-31
A-32
A-33

From: Judy [mailto:jrcrowder@comcast.net] 

Sent: Thursday, April 02, 2015 8:56 AM 

To: ECY RE AQComments 

Subject: State Implementation Revision 

April 2, 2014

Spokane Regional Clean Air Agency

3104 E. Augusta 

Spokane, WA 

SUBJECT: April 2, 2015 Public Hearing: Spokane Proposed State Implementation Revision to Update 

Spokane Regional Clean Air Agency's Solid Fuel Burning Device Rules

Dear Department of Ecology, 

The Federal government has grossly overstepped its constitutional bounds which the States enumerated 

in the U.S. Constitution at Article I Section 8. Without question there are 18 enumerated powers the 

Federal government can legally take charge of : CLAUSE 1 To lay and collect Taxes, Duties, Imposts and 

Excises, and to provide for the Common Defense and general Welfare: CLAUSE 2 To borrow Money: 

CLAUSE 3 To regulate Commerce with foreign Nations, and among the several States, and with the 

Indian tribes: CLAUSE 4 To establish a uniform Rule of Naturalization, and uniform Laws on the subject 

of Bankruptcies throughout the United States: CLAUSE 5 To coin Money, regulate the Value thereof, 

and of foreign Coin, and fix the Standard of Weights and Measures:CLAUSE 6 To provide for the 

Punishment of counterfeiting the Securities and current Coin of the United States: CLAUSE 7 To 

Establish Post Offices and Post Roads: CLAUSE 8 To promote the Progress of Science and useful Acts, by 

securing for limited Times to Authors and Inventors the exclusive Right to their respective Writings and 

Discoveries: CLAUSE 9 To constitute Tribunals inferior to the supreme Court: CLAUSE 10 To define and 

punish Piracies and Felonies committed on the high Seas, and Offenses against the Law of Nations: 

CLAUSE 11 To declare War, grant Letters of Marque and Reprisal, and make Rules concerning Captures 

on Land and Water: CLAUSE 12 To raise and support Armies, but no Appropriation of Money to that Use 

shall be for longer than two Years: CLAUSE 13 To provide and maintain a Navy: CLAUSE 14 To make 

Rules for the Government and Regulation for the lands and naval Forces: CLAUSE 15 To provide for call 

forth the Militia to execute the Laws of the Union, suppress Insurrections and repel Invasions: CLAUSE 

16 To providing for organizing, arming, and disciplining, the Militia, and for governing such Part of them 

as may be employed in the Service of the U.S. reserving to the States respectively, the Appointment of 

the Officers, and the Authority of training the Militia according to the discipline prescribed by Congress: 

CLAUSE 17 To exercise exclusive Legislation in all Cases whatsoever, over such District (not exceeding 

ten Miles square) as may, by Cession of particular States, and the Acceptance of Congress, become the 

Seat of the Government of the U.S., and to exercise like Authority over all Places purchased by the 

Consent of the Legislature of the State in which the Same shall be, for the Erection of Forts, Magazines, 

Arsenals, dock-Yards and other needful Buildings:--And: CLAUSE 18 To make all laws which shall be 

necessary and proper for carrying into Execution the foregoing Powers, and all other Powers vested by 

this Constitution in the Government of the U.S. , or in any Department or Officer thereof. In addition to 

the above 18 enumerated and limited federal power, the states gave the Federal government the 

authority to make treaties at U.S. Const. Art. II sec.2, cl.2 and authority to dispose of land at U.S. Art. 

IV,sec 3, cl. 2. 

Since the beginning of our country the Federal government has attempted to take powers it was not 

delegated and James Madison and Thomas Jefferson address the misuse of the general welfare clause to 
A-34

gain unconstitutional power in the Kentucky and Virginal Resolutions of 1798. Kentucky Resolution 

Approved December 3rd, 1799 ;“That if those who administer the general government be permitted to 

transgress the limits fixed by that compact, by a total disregard to the special delegations of power 

therein contained, annihilation of the state governments, and the erection upon their ruins, of a general 

consolidated government, will be the inevitable consequence:... That the several states who formed that 

instrument, being sovereign and independent, have the unquestionable right to judge of its infraction; 

and that a nullification, by those sovereignties, of all unauthorized acts done under colour of that 

instrument, is the rightful remedy:”. Virginia Resolution Agreed to by the Senate, December 24, 1798 

“RESOLVED, That the General Assembly of Virginia, doth unequivocably express a firm resolution to 

maintain and defend the Constitution of the United States, and the Constitution of this State, against 

every aggression either foreign or domestic... That this Assembly doth explicitly and peremptorily declare, 

that it views the powers of the federal government, as resulting from the compact, to which the states 

are parties; as limited by the plain sense and intention of the instrument constituting the compact; as no 

further valid that they are authorized by the grants enumerated in that compact; and that in case of a 

deliberate, palpable, and dangerous exercise of other powers, not granted by the said compact, the 

states who are parties thereto, have the right, and are in duty bound, to interpose for arresting the 

progress of the evil, and for maintaining within their respective limits, the authorities, rights and liberties 

appertaining to them.... That the General Assembly doth also express its deep regret, that a spirit has in

sundry instances, been manifested by the federal government, to enlarge its powers by forced 

constructions of the constitutional charter which defines them; and that implications have appeared of a 

design to expound certain general phrases (which having been copied from the very limited grant of 

power, in the former articles of confederation were the less liable to be misconstrued) so as to destroy 

the meaning and effect, of the particular enumeration which necessarily explains and limits the general 

phrases; and so as to consolidate the states by degrees, into one sovereignty, the obvious tendency and 

inevitable consequence of which would be, to transform the present republican system of the United 

States, into an absolute, or at best a mixed monarchy.”

The U.S. Constitution does not give the EPA the power to dictate anything in regard to States air or our 

ability to heat our homes with the God given abundant energy source provided by our forests. To 

require us to heat our homes with a source that is controlled by a third party is a taking of property 

rights and our ability to live independently as freemen. 

The very purpose of the State government is to protect individual rights as stated in Article I Section 1 of 

the Washington State Constitution “All political power is inherent in the people, and governments derive 

their just powers from the consent of the governed, and are established to protect and maintain 

individual rights.” In the Northwest without heat a family cannot survive thus a monopoly on the source 

of heat which can legally be used is the taking of one’s individual right to live on ones land year round. 

Article 1 Section is even clearer on this issue, “No person shall be deprived of life, liberty or property, 

without due process of law.” If the State government deprives a person the right to use the wood of 

their land to heat their homes and force them to use what today has become a local monopoly on 

electricity or gas they have in fact deprived the people of their liberty and property making use of their 

property dependent on a third party. In an emergency when the electricity is taken out it could 

conceivably deprive them of life. My young family experienced 6 days without power in the Spokane 

County ice storm and without our fireplace we would have been forced out of our home. Americans 

should enjoy freedom from dependency.
A-35

The Clean Air Act has no constitutional authority to require states develop a general plan to attain and 

maintain the National Ambient Air Quality Standard (NAAQS) and no power to interfere with a State 

Implementation Plan.

According to your air quality brochure found at: www.spokanecleanair.org/documents/our_air/CleanAir-Brochure.pdf

the air quality in Spokane had not exceeded the National Air Quality Standard since 2000. As a State 

agency perhaps a more regional county by county approach is warranted and the counties with a air 

quality problem could look for solutions to minimize air pollution without taking the people’s right to 

heat their homes is the way they choose. 

Blessings in Liberty,

Judy Crowder

20135 N. Yale Rd.

Colbert, WA 99005
A-36

From: jrcrowder@comcast.net [mailto:jrcrowder@comcast.net] 

Sent: Friday, April 10, 2015 10:31 AM 

To: ECY RE AQComments 

Subject: Comment SRCAA Reg I Art.VIII Solid Fuel Burning Devices Rule 

April 10, 2015

Spokane Regional Clean Air Agency

ATTN: Margee Chambers

3104 E. Augusta Avenue 

Spokane, WA 99207

RE: Comments on Public Draft, March 2015 Updates to SRCAA Solid Fuel Burning 

Devices Rule (Reg. I Art. VIII)

Dear SRCAA,

I believe government closest to the people is best and that is why the American system 

has been so successful allowing the checks and balances of Local, County, State and 

Federal governments with the planned decentralization of power. Spokane Regional 

Clean Air Agency should follow the WASHINGTON CLEAN AIR ACT RCW CHAPTER 

70.94 and should not be obligated to national standards.

The U.S. Constitution does not give the Federal government or it’s agency any power 

over the air quality in the States and the State is correct to limit EPA control over the 

clean air policies of State policy.

In fact RCW 70.94.230 specifically outlines who has authority to make rules an it does 

not mention any national agency. The local agencies are to follow rules made by the 

Authority “The rules and regulations hereafter adopted by an authority under the 

provisions of this chapter“. The authority is defined RCW 70.94.030 (5) and is not the 

EPA. Other areas of the State law which concern our local air quality are RCW 

70.94.450 Woodstoves-Policy , RCW 70.94.456 Woodstoves – Definitions, RCW 

70.94.455 , RCW 70.94.457 Solid fuel burning devices – Emission performance 

standards and WAC 173-433-100 EMISSION PREFORMANCE STANDARDS. The 

State has adopted rules for when advisory alerts and burn bans maybe called RCW 

70.94.473 which list the level necessary to began the bun ban process. That is not the 

same as saying that is the annual or 24 hour standard for the State of Washington.

Control of the Standards for our air quality are and should be established by the State. It 

is the intent of the State to comply with the requirements of the federal clean air act 
A-37

however the legislator’s did not directly tie the State air quality standards to the EPA 

standards. (RCW 70.94.011) 

The State has maintained control over the clean air policy in Washington State and has 

used CFR Title 40 Part 60 & 61 national regulations to provide the standard of testing 

methods and to provide the list of contaminates considered as pollutants. CFR Part 60 

for testing standards and Part 61 for air pollutants. The State has adopted rules for 

when advisory alerts and burn bans maybe called RCW 70.94.473 which list the level 

necessary to began the bun ban process. That is not the same as saying that is the 

annual or 24 hour standard for the State of Washington. 

One of the main goals SRCAA listed on page one of the Public Review Draft, March 

20155 is to meet EPA air quality requirements. I strongly believe that should be 

changed to Washington State air quality requirements. I am requesting you not submit 

the Spokane Regional Clean Air Agency (SRCAA) State Implementation Plan (SIP) to 

EPA for approval as your letter included in the Public Review Draft of Feb 25, 2015 is 

suggesting.

I have attached a excel spread sheet of the history of the record of Spokane County and 

I commend the people of Spokane and your agency for making it possible that we have 

never exceeded the PM2.5 microgram National Annual Standard and have only twice 

exceeded the Annual National Annual PM10 micogram standard in 1987 & 1988. I 

believe those exceedent years were years of Northwest fires and I know 1988 was the 

year of the Yellowstone fires. As we go down the path of cleaner and cleaner air we 

must balance the citizen’s rights to use natural resources on their land and their right to 

remain independent of third party energy providers.

I recommend (red is your suggested changes):

SECTION 8.03 – DEFINITIONS 

Do not add (I) National Ambient Air Quality Standards (NAAQS; 40 CFR 50) means 

outdoor air quality standards established by the United States Environmental Protection 

Agency under authority of the federal Clean Air Act. EPA set standards for six principal 

air pollutants, called “criteria” pollutants, under the NAAQS. The criteria pollutants are 

carbon monoxide, sulfur dioxide, nitrogen dioxide, lead, ozone and particulate matter 

(PM2.5 and PM10).

Do not add (K) Nonattainment Area means a clearly delineated geographic area which 

has been designated by the Environmental Protection Agency because it does not 

meet, or it affects ambient air quality in a nearby area that does not meet, a national 

ambient air quality standard or standards for one or more of the criteria pollutants 

defined in 40 CFR 50, National Ambient Air Quality Standards.

SECTION 8.04 - EMISSION PERFORMANCE STANDARDS

Remove existing language with reference to National Air quality Standards and replace 

section to read: Add: The Agency adopts RCW 70.94.457 and WAC 173-433 by 

reference “ Emissions Performance Standards.
A-38

SECTION 8.09 - PROCEDURE TO GEOGRAPHICALLY LIMIT SOLID FUEL 

BURNING DEVICES

Do not add :(A) If the EPA finds that the Spokane PM10 Maintenance Area has violated 

a National Ambient Air Quality Standard for PM10 and After July 1, 1995, if the EPA 

finds that the Spokane PM10 Nonattainment Area, as defined in CFR Title 40, Part 81, 

has either: 1. failed to make Reasonable Further Progress, or 2. failed to timely attain a 

National Ambient Air Quality Standard for particulates ten microns and smaller in 

diameter (PM10), as defined in CFR title 40, Part 50.6, or 3. violated a National Ambient 

Air Quality Standard for PM10 after redesignation as an attainment area, emissions 

from solid fuel burning devices are determined by the EPA, in consultation with Ecology 

and the AuthorityAgency, to be a contributing factor to such failure or violation, then one 

year after such determination, the use of solid fuel burning devices not meeting the 

standards set forth in RCW 70.94.457 and WAC 173-433-100, is restricted to areas 

outside the Smoke Control Zone.

Do add: (A) If the Spokane is outside the Washington State guidelines for air quality 

and has failed to make Reasonable Further Progress, or failed to timely attain State 

Ambient Air Quality Standards for particulates ten microns and smaller in diameter 

(PM10), as defined in CFR title 40, Part 50.6, then one year after such determination, 

the use of solid fuel burning devices not meeting the standards set forth in RCW 

70.94.457 and WAC 173-433-100, may be restricted to areas outside the Smoke 

Control Zone. 

Blessings in Liberty, 

Judy Crowder 

20315 N. Yale Rd 

Colbert, WA 99005 

509-238-9430 

Attached: excel spread sheet on history of SRCAA exceedences 

cc. DOE 
A-39
A-40

From: Lester Lea [mailto:lesterlea@gmail.com] 

Sent: Wednesday, April 08, 2015 3:49 PM

To: Ekrem, Joanna (ECY)

Cc: Shea Matt

Subject: Wood stoves

I do not approve of these unnecessary changes to air standards in Spokane County 

that will infringe on my private property rights guaranteed under the U.S.

Constitution and the Constitution of the State of Washington."

Lester Lea

Sent from my iPhone
A-41

From: -Y- [mailto:lizard@use.startmail.com] 

Sent: Wednesday, April 08, 2015 4:12 PM 

To: Ekrem, Joanna (ECY) 

Subject: wood stove ban 

Joanna good day, 

I do not approve of these unnecessary changes to air standards in Spokane County that will infringe on 

my private property rights guaranteed under the U.S. Constitution and the Constitution of the State of 

Washington. 

We appreciate SRCAA’s effort to update the policy and propose it to EPA which would appear to make 

more sense and be better for the public, but we do not approve of the idea. We highly suggest and ask 

that you and the team really look beyond the horizon here and see what’s happening. We too are 

people who are in need of paychecks but we do not compromise. If you’re in the position to select 

compromise or losing your position, we strongly encourage you all to seek companies that do not bow 

under tyranny. 

Thank you for hearing us out. 

Regards, 

-LizSpokane County
A-42

From: Marilyn Montgomery [mailto:marilynj35@gmail.com]

Sent: Wednesday, April 08, 2015 6:39 PM 

To: Ekrem, Joanna (ECY) 

Subject: DOE/SRCAA "UPDATE" OF SPOKANE REGION'S AMBIENT AIR QUALITY STANDARDS 

At your April 2nd Public Hearing in Spokane which I attended, SRCAA's employee Margee Chambers 

stated that the purpose of the Statewide Implementation Plan is to update solid burning device rules to 

align with state rules to call burn bans. It is my understanding that the Spokane region has not exceeded 

the National Ambient Air Quality Standards since 1995, and therefore it is nonsensical - and ridiculously 

restricting - to proceed with increasing the non-attainment standards when Spokane hasn't exceeded 

them in 19 years! 

Is my understanding correct that the EPA may force homeowners to physically block up their fireplaces 

"permanently" and remove their wood stoves, and - for heaven's sake! - forbid all citizens from 

barbecuing if the standards are not met? Such restrictions are draconian and would deny families from 

the natural enjoyment of their homes, reducing our beloved amenities that help make life worthwhile. 

Do I also understand that our neighbors are called upon to "snitch" on anyone whom they think may be 

contributing to non-attainment? That is just Orwellian! There are many families who use wood 

exclusively to heat their homes, and even many more who partially heat their homes with wood when 

inclement weather takes hold. They do not need the stress of these new restrictions with the threat of 

censure and fines, and perhaps the mandate that they replace their stove with a much more expensive 

one in order to "comply." 

For the record, I do not approve of these absolutely unnecessary changes to air standards in Spokane 

County, standards that will infringe on my and my neighbors' private property rights guaranteed under 

both the Constitution of the State of Washington and the Constitution of these United States. 

Respectfully submitted, 

Marilyn J. Montgomery 

4715 East Sumac Drive 

Spokane, WA 99223-2210 

509-448-5288 
A-43

From: Mary jo King [mailto:behappymj@icloud.com] 

Sent: Saturday, March 21, 2015 7:09 PM

To: Ekrem, Joanna (ECY)

Subject: Fireplace Ban in Spokane County

Hello Joanna...

I hope you are having a nice day. 

Could you please explain what the hearing is about in Spokane Wa on April 2nd and 

what the Department of Ecology is proposing to do in Spokane County?

Are there bans being proposed permanently for residential fireplaces in Spokane 

County and is it only for the county? Does this include Spokane city as well?

Thank you so much for responding and explaining what this hearing is about and 

exactly what you are proposing to do. 

Thank you so much for your help..

Mary Jo King 

Sent from my iPhone
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From: Mary Jo King [mailto:behappymj@gmail.com] 

Sent: Tuesday, March 24, 2015 10:03 PM 

To: Ekrem, Joanna (ECY) 

Subject: Wood Burning Fireplaces in Spokane County 

Dear Joanna ... 

I hope you are having a great day!! 

I apologize if you have received a couple of emails from me - I can't tell if you are receiving them. So I 

am sending one from my email so I know it gets sent. Thanks so much. 

I am writing in regards to some proposals about banning wood burning fireplaces in Spokane County or 

very severe restrictions? There is a hearing on April 2nd about this. 

I was just wondering if you could clarify what this meeting is about and what The Department of Ecology 

is proposing for the residents of Spokane County? I have received no flyers or information about this 

from The Department of Ecology. 

I will look forward to hearing from you. 

Thanks so very much. 

Mary Jo King 

--

Mary Jo King 

"Be happy..it is one way of being wise".. 

"No act of kindness, no matter how small, is ever wasted." Aesop 
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From: Patsi Marie [mailto:swimgal4@msn.com]

Sent: Wednesday, April 08, 2015 5:17 PM

To: Ekrem, Joanna (ECY)

Subject: Woodstove Burning in Spokane

For hundreds of years people have burned wood in their homes. It is our right to 

enjoy our home. To remove one more infringement upon our rights granted by the 

constitution is despicable. Large mills & casinos can omit whatever comes out 

their chimney stacks ... It's aways the small guy who is under siege. Our 

incinerator can't be without some stink but let's hush that up:) Empty city buses 

omit plenty of awful diesel fumes & the wealthy who burn in their oval shaped 

fire pits are not a problem. But let's get Granny away from that stove & turn up 

that electric or gas ( AVISTA NEEDS YOU )

Patricia Dunham

Sent from my iPhone
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From: Appy Holadays Sport Horses [mailto:mrromantico@earthlink.net] 

Sent: Thursday, March 19, 2015 7:10 PM 

To: Ekrem, Joanna (ECY) 

Subject: Re: Dept. of Ecology: Spokane Wood Stove Burn Ban Hearings on April 2 

Joanna Ekrem, 

 I don't know if you have had the formal request for this hearing sent to you yet, but if not, I am formally requesting 

a hearing for the 2nd of April with this email response. This rather hidden notice to the public is grossly inadequate 

for such an extremely important issue. Something of this magnitude should be announced as an ALERT on the 

evening news, morning news, and in every newspaper in the entire State. 

 This subject on "woodstoves" and the banning of them in any way, shape, or form, is the equivalent to a gun ban, 

a property rights ban, or a water usage ban, and don't think for a minute it is anything of less importance than those 

other things. You are talking about cutting into, or completely cutting out, a part of "the bare essentials necessary for 

human life" in our State. We are not Arizona... in case the DoE has failed to notice that important fact. 

 Nobody over here is going to allow any sort of a woodstove ban or partial woodstove ban to be enforced in this 

state, and furthermore, the people even thinking of pushing this idea are completely insane. So in other words, yes, 

we absolutely want a hearing. 

Rene' Holaday 

President, Stevens County CAPR 
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From: Holy, Rep. Jeff [mailto:Jeff.Holy@leg.wa.gov] 

Sent: Thursday, March 19, 2015 8:37 AM 

To: Ekrem, Joanna (ECY) 

Subject: FW: URGENT ALERT: Spokane Wood Stove Burn Ban Hearings on April 2 (Please Forward) 

Importance: High 

Joanna, 

Keep me in the email loop as to any change in state standards or Spokane County local rules resulting 

from these hearings. 

Thanks, 

Rep. Jeff Holy 

6th Legislative District 

360-786-7962 

Visit my website here.
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From: Stephen Dunham <sdunham@q.com>

Date: April 9, 2015 10:44:12 PM PDT

To: Joanna.ekrem@ecy.wa.gov

Subject: Proposed SIP Revision Comment

I would like to make a few comments about the proposed 

SIP revision. First, The SIP does not have to be submitted to 

the EPA for approval and Washington State does not have to 

meet EPA requirements for national air quality. The EPA is an 

unconstitutional agency that Congress created in the 1970's. 

 Article I Section 8 of the Constitution lists the only specific 

government expenses for which it has the power to tax. 

Protecting the environment , regulating air quality, and 

restricting the use of wood stoves are not on this list. The tenth 

amendment to the Constitution states " The powers not 

delegated to the United States , nor prohibited by it to the 

States, are reserved to the States or to the people. In other 

words it is up to the States or the people to regulate the 

environment not the federal government. In the Kentucky 

Resolution of 1799 Thomas Jefferson called nullification the 

"rightful Remedy" for any and all unconstitutional acts of the 

federal government. Nullification is founded on the fact that 

the sovereign States formed the union, and as creators of the 

contract, they retain ultimate authority to enforce the 

constitutional limits of the power of the federal government. 

Simply stated nullification recognizes each state's reserved 

power to nullify, or invalidate, any federal measure that a state 

deems unconstitutional. Over the years many states have 

nullified unconstitutional federal laws in the areas of gun 

control, ObamaCare, NSA surveillance, and national ID cards. 

 The article from the New American below tells how in Alaska 
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local politicians attempted to regulate wood burning to comply 

with EPA requirements. The residents of Fairbanks passed a 

citizen initiative that nullified the implementation of the 

regulations on wood burning. They said they would rather not 

freeze to death to satisfy federal bureaucrats. This nullification 

 of unconstitutional EPA regulations should be done in 

Spokane, the State of Washington and all across the country. 

 SRCAA has the job of enforcing the EPA's unconstitutional 

 regulations which makes many of their activities such as 

running around town spying on people and levying fines illegal 

and unlawful under our Constitutional form of government.

Second, The Dept. of Ecology flyer we were given at the 

meeting on April 2nd states that the EPA sets national air 

quality standards for six common pollutants. One of those six 

is human breath (CO2) . Yes the totally out of control EPA 

under the clean air act has established CO2 as a regulatory 

"pollutant " even though all plants need CO2 for 

photosynthesis and all animals exhale carbon dioxide. About 

8% of man made worldwide CO2 emissions are due to simple 

human breathing. The EPA says they do not want to regulate 

our breathing...for now. The excuse for the EPA's need for 

regulatory powers to limit CO2 is the "threat" of global 

warming. About 186 Billion tons of CO2 enters the 

atmosphere every year. Only 3.3% is from human activity. 

 57% is given off by oceans and 38% is breathed out by animals. 

 In other words if you take out the 8% that humans breath out 

from the 3.3% of total CO2 from human activity you end up 

with about 3%. So if we eliminated all cars and trucks , all 

wood burning, all coal burning etc. we would reduce only 3% 
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of the CO2 that enters the atmosphere every year hardly 

enough to effect global warming or cooling. Modern 

commercial greenhouses often use CO2 generators to increase 

the daytime CO2 content to 1,000 ppm or higher for optimum 

 plant growth. Our atmospheric CO2 content now of 400 ppm 

is hardly dangerous. Higher CO2 levels lead to bigger crops and 

more food . In 2007 Al Gore publicly warned the North Pole 

would be ice free in the summer by around 2013 because of 

alleged man made global warming. Instead of melting, sea ice 

worldwide is at the highest levels since records began. The RSS 

(Remote Sensing Systems) set of global satellite temperature 

data report that the period WITHOUT global warming has now 

been extended to 18 years and three months, stretching back 

to October of 1996. This fact of global cooling makes us ask 

why the EPA is so intent on further limiting CO2 emissions and 

restricting the use of wood stoves when the science is simply 

not there to support their actions. 

 Finally, I believe the EPA and sadly our local SRCAA is being 

used much like the IRS as a tool of the federal government to 

intimidate, control,tax and regulate the American people in an 

effort to take away our freedoms and property rights. I totally 

agree with the bumper sticker that says , "Eliminate the EPA, 

It's Them or Us."

Please read the article below. Thank you

Steve Dunham 1616 S. Milton Spokane Wash. 99224

http://www.thenewamerican.com/tech/environment/item/14

016-just-freeze-epa-says-burning-wood-is-bad-but-so-isnatural-gas-coal-oil
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From: Steven DePiro [mailto:depirost@gmail.com] 

Sent: Thursday, April 09, 2015 12:18 PM 

To: ECY RE AQComments 

Subject: Leave My Wood Stove Alone Please

Myself and every neighbor and Friend I have talked to regarding wood stove bans are against any 

regulations on wood stoves that you may be proposing. 

Cattle Feed lots and cars/trucks are culprits, not wood stoves. 

Thank you. 

-- 

Steven DePiro 

Office 509-891-3635 

Cell 360-420-1332

17224 Offmy Lane 

Spokane, WA. 99217 

CONFIDENTIALITY NOTICE: This electronic mail transmission may contain legally privileged, confidential 

information. The information is intended only for the use of the individual or entity named above. If you 

are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or taking 

any action based on the contents of this electronic mail is strictly prohibited. If you received this in error, 

please contact the sender and delete all copies.
A-52

From: Sue Lani Madsen [mailto:suelani.madsen@gmail.com] 

Sent: Sunday, March 22, 2015 7:33 PM 

To: Ekrem, Joanna (ECY) 

Subject: Hearing Request for Update of Clean Air Plan for Spokane County 

Per the Joint News Release dated March 2, 2015 I hereby request a public hearing 

and am sending this request prior to the March 23rd deadline for receipt of such a 

request (just in case no one else made the request). See you at 9:30am on 

Thursday, April 2nd at the SRCAA offices on August Avenue. 

--

Sue Lani Madsen

Home/Office: 509-236-2311 

"He has showed you, oh man, what is good; And what does the Lord require of you but to 

do justice, and to love kindness, and to walk humbly with your God." 

 --Micah 6:8
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