Duraflame, Inc. P.O. Box 1230, Stockton CA 95201 Phone: 209.461.6600 / Fax: 209.462.9412 info@duraflame.com / www.duraflame.com The Secret of Fire ®

September 22, 2006

Larry Greene

Executive Director / APCO

777 12 th Street, Third Floor Sacramento, CA 95814

Dear Larry,

I appreciated the opportunity to meet with you and your senior staff recently to discuss

the emissions characteristics of manufactured firelogs and how our industry might play a role in assisting the Sacramento Metro Air Di strict to reduce emissions from residential

wood combustion. The frank discussions were ve ry useful to clarif y the Air District’s open questions about the emissions charac teristics of our industry’s products.

As you are aware several independent tests, sponsored both by our industry and air quality authorities, have proven that th e emission rates of particulate matter,

Dioxin/Furans and related air t oxics for burning firelogs in an open fireplace are far lower than those produced from burning a typical wood fire in an open fireplace. In spite of these consistent findings from numerous independent labora tory tests your District now questions whether the prior test methodol ogies provided a fair comparison of the emissions produced by firelogs and / or cord wood when burned in a non-laboratory, real

world environment. You also noted that so me of the emissions tests you had reviewed indicated that firelogs produ ce greater emissions than co rdwood when evaluated on an emission factor basis, and therefore feared if consumers were to burn more than one firelog at a time the emissions produced woul d be equal to or greater than those of a cordwood fire providing no emission reduction benefit.

These are certainly fair questi ons, which we are confident we can resolve with a review

of the technical facts related to the performance and usage of our industries products vs.

cordwood.

1. Real World usage of Manufactured Firelogs and Cordwood in Open fireplaces –

By design manufactured firelogs have entirely different burn ch aracteristics than those of cordwood. Firelogs are made with approxima tely 55% natural or petroleum based waxes and 45% recycled biomass fibers. The wa x component of the product provides a far higher energy content fuel that generates approximately twice the BTU content per mass as natural wood, yet the burn rate of this wax component if far lower than seasoned firewood. Firelogs also have significantly lo wer moisture content than natural wood (2-Duraflame, Inc. P.O. Box 1230, Stockton CA 95201 Phone: 209.461.6600 / Fax: 209.462.9412 info@duraflame.com / www.duraflame.com 3% vs. 20% for seasoned wood), which allows th e fuel in a firelog to be combusted more efficiently. In fact the burn rate for firelogs is 1⁄4 the burn rate of cordwood burned in an open-hearth fireplace. This combination of a higher BTU content fuel which combusts at a significantly lower burn rate thereby allows the user to burn far less fuel during a typical usage occasion. Hence burning far less fu el per fire occasion results in far fewer emissions being emitted.

During our recent meeting a member of your staf f indicated that they feared many of the test studies we have presente d the District may have utiliz ed an unrealistically high fuel charge for an aesthetic cordwood fire vs. burni ng just one firelog. They speculated that a person who was going to burn for aesthetic purposes might burn less wood than the

recent emission studies indicated. As I mentioned during our meeting the test methodology for both the studies recently pr esented to your Dist rict attempted to replicate emissions for reasonably comparable usage of the two very different fuel products in common appliances. The test protocols and fuel charges for the wood tests were designed to represent real world ope rating conditions for wood burning fireplaces and were based on independent user data derived from published studies of fireplace

usage.

To elaborate on this matter I am attaching a letter from Dr. James Houck, a PHD scientist

with Omni Environmental Services who dir ected the recent firepl ace emission tests for the EPA, Environment Canada and the Puget Sound Clean Air Agency. Dr Houck is a renowned expert in this field, and has c onducted significant amounts of residential wood combustion emission testing and consulting work for Industry, The EPA and several regional Air Quality Districts.

In addressing the question of fireplace use for aesthetic vs . heating purposes Dr. Houck points out that from an Air Quality planners perspective usually this distinction is made by the number of days and hours a fireplace is used as opposed to the amount of fuel used during a given fire occasion. Air Quality Pl anners usually consid er a household that burns wood frequently in their fireplace to be classified as usage for heating purposes and infrequent users as those who burn for aesthetics.

With regard to individual usage occasions, Dr . Houck notes there is a minimum burn rate

of wood fuel that must be combusted in an open-hearth fireplace in order for the fireplace to function properly. This minimum burn rate for burning seasoned cordwood in a typical 36” manufactured fireplace that would be most common appliance in more densely populated tract home developments in the Sacramento Metro area is 3.3 kg per hour. Burning at a rate below this would not sustain combustion and produce a smoldering, unacceptable fire that the user would rectify by adding more fuel to the fire.

Further, Independent studies of firepl ace usage in N. California (including the Sacramento Area) conducted by UC Berkeley in 2003 for the California Air Resources Board indicated the average duration of house hold burning cordwood in their fireplaces is more than 30% longer than the durati on of fires burned by households using manufactured fires. (See attached excerpt from this study below)Duraflame, Inc. P.O. Box 1230, Stockton CA 95201 Phone: 209.461.6600 / Fax: 209.462.9412 info@duraflame.com / www.duraflame.com Results of Wood Burning Survey - Sacramento, San Joaquin, and San Francisco Areas, University of California Berkeley/ California Air Resources Board - GIS Study , January 15, 2003

Fireplace Usage, Wood Fires - Average fire duration on weekdays was 4.4

hours ; Average fire duration on weekends was 5.1 hours

Fireplace Usage, Wood/Wax Firelog Fires - Average fire duration on weekdays

was 3.3 hours ; Average fire duration on weekends was 3.4 hours

Therefore if one multiplies the minimum bur n rate of cordwood for an average size fireplace of 3.3kg / hr as noted by Dr Houc k, by the minimum average burn duration of 4.4 hours for wood users in N. California, a wood burning household would consume 14.52 kg (32lbs) of fuel during a typical fire occasion. In comparison a household burning firelogs for the average burn durati on reported above would only burn one 5-6 lb firelog.

So, contrary to your staff’s assertion that people who burn wood fi res for aesthetics may

burn less wood than the recent emissions studies utilized, the facts do not support such a hypothesis. The average household burning wood in an open fireplace in the Sacramento Metro area clearly burns more mass of fuel per fire for a longer period than households that burn firelogs, and wood burning hous eholds generate far more emissions.

2. Are firelogs more emissive if mis-used contrary to manufacturers usage

instructions?

Another concern stated by staff during our re cent meeting was that if the Air District began to promote firelogs as a cleaner burning for open fireplaces, traditional wood burners might burn more logs than prescribed by the manufactures’ directions and negate

the lower emissions benefit that occurs as a result of the user burning less fuel with firelogs during a typical fire occasion. Agai n, this is a fair question, but it is again a hypothesis for which there is no supporting causal data.

To give you some background, firelogs are design ed to be used one at a time – no matter the brand or size. All firelog packaging in structs consumers to us e the product in this

manner. Such instructions are uniform th roughout the industry based on compliance with a UL safety Classification for our product ca tegory. There are different size firelogs for different applications / lengt hs of fires, whether 2 hours or upwards of 4 hours. Approximately 70% of the firelogs sold in the marketplace today are the 5-6lb size which

burn from 3-4 hours.

As noted in the above-cited 2003 CARB firepl ace usage survey the average user of firelogs burns their fireplace for 3.3 – 3.4 hours. This is consistent with burning one 5 or 6lb firelog as prescribed by manufacturers instructions.Duraflame, Inc. P.O. Box 1230, Stockton CA 95201 Phone: 209.461.6600 / Fax: 209.462.9412 info@duraflame.com / www.duraflame.com The retail cost of firelogs also creates a disincentive to burning multiple logs in one occasion. The average retail price of a si ngle 5-6 lb firelog today is between $3-$4. Burning two logs would cost $6-$8 per fire wh ich is more than the homeowner who uses their fireplace for secondary heating purposes would be willing to spend.

Due to the high energy content per mass of fuel burning two firelogs at a time, or adding a second firelog to an existing fire will pr oduce a very aggressive fire that could be unsafe, which is why our industry recommends against this practice. Attached you will find some photos of two (6 pound / 4 hour) fi relogs burned in a standard 36 inch manufactured fireplace, the most comm on size wood burning fireplace installed in densely planned subdivisions in the Sacramen to Metro Area. One set of photos show two logs that were ignited at the same time, a nd the other shows the fire produced when one firelog was added to the fire after the first l og had been burning for about one hour. You will note that burning two 6lb logs produces a raging fire that would produce too much heat and flame that would alarm the average homeowner. They would likely only do this one time before learning that bu rning two logs at a time is not necessary and may not be

safe.

While, people could burn more than one log in a large masonry fireplace, these are not

the standard in most homes t oday. If a consumer were to choose to burn more than one firelog it is likely the woul d do so by burning one log in su ccession to the other. This would extend their burning time to 6-8 hours, depending on when the second log is added to the fire, which would be contrary to th e average burn durations for fireplace according to the CARB 2003 Fireplace usage study.

Even in the event that the minority of house holds with large masonry fireplaces in the

Sacramento Metro area decided to burn two fi relogs their fireplace, firelogs would still produce fewer emissions than burning and a wood fire for an equivalent time period in an open fireplace.

1. Firelogs 2 x 2.72kg (6lb) = 5.44kg of fuel consumed over 5 hours 5.44kg x 14.2 g/kg pm 1 = 77.25 g particulate matter emitted 77.25 g-pm / 5 hours = 15.45 g-pm / hour

2. Cordwood 3.3kg / hr (minimum functional burn rate for a fireplace) 3.3kg / hr x 5 hours = 16.5kg of fuel consumed over 5 hours 16.5kg x 13 g/kg pm 2 = 214.5 g particulate matter emitted 214.5 g-pm / 5 hours = 42.9 g-pm / hour

1 Mean emission factor of Total Particulate emissions for manufactured firelogs cited from 2005 Environment Canada / EPA region 5 study “Content and emission characteristics of Artificial Wax Firelogs”

2 Mean EPA method 5H emission f actor of total particulate emissi ons for Cordwood from 167 fireplace emission tests – Source January 200 5 Omni Environmental Services “D evelopment of a Fireplace Baseline

Particulate Emission Factor Database”Duraflame, Inc. P.O. Box 1230, Stockton CA 95201 Phone: 209.461.6600 / Fax: 209.462.9412 info@duraflame.com / www.duraflame.com This example clearly demonstrates, that even a household chose to burn more firelogs than manufacturers prescribe, or that inde pendent usage studies indicate to be normal, they would still produce 64% fewer particulate emissions than burning cordwood for a comparable time period. So again the Districts co ncerns that increased usage, or misusage for firelogs would increase emissions and negate the emission reduction benefits of burning firelog are without merit.

3. Do firelogs emit more air toxic compounds than burning cordwood?

During our recent meeting you pointed out that your review of the recent tests conducted for the Puget Sound Clean Air Agency to compare the Dioxin / Furan Air emissions of manufactured firelogs vs. cordwood indicated that such emissions for firelogs were greater than those of cordwood. You were correct that when looking at the emissions data on a grams of pollutant emitted / kg of fuel combusted basis firelogs produced 1/3

more dioxin / furans emissions than cordw ood. However the grams of pollutant emitted per hour of a comparable fire duration data from the same test demonstrated firelogs produced 3/4 less toxic emissions than burning cordwood.

Again for the reasons outlined above, namely firelogs contain a much higher energy

content that is combusted at a much lower bur n rate than cordwood, it is not realistic to attempt to make apples vs. apples comparis ons of emissions on a mass of emissions per mass of fuel basis, when the fuel products being compared are apples and oranges.

What you may have overlooked from reviewing the recent test reports though is that the Dioxin / Furan emissions for both firelogs a nd cordwood were extremely low in relative terms. Further, most of the air toxic compone nts used to calculate the total Dioxin / Furan emissions of firelogs were non-detectable, and therefore the appr oved EPA protocol for measuring dioxin emissions requires that 1⁄2 of the detection limit must be added to the

calculation for a non-detectable component, thereby resulting in a potential overstatement

of the real total volume of such emissions . Finally, since the emissions of Air Toxic components including Dioxin / Furans for firelogs is so low, the test laboratory had to burn two firelogs in successi on in order to collect enough emission material to allow them to detect any level of air toxic compone nts from firelog emissions. Thus when used according to the manufactures instructions, th at is burning one firelog per fire occasion, the Air Toxic components of firelog emissions are extremely low, if not undetectable.

4. If the District promotes manufactured fi relogs as a clean burning alternative for fireplace use will it confuse households about what is acceptable to burn and undercut its goal to reduce residential wood combustion emissions by advocating less or no burning of so lid fuel in fireplaces?

At our recent meeting your Comm unications Director pointed out that even if firelogs are cleaner to burn than cordwood in an open fi replace, they still pr oduce emissions greater than not burning at all. She went on to state that since the District is just beginning to intensify its efforts to edu cate the public abou t the need to redu ce residential woodDuraflame, Inc. P.O. Box 1230, Stockton CA 95201 Phone: 209.461.6600 / Fax: 209.462.9412 info@duraflame.com / www.duraflame.com combustion emissions it was important to k eep the message simple and advocate that converting a fireplace to natural gas fuel or not using fireplaces at all are the lowest emission alternatives. We won’t argue that firelogs don’t generate emissions, but we do disagree with the strategy of not advoca ting all clean burning options available to

consumers.

There appears to be a double standard in th e Districts policy on what it will advocate as clean burning and what it will not. In th e case of wood burning stoves the District is advocating that consumers change out old wood burning appliances to newer, cleaner burning wood or pellet fueled heating stoves. These appliances sti ll produce particulate

emissions but far fewer than old wood fueled stoves. A gas fueled stove produces even fewer particulate emissions vs. a wood-burni ng stove, yet it still encourages cleaner burning wood stoves or pellet stoves as an alte rnative. If the di strict is willing to advocate cleaner burning solid fuel options for wood heating, than it should be consistent and advocate proven cleaner burning fuels such as firelogs for aesthetic use in wood burning fireplaces.

What is even more confusing with the Distri cts policy, is that it does advise households that plan to burn cordwood in fireplaces to burn seasoned wood, which certainly is cleaner than burning “green” wood, yet in sp ite of numerous independent tests that demonstrate firelogs burn signi ficantly cleaner than even se asoned wood, the District has decided to discontinue its prior policy of advocating firelogs as a cleaner burning alternative. We fail to accep t the logic in this policy ch ange as a fair and reasonable approach when the District is willing to advoc ate other uses of solid fuel as clean burning options.

While we can appreciate the District’s desire to present a simple message to the public, even the simplest most concise message will ha ve little impact if it is not a message that the public is receptive too. A simple message of “do not burn in your fireplace” will not be as readily accepted as a message that indi cates there are options to burn cleaner in your fireplace. The public today is more envi ronmentally aware than ever, and while they are not ready to give up their everyday comforts, they are willing to make incremental changes in their behavior. The overwhelmi ng demand and growth in sales of expensive hybrid fuel vehicles is a good ex ample of this trend. The public is still not willing to cut back the amount they drive in their vehicles, but they are willing to purchase vehicles that will use less fuel for economy and environm ental benefits. The fact that a growing number of people are willing to pay more for fu el efficiency than will ever be paid back by the efficiency gain is a demonstration th at more people see the need to do the right thing for the environment, particularly when it doesn’t require them to drive any less.

We suggest that advocating manufactured fi relogs as a clean burning alternative to burning cordwood for the hundreds of thousands of open fireplaces in the Sacramento Metro Area could be your hybrid vehicl e strategy for cutting residential wood combustion emissions. People are going to cont inue to use their fire places regardless of your messaging but if you give them an option to use them in a cl eaner burning fashion people will begin to change their burning habits and you will see a real reduction inDuraflame, Inc. P.O. Box 1230, Stockton CA 95201 Phone: 209.461.6600 / Fax: 209.462.9412 info@duraflame.com / www.duraflame.com residential wood combustion emissions from open fireplaces. We know it will work because the strategy has been proven in the Puget Sound area, which was once a nonattainment area for PM 10 emission. The Puget Sound Clean Air Agency achieved PM10 attainment without ever banning the installa tion of a wood burning fireplace, but instead by creating meaningful partners hips with all stakeholders to cooperatively implement a multifaceted strategy of educati ng the public about how to burn cleaner with tools such as new clean burning appliances and clean burni ng fuels such as manufactured firelogs. We are confident the Sacramento Metro Air Qualit y Management can achieve this same level

of success.

We aren’t asking the District to carry a ll the burden of communicating this message either. All we ask is that you change your recently modified neut ral strategy regarding burning of firelogs to one that advocates them as one of se veral simple cleaner burning tips for open fireplace use. With your suppor t our industry will take the initi ative of spreading this message to the public, and to the extent you are willing to engage in cooperative communications we are ready and w illing to partner with the District in promoting its residential wood comb ustion emissions reduction messages.

Larry, we trust we have addressed all of the concerns expressed by your staff at our recent meeting. We really desire to be a pa rtner of the Air District instead of an adversary. We hope that your re view of our comments herein will once again open a path for your District and our i ndustry to pursue a win / wi n strategy to reducing RWC

emissions.

Best Regards,

Chris Caron Vice President, Brand Development

cc; Bob Cline, Cline & Dupliessea Erika Schmidt, Frause PR

Attch;OMNI Environmental Services, Inc.

Consulting 6 Engineering 6 Testing

5465 SW Western Avenue • Suite G • Phon Phone: (503) 643-3788 Beaverton, Oregon 97005 • USA Fax: (503) 643-3799
Email: houck@omni-test.com September 13, 2006

Chris Caron Duraflame, Inc.

2894 Mount Diablo Blvd. Stockton, CA 95203

Dear Chris,

In response to your question regard ing the burn rate of cordwood in fireplaces used to compare the air emissions from commercially available wax/fiber firelogs th at were part of the two recent testing programs sponsored by Environment Cana da (EC), I offer the following information. The first EC testing program (administered by U.S. EPA Region 5), which focused on a number of key pollutants (NO

x , VOC, PM 2.5 , PAH, CO, benzene, and formaldehyde), made measurements of these pollutants for five firelog brands. Direct measurement of emissions from cordwood was not funded. Comparison with cordwood was accomplished by using literature values compiled in a refereed Air and Waste Management Association publication, which in turn, compiled test results from a broad spect rum of fireplace operations and cordwood fuels (multiple fireplace models and nine tree species were used for fuel). These data were from work conducted for the Oregon Department of Energy, work conducted for Duraflame, Inc., work conducted by the Canadian Combustion Resear ch Laboratory, work conducted by Shelton Research, Inc., and work conducted by B.C. Re search. The second Environment Canada study (administered by the Puget Sound Clean Air Agen cy – PSCAA), which measured dioxin and furan (TEQ values) emissions, as well as, the key pollutants listed above on one additional firelog (a west coast manufactured Duraflame product) did directly measure emissions from cordwood for comparison and in that case the cordwood burn rate was 3.3kg/hr (dry reporting basis).

It is my understanding that there is concern a bout cordwood burn rates for fireplaces used for aesthetic purposes being less than for fireplaces used for heating and, that because of this, difference the comparisons between air emissions from cordwood and wax fiber firelogs are not applicable to the aesthetic use of fireplaces in the Sacramento area. This is not the case for several reasons: (1) The distinction between the aesthetic and heating use has been traditionally based on the number of fires per year rather than the intensity of the fires. The distinction between aesthetic use and heating use is a “gray” area as both the enjoyment and the utility of a fireplace share a common commodity – heat. Ge nerally, if a home occupant reports using a fireplace less than several times a year it is cons idered aesthetic use. (2 ) There is only a small range of burn rates that are reasonable for a given fireplace size regardless of whether its use isdescribed as for heating or aesthet ics and the burn rate is also la rgely independent of the climate where the fireplace is located. For a standard 36 -inch fireplace, the burn rate range would be about 3.0 to 5.0 kg/hr (dry reporti ng basis). The 36-inch size is the most common size in the Sacramento area. Below about 3.0 kg/hr the fire does not burn well and can go out. Above about 5.0 kg/hr the fire is too hot for most rooms a nd also can become a fire hazard. It should be remembered that a fireplace is a room heater, not a centralized heating system, its heating use is almost always classified as “secondary” not “p rimary” and its heat output doesn’t, and can’t, tract heating demand well. It should also be remembered that while true wood heaters (freestanding stoves and fireplace in serts) have air controls that re gulate fires, fireplaces have no

such controls – fire burn rates are primarily a function of how mu ch wood is put into the unit, which has practical limits. (3) According to a su rvey conducted by the University of California, Berkeley in 2002, for the Sacramento Valley, 56% of the respondents that use fireplaces reported using them for aesthetics and 44% using them for heat . Even if there is a slightly lower burn rate on average for fireplaces used for aesthetics, the impact is diluted by the high fraction of fireplaces that are used for heating.

Over the last two decades, there have been num erous studies conducted by various laboratories funded by both the private and public sector that show wax/fiber firelogs offer an air emission reduction as compared to cordwood use in fire places. Emission comparisons for fireplaces should be on a mass pollutant per unit time, not mass of pollutant per mass of fuel burned. Wax/fiber fielogs have a heat content of about 15,700 Btu/dry pound of fuel as compared to wood, which averages about 8900 Btu/ dry pound of fu el. In addition wax/fiber firelogs average 2.2% moisture (dry basis) as compare to typi cal well-seasoned cordwood, which averages 24.1% moisture (dry basis). Less ener gy is required to evaporate the wa ter from firelogs as an equal mass of cordwood. Due to the higher heat conten t and lower moisture content, a lower mass of firelogs is needed for the same heat output. Further, one-at-a-time usage instructions are included with most firelogs and the use of multiple 5 lb or 6 lb firelogs produces an obviously unsafe fire, which would be found to be unaccept able by most consumers. Reflective of the higher heat content, lower water co ntent, and one-at-a-time use, the average firelog burn rate in fireplaces is 0.74 dry kg/hr – si gnificantly less than cordwood.

The results of the second Environment Canada (PSCAA) study, which consisted of a western Duraflame firelog burned in a typical 36-inch fi replace and of cordwood burned at a rate of 3.3 kg/hr, provide a snapshot of the level of emission reduction achievable for fi relog use in lieu of

cordwood in the Sacramento area. The PM 2.5 emissions at a level reflective of aesthetic fireplace use are 6.79 g/hr for a wax/fiber firelog and 26.7 g/hr for cordwood, respectively. In addition the emission rates for all other air pol lutants measured, importantly including dioxin TEQ values, were less for the normal use of a firelog than for the use of cordwood.

I hope this information answers your questions. If you have any other questions please do not

hesitate to contact me.

Sincerely,

James E. Houck, Ph.D.