# Tacoma
- Pierce County

Clean Air Task Force

www.CleanAirPierceCounty.org Report and Recommendations to Puget Sound Clean Air Agency

December 2011

Puget Sound Clean Air Agency 1904 Third Avenue

- Suite 105, Seattle, WA 98101

- 3317

Phone: 206.242.8800 or 1.800.552.3565 Fax: 206.343.7522Tacoma

– Pierce County Clean Air Task Force Report and Recommendations, Dec . 2011 ii 

## Tacoma

– Pierce County Clean Air Task Force

Name Affiliation Gary Brackett Manager, Business & Trade

– Tacoma

- Pierce County Chamber Earl Brydson Community Member
, S outh End Neighborhood Council President
Frank DiBiase Tacoma

- Pierce County Health Department Jake Fey Tacoma City Council & Puget Sound Clean Air Agency Board
Dr. Soon Han * Community Member, Korean Women’s Association
Jesse Hart Community Member
, Eastside Neighborhood Council Vice President
Jason Jordan Port of Tacoma
Nicole Martineau Formerly Puyallup City Co uncil & Pierce County Regional Council (term

ended in December 2011) Kelly McGourty P uget S ound R egional C ouncil
Liz Norton Puget Sound Energy
Tom Olsen Joint Base Lewis

- McChord Public Works
Terri Patterson * Pierce County Chapter of Residential Property Managers
Janet Primomo UW Tacoma Nursing and Healthcare Leadership Program Julio Quan Community Member , Former D irector of Centro Latino
Lisa Rennie Tacoma Public Utilities Catherine Rudolph Tacoma

- Pierce County Association of Realtors
Tim Sexton W ashington S tate D epartment of Transportation Gary Smith Northwest Hearth, Patio and Barbecue Association
Hermine Soler Community Member Tiffany Speir Master Builders Association Hugh Taylor Pierce County Council Staff
Steve Webber Community Member

Ex

- Officio Members Stu Clark Washington State Department of Ecology Craig Kenworthy Puget Sound Clean Air Agency
*Did not complete term on task force nor vote on the recommendations.Tacoma

– Pierce County Clean Air Task Force Report and Recommendations, Dec . 2011 iiiTacoma

– Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 iv 

## Contents

Abbreviations

................................ ................................ ................................ ................................ ............... vi
Executive Summary

................................ ................................ ................................ ................................ ....... 1

I. The Air Quality Problem

................................ ................................ ................................ ...................... 10

A. Fine Particle Pollution

................................ ................................ ................................ ..................... 10 Air Quality Monitoring and Pollution Levels

................................ ................................ ....................... 11
What Is the Area of Concern?

................................ ................................ ................................ ............. 16

B. Implications of Nonattainment to Public Health and Regional Economic Development

............... 19

C. Steps Needed

................................ ................................ ................................ ................................ .. 20

II. Clean Air Task Force and Its Charge

................................ ................................ ................................ .... 22

II I. Task Force Process for Developing Recommended Solutions

................................ ........................ 23

A. Evaluation Criteria and Tools

................................ ................................ ................................ .......... 24

B. Potential Solutions

................................ ................................ ................................ .......................... 25

C. Foc using the Solutions

................................ ................................ ................................ .................... 26

D. Evaluation of Solutions

................................ ................................ ................................ ................... 27 Time of Sale Removal or Decommissioning of Uncertified Wood Stoves and Inserts

....................... 28
Enhanced Burn Ban Enforcement

................................ ................................ ................................ ....... 29
Date Certain Removal of Uncertified Wood Stoves and Inserts

................................ ......................... 32
Reductions in Other Sources of Pollution

................................ ................................ ........................... 34

IV. Public Outreach and Input

................................ ................................ ................................ .............. 37

V. Recommended Solutions and Principle Statements

................................ ................................ ........... 41

A. Enhanced Burn Ban Enforcement

................................ ................................ ................................ ... 42

B. Date Certain Removal of Uncertified Wood Stoves and Inserts

................................ ..................... 44

C. Making Progress Toward Clean Air

................................ ................................ ................................ . 46

D. Contingency Measures

................................ ................................ ................................ .................... 49

E. Task Force Consensus on Recommendations

................................ ................................ ................. 50

VI. Next Steps

................................ ................................ ................................ ................................ ...... 52 Appendix A Demographics of the Nonattainment Area

................................ ................................ ............. 53 Appendix B Ground Rules: Clean Air Task Force

................................ ................................ ......................... 54 Appendix C Evaluation Tools

................................ ................................ ................................ ....................... 56Tacoma

– Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 v

Appendix D Solutions Developed by Task Force: Organized by Potential for Pollution Reduction

............ 58 Appendix E Assumptions Made in Solution Analysis

................................ ................................ .................. 66 Appendix F Hea lth Effects Studies

................................ ................................ ................................ .............. 72

Table of Figures
Figure 1. Fine Particle Pollution at Tacoma South L Street Monitor, Compared to Old and Current Federal 24

- Hour Standards

................................ ................................ ............................ 12 Figure 2. Annual Average Fine Particle Pollution at Tacoma South L Street Monitor

................................ 13 Figure 3. Tacoma South L Stree t Fine Particle Pollution by Month, 2000

– 2010

................................ ...... 14 Figure 4. Sources of Fall and Wintertime Fine Particle Pollution at Tacoma South L Street Monitor

........ 15 Figure 5. Map of Nonattainment Area, with Topography

................................ ................................ .......... 16 Figure 6. Map of Nonattainment Area, with Jurisdiction Boundaries

................................ ........................ 17 Figure 7. Process for Developing Task Force Recommendations

................................ ............................... 23 Figure 8. Example of a Progress Thermometer

................................ ................................ .......................... 28 Figure 9. Overarching Themes from Combined Online, Public Open House, and Telephone Comments

. 38 Figure 10. Location of Online Survey Respondents by ZIP Code

................................ ................................ 39 Figure 11. Location of Public Open House Attendees by ZIP Code

................................ ............................. 40 Figure 12. Progress Thermometer for Task Force Recommendations

................................ ....................... 47 Figure 13. Proportion of Emission Reductions by Category in 2014, 2017, and 2019

................................ 49

Table of Tables
Table 1. Wood Burning Devices in the Nonattainment Area

................................ ................................ ...... 17
Table 2. Wood Use for Heat in the Nonattainment Area

................................ ................................ ........... 18
Table 3. Timeline

................................ ................................ ................................ ................................ ......... 19 Table 4. Evaluation Criteria and Ratings Used to Assess Potential Solutions

................................ ............. 24 Table 5. Task Force Ranking for Potential Use of Funds

................................ ................................ ............. 46 Nonattainment Area Demographics

................................ ................................ ................................ ........... 53Tacoma

– Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 vi 

## Abbreviations
Clean Air Agency: Puget Sound Clean Air Agency

Ecology: Washington State Department of Ecology

EPA: United States Environmental Protection Agency

HOV: high occupancy vehicle

PSCAA: Puget Sound Clean Air Agency

RACT: reasonably available control technology

SIP: State Implementation PlanTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 1 

## Executive Summary
The following provides a summary of the Tacoma

– Pierce County Clean Air Task Force final report. The task force was created in early 2011 to help the Puget Sound Clean Air Agency (Clean Air Agency) address a local fall and winter air quality problem

. The task force was asked to recommend community

based solutions to help the area meet federal air quality standards for fine particles. The Task Force learned that much of the typical pollution sources, such as industry and vehicles, are already operatin g under pollution control rules or are adopting tighter controls, and that about one

- third of the needed pollution reductions will come from those sources.

With wood smoke making up 50 percent of the particle pollution, the Task Force recommended two key

s olutions to reduce those emissions. One solution focuses on reducing spikes of pollution during weather inversions. The other focuses on reducing pollution from older more polluting uncertified wood burning devices. The task force recognized that the probl em will not be solved by addressing only wood smoke, but it cannot be solve d if wood smoke is not addressed.

Type of Pollution and Area of Concern In 2009, the U.S. Environmental Protection Agency (EPA) classified parts of Tacoma and Pierce County as a “n onattainment area” for fine particle pollution (or PM 2.5 ) under the federal Clean Air Act. During certain times of the fall and winter, the area does not meet the federal health standard for the maximum level of this pollutant allowed in a 24

- hour period

. F ine particle pollution comes mainly from combustion (burning) of fuels. Sources include wood smoke (from wood stoves, fireplaces, and burning of yard waste and land clearing), exhaust from motors (from cars, trucks, buses, ships, etc.), and industrial ope rations.

The levels of pollution are documented by one of the Clean Air Agency ’s air monitoring stations , which is located in the South End of Tacoma at South L Street. While not as high as the South End monitor, fine particle pollution levels are also el evated at other Pierce County monitoring sites . The violations occur in the late fall and winter months, usually on days of meteorological “inversion,” when a layer of cold air is trapped close to ground level, and pollutant levels build up rapidly.

Pollut ion Sources

M ore than half (53 percent) of the fine particle pollution measured at the Tacoma South L Street monitor during the fall and wintertime is from wood smoke, with another 25 percent from diesel and gasoline vehicles . Other fine particle pollution sources in fall and winter months are: industrial (10 percent), sea salt (5 percent), ships (4 percent), dust (2 percent), and fireworks (1 percent). Of the 53 percent of fine particle pollution from wood smoke, uncertified wood stoves are estimated to contribute just over half of this pollution, with certified wood stoves contributing more than a quarter, fireplaces a little less than a quarter and pellet stoves less than 1 percent. The highe st pollution levels occur at nigh t and early in the morning when more people are home and using their wood stoves and fireplaces

.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 2

Implications of Nonattainment
Not attaining federal air quality standards impacts health and potential ly impacts regional economic development. The fine part icle pollution in the air poses a serious health risk to people who live and work in the nonattainment area. Fine particles can easily enter the lungs and travel into the circulatory system, affecting the heart and lungs. All residents are affected, althou gh c hildren, older adults, and people with respiratory and cardiac illnesses are especially at risk.

Effects on economic development include stricter requirements on large industries seeking to expand and on new large businesses interested in moving to t he area. Some large businesses could be required to install additional emission control equipment , which would be costly . Tourism can also be affected by the perception that the area has “dirty” air.

There are also consequences for failing to act. If the state does not create a plan for improving air quality that is approved by the EPA, the Clean Air Act requires EPA to impose its own plan on the area. Th e i r plan would not necessarily clean up the problem in the way the local community might prefer. Not

ac ting also would endanger federal transportation funding for the region , and grant funding for air quality monitoring, planning
, and control programs.

To respond to the nonattainment designation and to show how the area will achieve cleaner air, the
state D epartment of Ecology (Ecology) must develop a State Implementation Plan (SIP) and submit it to the EPA for approval by December 2012. The area is required to get into attainment by the end of 2014 but can seek a series of extensions if it can show substant ial progress in reducing pollution. (All communities must be in attainment by 2019.)

Scale of the Challenge
The fine particle levels at the Tacoma South L Street (violating) monitor need to drop by at least 9 micrograms per cubic meter on peak fall/ winter days , from an average of 42.5 to between 32 and 34 micrograms per cubic meter (a little over 20 percent), in order to reach attainment.

Clean Air Task Force and Its Work to Develop Recommended Solutions

The Clean Air Task Force was asked to identify, evaluate and recommend community

- based solutions to bring the area back into compliance with federal air quality standards

. The 22 members were community leaders, elected officials and residents (see list on page ii). The task force met a total of 11 times between May and December 2011. After developing an understanding of the air quality issues and requirements of the nonattainment designation, the task force worked to identify possible solutions to reduce fine particle pollution in the nonattainment area and to assess which solutions would be the best fit for the community and region. The task force also learned about the solutions that other cities and counties across the country are using to reduce fine particle pollution. To evaluate the possible soluti ons, the task force used criteria the federal Clean Air Act require s and developed additional criteria to reflect the community’s values and interests.

The task force brainstormed potential solutions, producing a list of more than 60 possibilities. The Cl ean Air Agency staff reviewed the solutions for their potential to reduce the level of fine particle pollution inTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 3

the area, and grouped them in to four categories : (1) major reduction potential solutions (to reduce fine particle pollution by 0.5 micrograms per cubic meter or more); (2) supplemental solutions (which would not achieve much reduction alone but could boost the impact of one or more major solutions); (3) low reduction potential solutions; and (4) public education and outreach.

Because wood smoke accounts for more than half of the fine particle pollution in the fall and winter months, the solutions focused mainly on wood smoke. Reductions in pollution are also needed from the other sources of fine particle pollution (vehicles, ships, etc.).

Evalu ation of potential solutions. The evaluation process yielded four solution packages that could produce adequate reductions in fine particle pollution in the nonattainment area: (1) removal or decommissioning of uncertified wood stoves and inserts at the ti me a home is sold; (2) enhanced burn ban enforcement; (3) removal of uncertified wood stoves and inserts at “date certain” in a future year; and (4) reductions from non

- wood smoke sources, such as gas and diesel engines, ships and industry. The task force and agency staff reviewed each in detail. T he task force used several steps to review, discuss, and evaluate each of the potential solutions , including : a presentation by agency staff on each proposed solution; review and discussion of the key assumptions about how solutions would be implemented and the results of technical modeling; review and discussion of the staff’s assessment of the evaluation criteria they were asked to rate; the task force’s assessment of evaluation criteria related to community valu es and impacts; additional review and discussion after the staff revised each solution based on the evaluations; and development of recommendations.

The agency staff and task force worked together to further develop the elements of three of the four solut ions: enhanced burn ban enforcement, date certain removal, and reductions from non

- wood smoke sources. The task force decided not to move forward with the time of sale removal or decommissioning of uncertified wood stoves/inserts solution because of severa l concerns (described in this report).

Public Outreach and Input

The task force allowed for public comment at each of its meetings. In addition, the Clean Air Agency conducted significant public outreach in Pierce County on fine particle nonattainment. The re were two primary purposes: to raise general awareness and to gather public input on the draft solutions the task force was considering . Because of the likely impacts from future implementation of wood smoke reduction programs, special emphasis was given to reaching members of the community who burn wood for heat. Public outreach was conducted throughout the task force process, but was ramped up during October and November 2011. Activities included: mailing a post card to all 220,000 households in the non

- attainment area ; two public open houses with a total of 200 people attending; an online survey; a direct mailing; print and online advertising; and outreach throughout the year to approximately 30 community groups. As a result of these efforts, the Agency received more than 600 comments.

Overall, the majority of respondents indicated full or qualified support for the proposed solutions while expressing concerns about the possible impacts on some community members. Four major themes emerged: (1) s trong concerns about the economic impacts of the potential solutions , particularly forTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 4

lo w

- and fixed

- income families; (2) a large proportion of people expressed concerns about the impacts of wood smoke on their health and in their neighborhoods ; (3) a sm aller number expressed disbelief that wood smoke is a significant source of pollution ; and (4) a small number expressed concern that efforts to address wood smoke are intrusive and a waste of taxpayer money.

Recommended Solutions and Principle Statements
No single solution would enable the nonattainment area to reduce fine particle pollution sufficiently to achieve the federal air quality standard. The task force is recommending a combination of strategies to improve air quality in a timely manner and to h elp the area reach attainment. The three main strategies recommended by the task force are:

1. Enhanced enforcement of burn bans
2. Establishment of a date certain for removal of uncertified wood stoves and inserts 3. Implementation of the range of strategies to re duce fine particle pollution for gasoline vehicles, diesel vehicles, industries and ships.

Th e Clean Air Act allows education and voluntary measures to account for only up to 6 percent of the total emission reduction needed to achieve attainment because t hese measures are not considered enforceable and are difficult to measure. However, the task force firmly believes that the recommended solutions will not be successful without considerable public education
, community outreach , and public involvement

. Loca l communities must first understand the nature of the problem and then take ownership of the actions needed to improve air quality. Education and outreach are needed to help residents understand the causes and impacts of fine particle pollution, to encoura ge residents to take informed actions, and to overcome the skepticism many members of the public may have about why these steps are needed. Outreach and education must include efforts to reach individuals who may not receive information from traditional ci vic or community organizations.
The task force also expressed concern that the solutions being recommended could create an economic burden on residents in the nonattainment area. As a result, they are proposing that the solutions be implemented in a manne r that will provide assistance to low

- income residents.

The following provides several overarching principles the task force wants to see used in implementing the solutions described below.

Overarching Principle Statement

 All residents and communities in the nonattainment area should contribute to the solution. We

a re all in this together.

Common Principles for Implementing All Solutions

 Education efforts are a key component to ensure effective implementation.

 Outreach should be broad

- based and include groups that are less likely to receive notice or support.

 Individual strategies should be consistent and complement other strategies.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 5

The task force recommendations regarding reduction of wood smoke pollution include a combination of suggested program desi gn features and statements of principle t o guide the future implementation of these solutions.

Recommended Solution 1: Enhanced Burn Ban Enforcement Goal: Ensure that those who are contributing the most to the fine particle pollution during periods of the poorest air quality reduce their emissions. The task force felt that this potential solution would be effective because it would f ocus action during the days of the year when fine particle pollution in the nonattainment area exceeds the federal 24

- hour air quality standard. The solution also builds on an existing regulation (issuance and enforcement of burn bans) that is familiar to many residents.

Pro posed Key Features of Enhanced Burn Ban Enforcement: The task force is recommending a number of changes to the way in which burn bans are currently called and enforced in the nonattainment area. The changes include the following: revis e the emission thres holds for calling burn bans; increase enforcement presence during burn bans; enforce violations based on visible emissions (in addition to smoke density); add more evening enforcement, as practical; maintain a two

- stage burn ban ; provide exemptions and/or assistance to low

- income residents and households for whom wood burning is their only adequate source of heat; create a registration program for wood burning devices to make the program more effective; and expand outreach and education efforts.

Statements of Principle to Guide Implementation of Enhanced Burn Ban Enforcement :

 Enhanced enforcement should be combined with a robust community outreach initiative to enable neighbors to talk with neighbors about the importance of obeying burn bans and burning cle anly when the community is not in a burn ban.

 Assistance should be provided for low

- income households who may be affected by this requirement. Enforcement of burn bans should respect the challenges faced by low

- income burners and provide alternatives (e.g. , financial assistance or exemptions), even if these residents have other sources of heat available.

 Enhanced enforcement should be phased in to allow those who receive a first notice of violation to reduce or eliminate the initial fine if they engage in e ducational opportunities about proper burning practices and the importance of burn bans, or move to a cleaner source of heat. The initial fine should be meaningful enough to provide sufficient incentive to participate in education activities and to discour age subsequent burning during burn bans.

 Enhanced enforcement should continue to accommodate households for whom a wood burning device is their only adequate source of heat, while ensuring that the exemption is used only for those who qualify. Exemptions from burn ban enforcement do not exempt people from burning cleanly nor from other standards.

 Decisions about who provides enforcement should be based first on who would be most effective, while respecting the need to consider any capacity challenges of lo cal governments.

 When implementing a registration program, consider that the goal is to enhance effectiveness of enforcement staff and minimize unnecessary interactions with exempted households.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 6

 Revisions to the Stage 1 and/or Stage 2 “trigger” levels (whe n burn bans are called) should be considered, as they may enable burn bans to more effectively keep fine particle pollution below the federal daily standard during inversions, and better protect public health.

 Both forecast and monitored data should be uti lized to call burn bans (as they are both currently used).

Based on the program design features described above, it is estimated that enhanced enforcement of burn bans could achieve a reduction in fine particle pollution of about 1

. 4 micrograms per cubic m eter by 2014 ( nearly 20 percent of the minimum reduction needed); and a reduction of 6

. 8 micrograms per cubic meter by 2019 ( approximately 70 percent of the minimum reduction needed)

.
Recommended Solution 2: Date Certain Removal of Uncertif i ed Wood Stoves and Inserts Goal: Removal of the older, more polluting wood stoves and inserts from the nonattainment area

. Wood stoves and inserts manufactured prior to 1988 produce more pollution and are less efficient than more modern devices. The older stoves and ins erts made prior to 1988 are called uncertified devices. Since wood burning devices can last for 40 years, there are still a considerable number of older uncertified wood stoves and inserts in use. The task force felt that establishing one clear date when a ll residents will need to remove their uncertified wood stove or insert would be effective in reducing fine particle pollution in the long run.

Proposed Key Features of Date Certain Removal: The task force is recommending that all uncertified wood stoves a nd inserts be removed by the end of August 2015; that a combination of incentives, fines, education and regulations be used to encourage residents to remove uncertified devices; that a registration system be created for owners of wood burning devices; and that a “medium” level of confirmation be created to confirm removal of uncertified devices (e.g. including higher fines for using an uncertified device during a burn ban, or technology like GPS

- marked photos to confirm removal). The goal on confirmation is to achieve enough emission reductions in a way that creates the minimal amount of intrusi on in homes as possible.

Statements of Principle to Guide Implementation of Date Certain Removal of Uncertified Wood Stoves and Inserts :

 Households should have a range of options if they choose to replace their uncertified device (including certified device, pellet stove, or other type of heat), but incentives could vary depending on the device they use.

 Assistance should be provided for low

- income households who m ay be affected by this requirement. The assistance could take several forms, including, but not limited to, financial assistance for installing a new heating device, home weatherization, and/or providing additional time for low

- income households to meet th is requirement.

 The solution should accommodate households for whom a wood burning device is their only adequate source of heat.

 Date certain removal should allow time for transitions, yet begin soon enough that the date is meaningful. Timing of implementation should be equitable, be publically acceptable, and allow time to find funding.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 7

 A medium level of confirmation is the preference. But if that is not sufficient to achieve EPA approval or program effectiveness, a more active form of confirmati on should be used. If more rigorous methods of confirmation are needed, they should be equitable and as nonintrusive as possible.

 The purpose of the registration program is to confirm widespread removal of uncertified devices.

 Recognizing the current chall enges in local, state, and federal budgets, funds should be prioritized according to the task force’s ranking, where possible. The task force provided the following rankings for use of resources: 1 st assistance to low

- income households; 2 nd assistance to h ouseholds with no other adequate source of heat; 3 rd incentive payments for early adopters; and tied for 4 th incentive payments of cleaner heat and assistance to all households for removal of stoves/inserts.

It is estimated that date certain removal of un certified wood burning stoves and inserts could achieve a reduction in fine particle pollution of about 0.7 micrograms per cubic meter by 2014 ( less than 10 percent of the minimum reduction needed); and a reduction of 2.5 micrograms per cubic meter by 2019 ( more than 25 percent of the minimum reduction needed)

. The task force concluded that this solution would improve air quality over time and address one of the underlying causes of fine particle pollution. The task force expressed concern about the level o f public and political acceptance of this solution, acknowledging that there are some in the community who will be opposed to limitations on their options for heating their home, or who object to the potential cost to replace the uncertified device with an other stove, insert or other heating device. At the same time, the group recognized that this solution is needed to get to attainment.

Recommended Solution 3 : O ther P ollution S ources Approximately one

- quarter to one

- third of the emission reductions needed to meet the fine particle pollution standard by 2019 will be accomplished from new federal regulations and local initiatives related to non

- wood smoke sources of pollution (vehicles, ships, etc.). Most of these regulations and initiatives are in the proce ss of being implemented.

Nationally, the focus for reducing fine particle pollution related to gasoline vehicles has been on creating cleaner standards for both engines and fuels. The State of Washington has adopted the California Clean Car Standards for v ehicles, the most stringent automobile standards in the country. T he se standards will help to reduc e fine particle pollution. L ocal governments have adopted several programs to reduce fine particle pollution related to gasoline engines , including installing electric vehicle charging stations, using electric and biodiesel vehicles, and adopting anti

- idling programs. T he regional transportation plan adopted by the Puget Sound Regional Council has several policy goals that will help reduce fine particle pollution even further . A number of planned transportation capital investments will also help, such as high occupancy vehicle (HOV) lane extensions, ramp metering, Sound Transit Sounder rail improvements, and investments in alternative means of travel. In addition, the task force suggested continued education efforts that encourage individual car and truck owners to take actions to reduce pollution emissions (e.g. anti

- idling initiatives).Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 8

New federal standards for diesel engines and fuel als o will help to reduce emissions. In addition, several local jurisdictions have adopted programs to reduce emissions from diesel engines and equipment.

Among the industrial sources of fine particle pollution in the nonattainment area, there are six that ha ve been identified by Ecology and the Clean Air Agency as the largest industrial emitters of fine particle pollution. Collectively, these six sources contribute more than 90 percent of the industrial fine particle pollution from industrial sources in the n onattainment area. The federal Clean Air Act establishes a requirement for working with industries to reduce their levels of pollution called Reasonably Available Control Technology (RACT). Engineering staff at Ecology and the Clean Air Agency are review in g the existing pollution controls and operations at the se six industrial sources to determine if they already meet RACT. A preliminary analysis indicates that most
, if not all
, of the sources do.

For ocean

- going ships, n ew international standards require u se of lower sulfur fuel, beginning in 2012 and moving to much stricter levels by 2015. These cleaner fuels will reduce the fine particle pollution from ships. The Port of Tacoma and its tenant, Totem Ocean Trailer Express (TOTE), have also installed shore power facilities and retrofitted ships so that ships can use shore power instead of operating diesel engines to create power when at berth.

Together the anticipated reductions from emission sources other than wood smoke are estimated to achieve approximat ely one

- quarter to one

- third of the reductions needed (2 to 3 micrograms) to reach the federal 24

- hour air quality standard by 2019. Most of the emission reductions from these other sources of fine particle pollution will come from changes in federal stand ards for more efficient engines and cleaner fuels. C ontinued efforts to reduce emissions from these sources will contribute to the overall plan to achieve attainment.

Making Progress Toward Clean Air

The task force was mindful of the need to meet the feder al Clean Air standard, but also to reduce overall levels of pollution in the nonattainment area. Since high levels of fine particle pollution have been demonstrated to have impacts on human health, the task force wanted the recommendations to first and fo remost, meet the federal standard. While acknowledging that the Clean Air Agency board of directors previously set a more aggressive regional health goal for the area, the Task Force chose to focus solutions on reaching the federal standard of attainment. T he combined effects of the proposed solutions suggest that attainment could potentially be achieved by 2017 assuming the programs were fully supported over the time frame. By 2019, it is estimated that the nonattainment area would achieve fine particle po llution reductions over the federal 24

- hour standard, leaving room should reductions not occur as rapidly as projected or should the standard be lowered (it is up for review in 2012).

Contingency Measures
The State Implementation Plan submitted by Ecology to EPA must identify not only the solutions the nonattainment area will use to meet the air quality standards, but also potential additional measures in

case the area is not making sufficient progress towa rd its target date. These additional solutions areTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 9

called contingency measures. The task force is recommending that the following contingency measures be considered for inclusion in the Plan:

 That cleaner technologies be required for use of fireplaces, suc h as cost

- effective catalysts, starters, or filter technology that has been shown to work (this technology has not yet been demonstrated successfully).

 A requirement that in the nonattainment area only the cleanest burning devices (equivalent to emissions produced by a pellet stove) be allowed. (The task force acknowledged that because the EPA is currently revising its emission testing protocol for stoves, this measure may not be available at the time the SIP is submitted, but could be added at a later date .)

 That the time of sale of a home be used as an opportunity to confirm the removal of uncertified wood stoves or inserts (in addition to the “date certain” removal of uncertified devices )

.

 For households that have an uncertified wood stove or insert as t heir only adequate source of heat, only those that are income qualified would receive assistance or be exempted from the requirement to remove their device.

Task Force Consensus on Recommendations
The task force reached consensus on the recommendations with one exception. This exception was on the recommendation that a system of registration be created for all wood stove and insert owners in the nonattainment area. T hree members did not support th e recommendation for the registration system, because of concerns about the level of response to a voluntary program, about resentment that it might create, about possible confusion as to whether a stove is certified or uncertified and about what registratio n means, and about whether the program might become more regulatory over time

. Next Steps With this report the task force is transmitting its recommendations to the Puget Sound Clean Air Agency. The Agency’s board of directors will review the report and m ak e recommendations to the State Department of Ecology

. Ecology will conduct further analysis and prepare a State Implementation Plan (SIP). T here will be opportunities for public review and comment o n the Plan. Because any local rules or state laws requir ed for the solutions will need to be in place before the SIP is submitted to the EPA, the Clean Air Agency will seek state legislation in 2012 to clarify its existing authority for implementing the recommended solutions.

Ecology must submit the SIP to the EPA by December 2012 for their review and approval. At the same time, the Clean Air Agency will be developing plans and implementing actions to improve air quality in the nonattainment area.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 10



## I. The Air Quality Problem

The Tacoma

– Pierce County Clean Air Task Force was created in early 2011 to help the Puget Sound Clean Air Agency (Clean Air Agency) address a local air quality problem. In 2009 , the U.S. Environmental Protection Agency (EPA) classified part s of Tacoma and Pierce Count y as a “nonattainment area” for fine particle pollution (or PM 2.5 ) under the federal Clean Air Act

. During certain times of the fall and winter, the area doe s not meet the federal health standard for the maximum level of this pollutant

. The pollution comes f rom a variety of sources

. B ut with half of the emissions coming from indoor wood burning (see Figure 4 , below) , it i s a different challenge from past air pollution issues. To be sustainable, solutions must include finding a way to achieve both clean air and warm homes for the citizens of Pierce County.



### A. Fine Particle Pollution Definition. Dust, soot , and smoke are all “particulate matter.” Fine pa rticle s in the air measure 2.5 micrometers in diameter or smaller

– commonly referred to as PM 2.5 . This is a fraction of the diameter of a human hair. In the Pierce County nonattainment area, f ine particle pollution comes mainly from combustion (burning) o f fuels, such as wood and fossil fuels. Sources include wood smoke ( from wood
stoves , fireplaces, and burning of yard waste and land clearing )
, exhaust from motor s ( from cars, trucks, buses, ships, etc.), and some i ndustrial operations. Less significant co ntributions come from sea spray , wind

- blown dust
, and fireworks.

Effect on health and environment. This kind of air pollution affects everyone. The impact on human health can be serious. Fine p articles can easily enter the lungs and travel into the circulatory system, affecting the heart and lungs

. Children, older adults, and people with respiratory and cardiac illnesses are especially at risk. Breathing fine particle pollution can cause coughing, wheezing and decreased lung func tion, even in otherwise healthy children and adults. Exposure to fine particle pollution has been linked to respiratory disease, asthma attacks, decreased heart and lung function, heart attacks, strokes, and premature death. Studies have found that even s hort

- term exposures to fine particles can cause health problems. See Appendix F for a summary of health effects studies and references.

C ertain types of fine particles are considered toxic. For example, both diesel exhaust and wood smoke contain chemicals known to cause cancer. 1 Each year millions of dollars are spent treating illnesses and health conditions stem ming from fine particle pollution that are preventable. 2

Nonattainment d esignation

. The federal EPA, under the authority of the federal Clean Air Act, set s standards and regulations for air quality in communities across the nation. The EPA has set two standards for fine particle pollution. One standard is the 24

- hour partic le standard (calculated by taking the three

- year average of the 98th percentile of the 24

- hour air quality values for each of the three years)

. The other EPA fine particle standard is the annual standard ( calculated by taking the average air quality value for each of the four quarters of the year).Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 11

Much of Tacoma and Pierc e County are currently in “nonattainment” for the 24

- hour fine particle pollution standard (do es not meet the standard of 35 micrograms per cubic meter ) . The EPA designated this area (called “Wapato Hills

– Puyallup River Valley” in some documents) as being in nonattainment as a result of three factors : a change in EPA’s protective standards in 2006 , the fall and wintertime pattern of pollution in the area , and the sources of fine particle pollution in the area. The same area is in compliance with the federal annual standard. (See Figures 1 and 2 for graphic representations of how air quality in the area has compared to both the 24

- hour and annual standards since 2002.) For the remainder of this report
, the area will be referred to as the “ nonattainment area. ” (See Figures 5 and 6 for maps of the nonattainment area.)

Change in EPA protective standards

. The federal Clean Air Act requires the EPA to conduct a comprehensive review of ambient air quality standards every five years to ensure they a re set at levels
p rotective of public health. As part of that review, t he EPA set a stronger daily (24

- hour) air pollution standard (limit) for fine particle pollution in 2006. 3 This action was in response to numerous scientific and health studies that concluded that exposu re to fine particle pollution , even for short periods of time, has serious health effects at lower levels than previously understood. Based on this evidence, the
EPA lowered the federal 24

- hour standard for fine particle pollution from 65 micrograms per cu bic meter to 35 micrograms per cubic meter. The intent was to better protect human health

.
Under the lower daily standard, the nonattainment area’s air quality is considered unhealthy on certain fall and winter days of the year

. Between 2002 and 2010 the a ir quality in the nonattainment area exceeded the federal daily standard on 89 days, or an average of nearly 10 days per year.
Air Quality Monitoring a nd Pollution Levels The Clean Air Agency operates a network of air monitoring stations in the Puget Sound area. The re is a monitor in the S outh End in Tacoma at South L Street

. The levels measured at this monitor are below the former federal standard but are above the current, more protective standard ( s ee Figure 1 )

. While not as high as the South End monitor, fine particle pollution levels are also elevated at other Pierce County monitoring sites , including the Tacoma tide flats, Puyallup South Hill, and in several areas where temporary monitors were located. T hese mo nitors also collect dat a from which the Clean Air Agency can estimate the annual average concentration for fine part icle pollution

. 4Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 12 Figure 1. Fine Particle Pollution at Tacoma South L Street Monitor , Compared to Old and Current Federal 24

- Hour Standards The level of fine particle pollution recorded at this air monitor has remained fairly stable since at least 2002. 4Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 13 Figure 2. Annual Average Fine Particle Pollution at Tacoma South L Street Monitor Since the federal annual standard was announced, the L Street Monitor has remained below the standard. The annual average represents air quality throughout the year

— unlike the daily s tandard, which represents the highest pollution days. 4

Fall and w intertime pollution pattern. The violations of the federal daily standard for fin e particle pollution in the nonattainment area occur in the late fall and winter months ( s ee Figure 3 )

. Looking at fine particle pollution levels by month for a 10

- year period, as recorded at the Tacoma South L Street monitor, shows that the air pollution levels exceeded the 24

- hour standard for fine particle pollution on certain days in January, February, November
, and December. These are most commonly days of meteorological “inversion
, ” when a layer of cold air is trapped close to ground level , and pollutant levels build up rapidly. The EPA finds an area to be in nonattainment of the fine particle pollution air quality standard when the monitored air pollution exceeds the 24

- hour standard a specified number of times each year, using three years of data . This ensure s that an area is not designated as nonattainment just because of one bad year.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 14 Figure 3 . Tacoma South L Street Fine Particle Pollution by Month, 2000

– 2010 Air pollution l evels at Tacoma South L Street m onitor exceeded the standar d for fine particle pollution on certain days in January, February, November
, and December. These are days of meteorological “inversion,” when a layer of warm air traps a layer of cold air close to ground level , and pollutant levels build up rapidly. 5

Sources of fine particle pollution

. Analysis of data from the Tacoma South L Street monitor shows that more than half (53 percent ) of the fine particle pollution during the fall and wintertime is from wood smoke
, with another 25 percent from diesel and gas oline vehicles ( s ee Figure 4 below )

. To identify the sources, a mathematical model is used that utilizes data about the chemical composition of samples collected from the South L Street monitor. 6

Of the wood smoke contribution, uncertified wood stoves contribute approximately 51 percent of the fine particle pollution, while certified wood stoves contribute 27 percent , fireplaces 21 percent, and pellet stoves less than 1 percent . Th e s e estimates are based on the estimated total number of devices in the nonattainment area, the amounts of fine particle pollution that each typically emit, and the way devices are used
, based on survey results. 7

The higher pollution levels occur at night and early in the morning , when more people are home
, and more wood stoves and fireplaces are in use than during the daytime hours. Evening hours are also whenTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 15

colder air is trapped near the ground and winds are nearly stagnant , contributing to pollution levels rising

.

Dur ing the summer months, the fine particle pollution levels are lower overall and the sources are in different proportions, with motor vehicles as the highest source.

Figure 4 . Sources of Fall and Wintertime Fine Particle Pollution at Tacoma South L Street Monitor Analysis of data from the Tacoma South L Street monitor shows that more than half (53%) of the fine particle pollution during fall and winter months is from wood smoke, with another 25 percent from diesel and gasoline vehicles.
Size of problem. Th e fine particle levels at the Tacoma South L Street monitor need to drop by at least 9 micrograms per cubic meter on peak fall/ winter days , from an average of 42.5 to between 3 2 and 34 micrograms per cubic meter (a little over 20 percent ) , in order to reac h attainment. Not all emissions reductions will have an equal impact at the monitor , based on the location of the emissions and weather conditions . Reductions that take place in neighborhoods where people are living and playing will have a more immediate i mpact on their local air quality.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 16

What I s the A rea of C oncern? Nonattainment area. The Clean Air Act requires that a “nonattainment area” include not only the area that is violating the federal pollution standard, but also nearby areas that contribute to the violation. The Clean Air Agency and Ecology proposed a boundary to the EPA that took into account such factors as: air quality data, emissions information, population density, traffic and commuting patterns, expected growth, weather, topography, jurisd ictional boundaries
, and control of emissions. 8 In 2009 , the EPA approved the boundary. 9 The nonattainment area includes most of Tacoma , including the P ort of
Tacoma and residential areas
, and most of the Pierce County urban growth area, including the citi es and
towns of: Edgewood, Fife, Fircrest, Lakewood, Milton, Puyallup, Ruston, Steilacoom
, and University Place . The nonattainment area also includes the unincorporated communities of Fredrickson, Midland, Parkland, South Hill
, Spanaway, and Summit

- Waller

. Figure 5 below shows the topography and major roads in the nonattainment area ; Figure 6 shows the jurisdiction boundaries. Also see Appendix A for the demographics of the area.

The nonattainment area includes most of Pierce County’s urban growth area
, with two exceptions . The first exception is the areas of south and east Pierce County that have low population density or very few emission sources that contribute to this problem , such as Graham and Orting

. Joint Base Lewis

- McChord has a concentration of population but few fine particle emission sources

. The task force learned that the analysis of fine particle pollution at the South L Street monitor does not show jet fuel to be a contributor to the air quality violations in the area. The second exc eption is areas for which the topography and typical weather patterns make it unlikely that their pollution affects the air quality measured at Tacoma South L Street. These areas include the far eastern portion of Pierce County ( east of the Puyallup River and Wh ite River Valley )

.

Figure 5 . Map of Nonattainment Area, with Topography

The nonattainment area, showing topography, major highways, and larger communities.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 17 Figure 6 . Map of Nonattainment Area, with Jurisdiction Boundaries

Wood burning devices in use in the nonattainment area

. The Clean Air A gency provided estimates of the number of households in the nonattainment area that have wood burning devices and the number in use (s ee Table 1 ), and of the number who use wood as their primary or sole heat sourc e (see Table 2 )

. These estimates were based on results of a survey done by the National Research Center in 2007 7 and
U

. S

. Census data. 10

Table 1 . W ood Burning Devices in the Nonattainment Area

Device Estimated # Households that Have Estimated #

Households that Use Fireplaces 30,900 21,200 Uncertified inserts and wood stoves 24,200 21,200

Certified inserts and wood stoves 20,200 17,200
Pellet stoves 3,900 2,100
Total 79,200 61,700

Source: National Research Center
, Puget Sound Clean Air Agency I ndoor Wood

- B urning Emission Inventory Survey of King, Kitsap, Pierce and Snohomish Counties (2007)

.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 18 Table 2

. Wood Use for Heat in the Nonattainment Area

Number of Households Percent

Use wood as primary source of heat 11 3,4 46 1.7% Use wood as “only adequate” source of heat (definition in statute) 12 unknown Estimate: 0.02% to 0.46%
Wood is the sole source of heat 13 600 0.3%

Definitions of heat sources and wood burning devices

. “Non

- wood heating equipment” refers to equipment used to heat a home that uses natural gas, heating oil, electricity, or another source of energy to heat a home. These source s of heat emit significantly less fine particle pollution than wood
, with natural gas and clean electric heating equipment emitting less than 1 percent of the fine particle pollution of wood burning
, and heating oil equipment emitting less than 2 percent o f the amount emitted by wood burning.
Washington state regulations define “adequate source of heat” as “the ability to maintain seventy degrees Fahrenheit at a point three feet above the floor in all normally inhabited areas of a dwelling” (see Washington State Rule , WAC 173

- 433

- 0 30 )

. There are a limited number of homes located within the nonattainment area, less than one percent , for which a wood stove or wood‐burning fireplace insert is the only, or sole, source of heat (a narrower definit ion than “adequate source of heat”

. ) This figure comes from a review of the U

. S

. Census 2005‐2009 American Community Survey, Pierce County property records and the Clean Air Agency’s wood stove replacement program database.

E ven though a home may have work ing, non‐wood heating equipment that is sufficient to heat the home

— such as a gas
, oil or electric furnace
, or electric heater s — a wood burner might consider his or her wood stove to be the home’s “primary source of heat

. ” According to the 2005‐2009 America n Community Survey, 1.7 percent of respondents with homes in the nonattainment area consider a wood device to be their primary source of heat.

A wood stove is an appliance that is usually made of cast iron, steel, or stone. It can be free standing or made to be installed within the firebox of an existing masonry or metal fireplace.

“ Uncertified ” refers to older, higher polluting
, less efficient
, conventional wood stoves that were manufactured prior to 1988 when the EPA issued emission standards. The internal design of wood stoves and wood burning fireplace inserts changed significantly in 1988. A ny wood stove or fireplace insert can last as long as 40 years
, so there are still an estimated 21,200 un certified wood st oves in operation in the nonattainment area

. Because of their high emissions, uncertified wood stoves cannot be used during Stage 1 or Stage 2 burn bans (see Washington State Rule , WAC 173

- 433

- 150)

.
“EPA

- certified” stoves and inserts are much less polluting (up to 5 0 percent less polluting ) and are more energy efficient than older un certified stoves. In 1988 , the EPA issued standards of performance andTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 19

testing for new wood stoves. 14 New stoves produced or sold in the United States after 1988 had to meet these standards. Additionally, since Jan uary 1, 1995, wood stoves offered for sale in the state of Washington must meet a n emission limit that is more strict than the EPA standard. 15 C ertified wood stoves sold in Washington s tate must meet an emission standard of 4.5 grams/hour for non

- catalytic stoves, and 2.5 grams/hour for catalytic stoves. Certified stoves can be used during a Stage 1 burn ban, but cannot be used during a Stage 2 bu rn ban (see Washington State Rule , WAC 173

- 433

- 150)

. 16

Pellet stoves and pellet fueled inserts are similar in appearance to wood stoves; however, instead of wood, pellet stoves burn a fuel made of ground, dried wood, and/or other biomass compressed into pellets. Because they are solid

- fuel burning devices, they must meet Washin gton s tate’s emission standards

. Because of their design, many pellet stoves are exempt from the requirement to be certified by the EPA. Pellet stoves are recognized by the EPA and Washington s tate as among the lowest emission solid fuel heaters and on ave rage emit about 60 percent less than is required by the Washington standard

. Pellet stoves can be used during a Stage 1 burn ban, but cannot be used during a Stage 2 burn ban

. 16



### B. Implications of Nonattainment to Public Health and Regional Economic Development
Current effects

. Not attaining federal air quality standards for fine particle pollution means that in the non attainment
area, the air quality is not as healthy as it should be. The fine particle pollution in the air at certain times of fall and winter months poses a serious health risk. A study conducted by Ecology estimates that approximately 1,100 people in Was hington die every year because of fine particle pollution. 2

N onattainment can also hinder economic development and tourism in the area and wider r egion

. When Congress wrote the federal Clean Air Act, it decided to provide an incentive to communities to clean their air
, by putting stricter requirements on large industries seeking to expand and on new large businesses interested in moving to the areas with high pollution. Some large businesses could be required to install additional emission control equ ipment. These factors might pro mpt businesses to locate their operations elsewhere. Tourism also might be affected by the perception that the area has

“ dirty” air.

Consequences of failing to act. If the state does not create a plan for improving air quality that is submitted to the EPA by December 2012 , the Clean Air Act requires EPA to impose its own plan on the

area . This plan would not necessarily cle an up the problem in th e way the community might prefer

. Not Table 3. Timeline
2006

– Health studies cause U.S. EPA to tighten the standard for fine particle pollution

2009

– EPA designates a nonattainment area in much of Tacoma and Pierce County

Summer 2011

– Clean Air Agency convenes Clean Air Task Force

Fall 2011

– Clean Air Task Force makes recommendations to Clean Air Agency

Winter 2011/ 2012

– Clean Air Agency submits recommendations to Ecology
December 2012

– Ecology submits State Implementation Plan (SIP) to EPA for approval

2014

– Target for County nonattainment

area to reduce fine particle pollution to meet federal standard

2019

– Final deadline to meet federal standard for fine particle pollutionTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 20

acting also would endanger federal transportation funding for the region , and grant funding for air quality monitoring, planning and control programs , as well as the continued personal and societ al costs from the health impacts caused by unhealthy air

. 17



### C. Steps Needed To respond to the nonattainment designation and show how the area will get to clean er air , Ecology must develop a State Implementation Plan (SIP ) and submit it to the EPA by December 2012 for approval . Th e plan must describe how the state will improve air quality to achieve the air quality standard for fine particle pollution as quickly as possible . The SIP must : (1) define what actions will be taken to control air pollution ; (2) descr ibe how these actions will lead to meeting the air quality standard ; and (3) project when air quality will meet the standard.

T he Puget Sound Clean Air Agency , as the regional air quality regulatory agency with jurisdiction within Pierce County , is workin g with Ecology to draft the SIP. The Clean Air Agency formed the Tacoma

– Pierce County Clean Air Task Force to get advice and ideas from the community about proposed solutions. The goal is to develop a plan that reflects the community’s values.

The SIP for the nonattainment area must meet certain requirements in order to show that the actions included will lead to attaining the federal air quality standard. These requirements are:

 Reduce the maximum d aily fine particle pollution levels recorded at the Tacoma South L Street monitor to below the federal daily standard of 35 micrograms per cubic meter me asured over a
24

- hour period

. This requires reducing current levels by at least 9 (and possibly up to 11
, depending on the results o f the modeling Ecology will do to show attainment ) micrograms per cubic meter on peak fall and winter days

.

 Improve air quality as fast as possible. The plan should target attaining the federal air quality standard by 2014 with a possible extension of one to four years (2019) based on the severity of the problem and feasibility of implementing controls. If the target for attainment is after 2014
, the area must show it will make substantial progress each year and then actually achieve those targets.

 Addre ss all sources of fine particle pollution.

 Use primarily enforceable acti ons with measurable results.

 Since public education and voluntary actions are not enforceable and are difficult to measure, the Clean Air Act allows these efforts to account for only up to 6 percent of the total emission reduction needed to achieve attainment (at least 9 micrograms) . The SIP may contain additional public education and voluntary actions because they will be helpful to achieve attainment, but they may not be considered by the EPA when they approve the SIP

. 17

Only after the air monitoring data indicate that the air quality has improved can the state petition the EPA to redesignate the area from nonattainment to attainment. The EPA can approve the redesign ation if the following conditions are met:

1. Air quality monitoring data show that the area meets the federal standard. 2. Reductions in the area’s emissions are permanent and enforceable.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 21

3. The SIP developed for the area has met the requirements of the f ederal Clean Air Act and has been fully approved by the EPA.
4. The EPA has fully approved a 10

- year Maintenance Plan for the area, which Ecology will submit as a revision of the SIP.
5. The area meets the Clean Air Act’s requirements for general SIPs and nonatt ainment areas.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 22



## II. Clean Air Task Force and Its Charge

The Clean Air Agency formed the Tacoma

– Pierce County Clean Air Task Force in the spring of 2011. The

m embers were community leaders, elected officials and residents (see list on page ii). Craig Kenworth y, t he Executive Director of the Puget Sound Clean Air Agency
, and Stu Clark, the Air Quality Program Manager of the Washington S tate Department of Ecology
, were ex

- officio non voting members. The members were chosen for their expertise and experience in on e or more areas that are important to solving the nonattainment area’s air quality problem. Examples of some of the perspectives included are industry, public health
, and people who burn wood for heat. The Clean Air Agency engaged John Howell of Cedar River Group to serve as facilitator for the task force meetings and process.
The task force’s objective was to recommend to the Clean Air Agency community

- based solutions to bring the area into attainment with federal air quality standards. The solutions must reduce emissions from the main source s of fine particulate matter. The full charge to the task force is reprinted below.

Charge to Tacoma

- Pierce County Clean Air Task Force As a task force member, we ask that you actively participate in identifying and evaluating possible solutions to bring the area back into attainment with the federal air quality standard. These solutions need to reduce emissions from the main sources of fine particle pollution:

woo d stoves and fireplaces, mobile sources (cars, trucks, buses, ships, rail, etc.), and industrial sources. Once possible solutions are evaluated, the group will recommend to the Puget Sound Clean Air Agency those most appropriate for possible inclusion in t he state’s plan.

As part of the process, all task force members are asked to:

 Address the problem and consider possible solutions

 Speak as one voice of the people or interest they represent

 Communicate with those you represent between meetings

— taking information to them, and bringing their concerns and information back to the task force

 Consider the broad interests of all Pierce County residents who may be affected by poor air quality and the range of possible solutions

 Work to find consensus among the task force members in providing advice and recommendations to the Clean Air Agency
In the task force’s first two meetings
, the group developed and adopted a set of ground rules to guide their discussion and decision

- making process (see Appendix B ). The gr ound rules include d three guiding principles: (1) transparency in creating a thorough and open process
, (2) respect for one another’s perspectives , and (3) commitment to recommending the best solutions for Pierce County. The ground rules also provide d that the task force would operate by consensus, with the goal of reaching unanimous consensus, meaning that all members could support or live with the task force recommendations. If the task force could not meet unanimous consensus, the differences of opi nion

were to be noted and included as part of the task force’s final recommendations.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 23



## III. Task Force Process for Developing Recommend ed Solutions

The Tacoma

– Pierce County Clean Air Task Force met a total of 1 1 times

— monthly from May through August 2011 , and twice a month from September through November
, with a final meeting in December

. The initial meetings focused on developing an understanding of air quality issues in the nonattainment

area , the nonattainment designation by EPA
, and the requirements for res ponding to this designation. The task force also reviewed information about what other communities facing nonattainment for fine particle pollution are doing and have done to improve their air quality and meet the federal standards.

Starting in June , t he t ask force work ed to answer three questions: What are possible solutions for reducing fine particle pollution? How do we assess what the best solutions are for our area ? What solutions do we recommend? The task force’s discussions produced a list of more than 60 possible solutions and a set of evaluation criteria

. The agency staff then applied initial technical modeling to the list of possible solutions in order to narrow the possibilities to those that could produce meaningful reduc tions of fine particle emissions. Then the task force used the evaluation criteria to identify the solutions with the best fit for the community. Based on these evaluation steps, the task force developed its recommendations. The figure below shows a graphical representation of t his process.

Figure 7 . Process for Developing Task Force Recommendations
Note : T he “Technical Model” in this graphic refers to a screening tool used by the task force. It is not the official model that will be used in the SIP

.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 24



### A. Evaluation C riteria and Too ls
S taff from Ecology briefed the task force on the evaluation criteria that the federal Clean Air Act requires the state to consider when developing a state implementation plan for fine particle pollution. These are that the solutions must be: r easonable
, t echnically feasible
, e conomically feasible
, t imely
, and

e nforceable.
In addition to these criteria, the Clean Air Agency encouraged the task force to develop criteria that reflect the community’s values and interests. The task force developed possible c riteria at its June meeting, and revised and approved them in July

. The Clean Air Agency staff recommended which criteria the agency should evaluate (those requiring technical expertise) and which criteria the task force members should evaluate (those requ iring judgments from the community’s perspective). Some criteria were evaluated by both the staff and the task force.
The table below lists all the evaluation criteria, the definition f or each criterion, who developed the rating for each one, and what the rating method was. For the criteria that did not have a numeric measurement, the Clean Air Agency and task force agreed to rate by asking the question How well does the solution meet each criteri on?
, with the rating scale of v ery well (V ), s omewhat/mixed ( S), and n ot well ( N)

. Table 4 . Evaluation Criteria and Ratings Used to Assess Potential Solutions
Criterion Definition Who Rated Rating Scale Fall/ Winter Day Ambient Concentration ( Fine Particle Reduction ) Consider how effectively the solution will reduce fine particle pollution concentrations in the air during periods of nonattainment

. PS C AA Micrograms per cub ic meter by 2014 and 2019

Emission Reduction Reductions in the amount of emissions emitted from the sources

. PSCAA Tons of PM 2.5 reduced , and percent of the reduction needed to reach attainment Economically Feasible* Cost is reasonable for the amount of reduction. PSCAA $ per ton in cost
Implementation Can be implemented effectively. There is a commitment to implement/enforce. There is adequate authority to implement. PSCAA Very well (V), somewhat/mixed (S), and not well (N)
Maintainability Will improve air quality over time. Addresses the underlying cause of poor air quality. PSCAA and Task Force V, S, N

Cost and Benefit The cost of the solution is commensurate with the air quality benefits that will be achieved. Task Force V, S, N

Public and Political Acceptance There will be sufficient public and political support for the solution. Task F orce V, S, N

Economic Well

- Bei ng of the County Will enhance the economic development potential for Pierce County. Task F orce V, S, N

Minimize Burden on Vulnerable Will minimize the economic burden on individuals and households. Task F orce V, S , NTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 25

Criterion Definition Who Rated Rating Scale

Communities and Populations

Minimize Unintended Consequences Will minimize the likelihood of unintended consequences. PSCAA and Task Force V, S, N

Funding Availability There is reasonable likelihood that funding needed to carry out the solution will be secured. PSCAA V, S, N

Technically Feasible/ Sound* The solution can be put into practice . E missions can be measured or quantified. PSCAA V, S, N

Timing/Timely* How quickly the solution will produce reductions. Will enable Pierce County to meet the federal timeline
, establish a basis for appropriate next steps , and reach attainment by 2014 (at the latest, 2019). PSCAA V, S, N

Enforceable * Will be independently verifiable . H a s defined violations . C an identify liable person . E nforceable as a practical matter

. PSCAA V, S, N

Reasonable* (encompasses all the other criteria) Not absurd, impractical, unenforceable, or severely disruptive socioeconomically. Focuses on significant emission reductions. PSCAA V, S, N (assessed based on all other criteria)
*Criterion required by the federal Clean Air Act
The task force members each used an evaluation tool to provide their ratings of each major solution. These results were rolled up into the master evaluation tool ( s ee Appendix C)

.


### B. Potential S olutions
At the July and August meetings, the task force learned about solutions that other cities and counties across the country are using to reduce fine partic le pollution, and brainstormed possible solutions for use in the nonattainment area

. This process produced a list of more than 6 0 potential solutions. Clean Air Agency staff organized the list by emissions source

— wood smoke, vehicle s , other

— and public education and outreach.

The staff then reviewed the solutions in terms of the i r potential to reduce the level of fine particle pollution in the area , and grouped them in four categories ( s ee Appendix D )

. The four categories were:

1. Major Reduction Potential Solutions

– four solutions with the potential to reduce fine particle pollution by 0.5 micrograms per cubic meter or more : A. Require removal of uncertified stoves by a date certain, with only non

- wood burning devices allowed as replacements
B. Require removal of uncertified stove s by a date certain, with certified stove s allowed as replacements C. Require removal or changeout of uncertified stoves at time of sale of the home
D. Increase capacity to enforce burn bansTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 26

2. Supplemental Solutions

– 21 solutions that would not achieve very much reduction by themselves or that presented other complications when used alone , b ut if combined with one of the “major reduction” solutions, could help to boost the reduction of that solution.

3. Low Reduction Potential Solutions

– 14 solutions that would not reduce fine particle pollution by very much or had other limitations. T ask force memb ers requested that Clean Air Agency staff evaluate the following three of these solutions:

 L1. Explore filtering technology for wood burning devices to determine if it is effective and affordable

 L3. Lower the threshold for calling the s econd s tage of b urn b ans in the nonattainment area (from 2 5 micrograms to 20 micrograms)

 L9. Develop a program to trade out polluting autos for bikes and/or fuel efficient autos
The rest of the Low Potential solutions were not taken off the table, but were not included in th e evaluations.

4. P ublic education and outreach

— 14 solutions. These were grouped separately because, w hile an important part of the overall solution
, t he federal Clean Air Act allows these efforts to account for only up to 6 percent of the total emission reduction needed to achieve attainment (at least 9 micrograms) . Additional public education and voluntary actions will be necessary to achieve attainment, but may not be considered by the EPA when they approve the SIP

.


### C. Focusing the S olutions
T he Clean Ai r Agency staff provided the task force with an evaluation of each of the four major reduction solutions separately and combine d with supplemental solutions. In discussion, the task force members suggested some possible changes in the solution packages. The solutions the task force and agency staff reviewed were as follows:

 Time of Sale Removal or Decommissioning of Uncertified Wood S toves and I nserts :

o Time of sale solution

o Time of sale solution, with inspections and incentives

o Time of sale solution, adding decommissioning also for fireplaces, with inspections and incentives

 Enhanced Burn Ban Enforcement:

o Enhance enforcement by adding significant personnel capacity during burn bans

o Combined solutions for enhanced enforcement :

 implementing a registration program

 enforcing based on visible smoke standard
, rather than illegal smoke density

 adding enforcement personnel beyond the initial addition

 modifying when a burn ban is called (modifying the “triggers”) to reduce the number of impaired air quality days

 e nforcing the ban more effectively during evening hours

 increas ing awareness of burn bansTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 27  increas ing education and outreach

 Date Certain Removal of Uncertified Wood S toves and I nserts with a V ariety of O ptions :

o Date certain removal, and restrict replacemen ts to non

- wood sources; registration
program

o Date certain removal, and allow certified wood stoves as replacements; registration
program

o Date certain removal, and allow pellet stoves (pellet stoves are significantly lower in

em issions) or a wood st o ve wit h emissions equivalent to a pellet stove as replacements; registration program



### D. Evaluation of Solutions Once the list of potential solutions had been narrowed to those that have the greatest potential to reduce fine particle emissions in the nonattainment area , the task force used several steps to review, discuss
, and evaluate each of the potential solutions. The process involved the following:

 Presentation of a description of each proposed solution, including appropriate background in formation, as needed

 Review and discussion of the key assumptions used to conduct the evaluation of each solution, and the results of the technical modeling based on those assumptions

 Review and discussion of staff‘s assessment of the evaluation criteria ( described earlier) they were asked to rate, and task force assessment of the evaluation criteria they were asked to rate

 Additional review and discussion of each solution after recommended revisions to the key assumptions and associated revisions to estima ted modeling outcomes

 Development of recommendations

In order to conduct a thorough evaluation of each solution
, a number of assumptions had to be made about how the solutions would be implemented. For example, the assumptions included estimates regarding the rate of compliance for each solution (the percentage of the public within the nonattainment area who would follow a new rule, regulation or procedure), the staffing levels needed for implementation, or the administrative and capital costs required for implementation. Those assumptions were used to inform the technical modeling carried out by the Clean Air Agency staff to estimate how much pollution reduction could be achieved by each solution and over what period of ti me that reduction would occur. The assumptions were also used to estimate the total cost of each solution (including an estimate of the potential costs borne by homeowners and the community ).

In its September and October meetings
, the task force reviewed and discussed the assumptions fo r e ach of the major solutions. A number of revisions were suggested based on the task force members ’ expertise or assessment of community values. Agency staff then revised the key assumptions and presented to the task force any changes in the estimated levels of pollution reduction or costs.

In addition, Clean Air Agency staff was asked to develop a tool that would allow the task force to understand how quickly a combination of solutions could achieve progress toward meeting or exceeding the federal air qualit y standards. Figure 8 represents the “Progress Meter” used by the task force

. TheTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 28

meter included three dates: 2014, which is the target established by the Clean Air Act for communities to reach attainment; 2019, which is the latest a community is allowed t o achieve attainment; and 2017, a mid

- term date that allowed the task force to measure estimated progress toward meeting the federal standard prior to the end

- date of 2019. The meter also include d two potential reduction goals: a minimum reduction of 9 mic rograms per cubic meter to meet the federal daily standard and to bring the

area into attainment ; or a reduction of 19 micrograms per cubic meter to meet an air quality health goal established several years ago for the entire region by the Puget Sound Clea n Air Agency Board

. Agency staff indicated that the progress meter is a preliminary tool

. Ultimately Ecology will be continuing technical analysis of recommended solutions for the SIP, so the amount of gains from individual or collective solutions could ch ange in the final SIP.

Figure 8

. Ex ample of a P rogress T hermometer The blue lines signify the minimum reduction nee ded to demonstrate attainment. The green line is the amount of reduction needed to reach the Agency health goal

.
Time of Sale Removal or Decommissioning of Uncertified Wood Stoves and Inserts Solution Description: This solution was based on an Oregon statewide program in which uncertified wood stoves and inserts were required to be removed, decommissioned, or changed out at the time a hous e is sold

. The transaction of sell ing a home provides a point in time and an established process (an inspection prior to the closing of a sale) when uncertified stoves and inserts could be identified andTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 29

removed. The Oregon program was adopted in 20 09 and effective in 2010 , so there are li mited data to evaluate the effectiveness of the new program.

Selected Key Assumptions:

 The rate of annual home sales in Pierce County is 2 percent to 3 percent of all homes. This is based on the Pierce County Assesso r

- Treasurer’s reports from 2008 to 2010 , and from Northwest Multiple Listing Service data provide d by representatives from the Tacoma

- Pierce County Association of Realtors

. 18

 Sixty percent of homes sold in Pierce County will comply with this requirement

. Th e Oregon program estimated a 75 percent compliance rate, but there are no t significant data yet to confirm their rate of compliance. 19

 This solution would result in an annual removal rate of uncertified wood stoves and inserts of 1.2 percent to 1.8 percent.

 The cost of removing but not replacing an uncertified device was approximate d to be $350 for a freestanding wood stove and $1,200 for an insert.

Evaluation Conclusions: The technical analysis concluded that this solution would result in the following:

 A reduction in fine particle pollution of about 0.3 2 micrograms per cubic meter by 2014 ( less than 5 percent of the minimum reduction needed); and a reduction of 1. 0 micrograms per cubic meter by 2019 ( about 10 percent of the minimum reduction needed).

 A tot al cost per microgram per cubic meter for this solution was estimated to be $3 million

. Task force members expressed several concerns about this potential solution

. A primary concern was that it would be focused on one relatively small segment of the population

— those individuals selling and purchasing homes

— to solve a community

- wide issue

. T ask force members felt it would be inequitable to single out th o se households to reduce fine particle emissions, since they represent a small portion of the total n umber of homes using uncertified wood stoves and inserts

. This would also place a requirement on households that have an uncertified device, even if the device w as not used to burn wood.

In addition, task force members expressed concern about relying on th is solution in a highly uncertain and weak real estate market

. There was concern that additional requirements placed upon home sales could weaken the recovery of the already soft real estate market. Finally , g iven the need to make substantial progress towa rd cleaner air, task force members said they were concerned that the current annual rate of home sales would not result in significant reduction of fine particle pollution

.
Enhanced Burn Ban Enforcement Solution Description: In order to consider modificat ions to the ways in which burn bans could be enforced in the nonattainment area , the task force had to understand the current law and practice regarding the use of burn bans. Washington s tate law allows local agencies to restrict the use of residential woo d burning devices to protect public health when air pollution levels rise

. 16 The law stipulates the use of a two

- stage burn ban

. A Stage 1 burn ban is issued on the basis of weather conditions and a forecast of rising pollution levels

. A Stage 1 ban is issued when a forecast estimatesTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 30

that fine particle pollution will exceed 35 micrograms per cubic meter (the federal daily standard) within 48 hours

. During a Stage 1 burn ban
, only households with EPA certified wood burning devices or pellet
stoves , or households whose wood stove or insert is their only adequate source of heat (including uncertified wood stoves or inserts), can burn

. A Stage 2 burn ban can be issued when fine particle pollution reaches certain trigger levels established in s tate law

. A Stage 2 burn ban is issued in one of two ways: (1) if a community is already in a Stage 1 burn ban and fine particle levels are above 25 micrograms per cubic meter and are forecast not to drop below that level for a t least 24 hours ; or (2 ) if a Stage 1 burn ban has not been called but fine particle pollution levels are above 25 micrograms per cubic meter and are forecast to exceed 35 mic rograms per cubic meter within 24 hours. During a Stage 2 burn ban
, only households who have no other adequate source of heat can burn wood. During both a Stage 1 and Stage 2 burn ban
, outdoor burning is prohibited.

During the past 10 years ( 2000

– 2010 )
, 17 fall and wintertime burn bans have been issued by the Clean Air Agency for Pierce County . This represents an average of six days per year during the months of November through February

. However, since the federal daily standard for fine particle polluti on was strengthened in 2008 (reducing the acceptable air quality standard from 65 micrograms per cubic meter to 35 micrograms per cubic meter), it can be reasonably assumed that without further actions
, the average number of burn ban days per year will increase.
The Clean Air Agency issues and enforces the burn bans

. It has an enforcement staff of between eight and 12 people who operate in two

- person teams, and are responsible for air quality enforcement in King , Kitsap , Pierce, and Snohomish counties. Enforcement of burn bans is currently conducted primarily during daylight hours because th e light better allows inspectors to observe the opacity (density) of the smoke or visible emissions rising from chimneys. In a recent burn ban (December 2010

– Januar y 2011)
, 10 notices of violation were issued in Pierce County for violation of the ban.

E nhanced enforcement of burn bans would include the following features:

 Substantially increase the number of personnel to enforce burn bans

.

 Change the standard used by enforcement personnel from opacity (smoke density) to visible smoke. This will allow personnel to observe more homes and issue more notices of violation if those violations are occurring

. ( A n opacity violation can be issued only after a home is allowed 20 minutes for start

- up, when smoke is more dense, and then must be viewed for at least six minutes by an inspector trained as a certified smoke opacity reader

. )

 Explore technologies that would better enable personnel to enforce burn burns during evening hours (including exploration of possible use of infrared viewers and cameras)

.

 Enhance community outreach and education to better inform residents about proper wood burning practices and the importance of observing burn bans.

 Incr ease the amount of advertising and public awareness efforts to better inform residents about the issuance of a burn ban

.

 Maintain use of the two

- stage burn ban , and make changes as necessary to when burn ban s are called (i.e.
, consider changing the “trigge rs , ” the forecasted levels of pollution, when burn bansTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 31

would take effect). This could better enable the community to use burn bans to avoid exceed ing the air quality standard.

 Provide assistance for low

- income households so they are not forced to spend li mited resources on more expensive forms of heat during a burn ban

.

 Create a registration program for owners of all certified and uncertified wood stoves and inserts

. This will enable enforcement personnel to focus their efforts on those homes that are in

v iolation of a burn ban (e.g.
, they would know which homes use wood stoves or inserts as their only adequate source of heat, or which homes have certified stoves or inserts that are allowed to burn during a Stage 1 burn ban).

 Establish a meaningful initial fine that could be reduced or eliminated if the resident agrees to participate in training regarding burn bans and proper wood burning practices
, or to change to a cleaner source of heat

. Selected Key Assumptions:

 Three quarters of those who receive a ci vil penalty for violating a burn ban w ou l d not burn again during a burn ban.

 The number of i nspection personnel w ou l d be ramped up over the first three years, resulting in potentially 4,000 notices of violation being issued in Y ear T hree

.
Evaluation Conclusions: The technical analysis concluded that this solution would result in the following:

 Based on the program changes described above, it is estimated that enhanced enforcement of burn bans could achieve a reduction in fine particle pollution of abo ut 1

. 4 micrograms per cubic meter by 2014 ( less than 20 percent of the minimum reduction needed); and a reduction of 6

. 8 micrograms per cubic meter by 2019 ( approximately 70 percent of the minimum reduction needed).

 A total cost per microgram per cubic met er for this solution was estimated at $1.2 million

. This cost includes approximately $ 1.3 million dollars per year in societal costs (including civil penalties to homeowners and program administrative costs). For a complete list of assumptions and agency evaluation conclusions, see Appendix E.

The task force felt that this potential solution would be effective because it would f ocus action during the days of the year when fine particle pollution in the nonattainment area exceeds the federal air quality sta ndards. The solution also builds on an existing regulation (issuance of burn bans) that is familiar to many residents

. This solution was felt to be timely (air quality improvements could occur as soon as enforcement is increased), technically feasible, and enforceable. The task force also noted that other communities , such as Sacramento, have had success in using enhanced enforcement of burn bans to reduce wood smoke fine particle pollution ( although circu mstances in other communities are not directly analo gous to the Tacoma and Pierce County area). The task force discussed a number of potential implementation challenges (i.e.
, ramping up and training the number of personnel required to enhance enforcement, securing technology to accomplish better evening en forcement, the need to include considerable public education along with enhancing enforcement of burn bans, and others), butTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 32

concluded that these challenges could be solved and that the solution could achieve results in the near

term and over time

.
Date C ertain Removal of Uncertified Wood Stoves and Inserts Solution Description: Wood stoves and inserts manufactured prior to 1988 (as described earlier in this report) produce more pollution and are less efficient than more modern devices

. The older stoves an d inserts made prior to 1988 are called uncertified devices

. Since wood burning devices can last for 40 years, there are still a considerable number of older uncertified wood stoves and inserts in use

. It is estimated that there are 24,200 uncertified wood stoves and inserts in the nonattainment area , and 21,200 are estimated to be in use

. 7 This solution would set a date (or dates) when uncertified wood
stoves and inserts would be required to be removed from homes in the nonattainment area.

In 2009 , the Washington State Legislature provided the authority to prohibit the use of uncertified

s toves and inserts in nonattainment areas if it could be demonstrated that the wood smoke w as found to be part of the air pollution problem, and if there were a program to assist low

- income residents in comply ing with the regulations

. 20 In addition, the legi slation exempted residents for whom an uncertified device is their only adequate source of heat. Given the percentage of pollution from wood smoke, the first condition can be met
, and t his solution presumes that the other conditions will be included in the nonattainment area.
The task force discussed several alternatives for phasing in a requirement to remove uncertified wood stoves and inserts over a several year period. However, the task force felt that establishing one clear date when all residents will have to remove their uncertified device was preferable to having multiple dates affecting multiple categories of residents. They also felt it would be important to offer a combination of “carrots and sticks” (e.g.
, incentives for those who remove their unc ertified device before the deadline, and stiffer fines for failing to remov e until after the deadline) to encourage removal in a phased fashion. The proposed date when all uncertified wood stoves and inserts would have to be

re mov ed is the end of August 20 15.

This solution w ou l d include provisions to accommodate low

- income households and those whose uncertified device is their only adequate source of heat. Assistance to low

- income households could take several forms, including: financial payment s to remove uncertified devices; providing additional time to meet the removal requirement; assistance with payment of bills for other heat sources; and/or leveraging of home weatherization programs to insulate homes to reduce all heating costs.

Although this solutio n is focused on the removal of uncertified devices, one of the factors affecting the estimated level of pollution reduction is the kind of heating device that could be installed after the uncertified wood stove or insert is removed. The task force felt tha t r esidents sh ould be able to install any approved method of heating, including certified wood stoves or inserts

.
The task force also discussed the level of confirmation that would be utilized to determine if and when uncertified stoves and inserts were be ing removed. Three levels of confirmation were considered: low, medium
, and active

. Low confirmation would include outreach and incentives
, but would n o t include meaningful ways to confirm removal

. This level of confirmation would not meet EPA requirements ofTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 33

enforceability

. The medium level of confirmation w ould include some ways to confirm removal

. Examples are : requiring GPS

- marked photos provided by homeowners to provide certainty that uncertified devices had been removed, and increased fines for burnin g with an uncertified stove or insert during a burn ban. The active level of confirmation would include inspections in homes to confirm removal

. The task force felt that home inspections would be considered intrusive by the community

This solution c ould in clude the creation of a registration program for owners of all certified and uncertified wood stoves and inserts. The registration could be used for both the enhanced burn ban enforcement and the removal of uncertified devices. Registration would be phased in over time and would be accomplished mostly with a system of online registration. Registration of all wood burning stoves and inserts would allow the Clean Air Agency to track the progress and target efforts being made toward the removal of all uncertif ied wood stoves and inserts.

Selected Key Assumptions:

 The number of uncertified wood stoves and inserts that w ou l d be removed per year is estimated
at 1,000.

 The compliance rate (the percentage of all owners of uncertified devices who would remove their uncertified wood stove or insert) by the deadline is estimated to be 33 percent with a “medium” level of confirmation by 2019

. This allows for an exemption for adequate source of heat.

 Fifty (50) percent of those who remove their uncertified device would replace that device with a certified wood stove or insert

.

 Financial assistance ($500) would be provided to remove certified stoves, and an additional $500 incentive would be provided for early removal

.
Evaluation Conclusions: The technical an alysis concluded that this solution would result in the following:

 It is estimated that date certain removal of uncertified wood burning stoves and inserts could achieve a reduction in fine particle pollution of about 0.7 micrograms per cubic meter by 2014 ( less than 10 percent of the minimum reduction needed); and a reduction of 2.5 micrograms per cubic meter by 2019 ( more than 25 percent of the minimum reduction needed).

 A total cost per microgram per cubic meter for this solution was estimated at $5 mill ion

.
For a complete list of assumptions and agency evaluation conclusions, see Appendix E.

The task force concluded that this solution would improve air quality over time and address one of the underlying causes of fine particle pollution. This solution is technically feasible, and with a balance of “carrots and sticks
, ” it could begin to accomplish pollution reduction quickly. The task force did express concern about the level of public and political acceptance this solution wou ld achieve. There are some in the community who will be opposed to limitations on their options for heating their home, or who object to the potential cost to replace the uncertified device with another stove or insert.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 34

Reductions in Other Sources of Pollu tion Solution Description: As mentioned earlier in this report, combustion from residential wood burning accounts for over half of the fine particle pollution on peak fall and winter days in the nonattainment

area

. However, several other sources contribute to the pollution: gasoline vehicles, industry, diesel vehicles, ships
, and other miscellaneous sources

. (See Figure 4 on page 15 .) Each of these other sources contributes significantly less to fall/ winter fine particle po l l ution than wood smoke: gasoline vehicles (20 percent ), industrial sources (10 percent ), diesel vehicles (5 percent ), and ships (4 percent ). Although no single source contributes more than 20 percent, there are a number of actions being undertaken to reduce fine particle pollution from these other sources.

Gasoline V

ehicles Nationally, the focus for reducing fine particle pollution related to gasoline vehicles has been on creating cleaner standards for both engines and fuels

. The State of Washington has adopted the Calif ornia Clean Car Standards for vehicles, the most stringent automobile standards in the country

. 21 As the old fleet of vehicles is retired from the road and the newer, cleaner vehicles replace them, the new standards will have a positive impact on reducing f ine particle pollution

. This trend is partially offset by the anticipated increase in population growth, which will result in more drivers on the road. In addition, local governments have adopted several programs to reduce fine particle pollution related t o gasoline engines: Pierce County, the City of Tacoma, and Tacoma Public Utilities have installed 20 electric vehicle charging stations in the area, and have pu rchased electric vehicles , along with vehicles that use biodiesel . Anti

– automobile

- idling progra ms have been adopted for schools, Washington State F erry loading areas and for some public fleet s

. The regional transportation plan adopted by the Puget Sound Regional Council has several policy goals that will help reduce fine particle pollution:

 Focus po pulation and economic growth in urban centers and compact communities

.

 Improve efficiency through better signal coordination, active traffic management, and traveler information

.

 Implement strategic capacity investments in transit, roadways
, and non

- motori zed improvements

. In support of these policy goals there are a number of transportation capital investments planned in the nonattainment area between now and 2019. Those improvements include the following: high

occupancy vehicle ( HOV ) lane extensions on I

- 5 an d SR 16 ; ramp metering on I

- 5 in the Joint Base Lewis

McCord area ; Sounder ( commuter rail) improvements from Tacoma to Lakewood ; and selected bicycle lanes, sidewalks and trails to encourage alternative means of travel. 22

Diesel V e hicles There are new federal standards for diesel engines and fuel. The new standards for cleaner engines apply to a wide range of diesel engines, including cars, trucks, locomotives
, and marine. Cleaner diesel fuel standards have been phased in during the past several years : 2007 for on

- road vehicles, 2010 for off

- road vehicles, and 2012 for locomotive and marine fuel. 23 However, Tacoma Rail, the Port of Tacoma Terminal Locomotives, and the Washington State Ferries are already using fuel that meets the newe rTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 35

standards. There are also several programs adopted by local jurisdictions and often implemented through the Clean Air Agency’s “Diesel Solutions” program to reduce emissions from diesel vehicles and equipment, including: 93 percent of Pierce County schoo l buses and more than 140 City, County and Port vehicles equipped with exhaust control equipment; the Port of Tacoma’s and Tacoma Rail’s locomotive idl e

- reduction program; use of biodiesel by all of the City of Tacoma
, the Port of Tacoma and Tacoma Public Utilities diesel fleet s ; Pierce Transit’s use of compressed natural gas in its entire fleet; use of “clean diesel” and hybrid buses by Sound Transit; retrofitting of 59 diesel

- powered trucks with diesel oxidation catalysts by Tacoma Public Utilities; and t rading out heavy

- duty trucks older than 1994 for cleaner vehicles by the City of Tacoma , Port of Tacoma and Department of Ecology

. The Port of Tacoma has also implemented a program that only allows drayage trucks with 1994 or newer engines to enter the Port.

Industrial Sources Engineers and inspectors from Ecology and the Clean Air Agency have been working with Tacoma and Pierce County industries for the past 40 years to reduce pollution emissions , with significant reductions achieved

. Among the current industrial sources of fine particle pollution in the nonattainment area, there are six sources that have been identified by Ecology and the Clean Air Agency as the largest industrial emitters of fine particle pollution

. Collectively, these six sour ces contribute more than 90 percent of the industrial fine particle pollution from industrial sources in the nonattainment area

. The federal Clean Air Act establishes a requirement for working with industries to reduce their levels of pollution called Reas onably Available Control Technology (RACT ). The requirement stipulates that pollution control technology for industries must be available, reasonable to install, and cost effective to install and operate. Engineering staff at Ecology and the Clean Air Agen cy are currently conducting a review of existing pollution controls and operations at the six largest industrial sources to determine if they meet RACT

. A preliminary analysis indicates that most
, if not all
, of the sources do

. Ships
New international standards require that ocean

- going ships use low er sulfur fuel , beginning in 201 2 and moving to a much stricter levels by 2015

. These cleaner fuels will reduce th e fine particle pollution from ships

. 24 The Port of Tacoma and Totem Ocean Trailer Express ha v e also installed shore power facilities and retrofitted ships so that ships can use shore power instead of operating their diesel engines to create power when at berth.

Selected Key Assumptions:

 Older cars will retire and be replaced by newer ones

. 23

 Over $5 billion in transportation

- related investments that will help reduce fine particle pollution will occur by 2019. 22

 Ship emissions will decrease between 2012 and 2015 due to cleaner fuel requirements

. 24

Evaluation Conclusions:

 The new standards for cleaner gasoline cars and newer cars on the road are estimated to achieve a reduction in fine particle pollution of 1.3 micrograms per cubic meter by 2014, and 1.5 micrograms per cubic meter by 2019.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 36

 The federal standards for cleaner diesel engines and both diesel and marine fuels are estimated to achieve a reduction in fine particle pollution of 0 .5 micrograms per cubic meter by 2014, and 0 .6 micrograms per cubic meter by 2019.

 The new standards for large ship fuel are estimated to achieve a reduction in fine particle pollution of 0.4 micrograms per cubic meter by 2014, and 1.1 micrograms per cubic meter by 2019.

 Investments in regional transportation project s to improve traffic flow and provide alternative forms of transportation are estimated to achieve a reduction in fine particle pollution of 0 .4 micrograms per cubic meter by 2019.

Together the anticipated reductions from emission sources other than wood s moke are estimated to achieve approximately one

- quarter to one

- third of the reductions needed (2 to 3 micrograms) to reach the federal air quality standard by 2019. Most of the emission reductions from these other sources of fine particle pollution will co me from changes in federal standards for more efficient engines and cleaner fuels

. However, while the range of local initiatives do es not add a significant amount to the estimates of emission reduction in the nonattainment area, continued efforts to reduce emissions from the se sources will contribute to the overall plan

.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 37



## IV. Public Outreach and Input

The task force allowed for public comment at each of its meetings. In addition, the Clean Air Agency conducted significant public outreach in Pierce County on t he topic of fine particle nonattainment. There

were two primary purposes: to raise general awareness of the issues and to gather public input on the draft pollution

- reducing strategies under consideration by the task force. Because of the likely impacts fr om future implementation of wood smoke reduction programs, special emphasis was given to reaching members of the community who burn wood for heat

. Public outreach was conducted throughout the task force process, but was concentrated during October and Nov ember 2011. Activities included:

 Direct mailing

– Postcards were sent to all households within the nonattainment area (approximately 220,000 households) announcing public open houses and also requesting input online or by telephone.

 Public open houses

– Two public meetings were held in the nonattainment area (Tacoma, October 20; Puyallup, October 24). A total of a pproximately 200 people attended.

 Online survey

– Public input was invited via an online survey at www.cleanairpiercecounty.org

. More than 400 c omments were submitted between October 5 and November 30

. Approximately 50 people responded to the postcard by phone. An additional 10 responded by U.S. mail.

 Print and online advertising

– The public open houses and online survey were advertised in all of the major print media within the nonattainment area, in one Spanish

- language weekly, on Joint Base Lewis

- McChord, and on the Tacoma News Tribune website. Additionally, more than 4000 posters and flyers were distributed in public locations within the commu nity.

 Outreach to community groups

– Clean Air Agency staff and partners gave presentations and briefings throughout the year to more than 30 neighborhood coalitions, city and county councils, state and federal elected officials, and other community groups . Clean Air Agency staff also participated in community events focused on health impacts, emergency preparedness, and other relevant topics.

 Social media

– The Clean Air Agency also used its monthly electronic newsletter, FaceBook and Twitter to promote th e work of the Clean Air Task Force and to solicit public input on the draft pollution

- reduction strategies being considered.

Feedback was requested on three draft pollution

- reducing strategies: enhanced enforcement, removal of uncertified devices at a date certain (“date certain”), and removal of uncertified devices at the time a home is sold (“time of sale”). All comments received were categorized according to four levels of overall support for the strategy: full support, qualified support with economic co ncerns, qualified support with concerns about balanced implementation, and full opposition

. Overall, the majority of respondents indicated full or qualified support for all of the strategies proposed. The primary public concern about enhanced enforcement was that implementation should be balanced and reasonable. For date certain and time of sale removal, the primary concern was about economicTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 38

impacts to individual households, both due to the cost of removing uncertified devices and to ongoing heating costs

. Four major themes were common across all of the public input submitted. There were strong concerns about the economic impacts of potential pollution

- reducing strategies on individual households, particularly low

- and fixed

- income families. A large propo rtion of people expressed concerns about the impacts of wood smoke on their health and in their neighborhoods. A smaller number of comments expressed disbelief that wood smoke is a significant source of pollution, as well as concern that efforts to address wood smoke are intrusive and a waste of taxpayer money

.

Figure 9 . Overarching T hemes from C ombined O nline, P ublic O pen H ouse, and T elephone C omments Four major themes were common across all of th e public input submitted. In a number of cases, individuals expressed both support for and concerns about the proposed solutions.
All public input was compiled and provided to the task force for its consideration, as well as posted online at www.cleanairpiercecounty.org . Further public outreach will be done on issues related to burn bans, health impacts of wood smoke, clean burning practices, and other topics as the state implementation plan is completed and implemented. Health and Neighborhood Impacts 33%

Economic Burden to Households 33% Gov't Intrusiveness, Waste of Taxpayer Money 23% Disbelief that Wood Smoke is Key Pollution Source 11% 

# General Themes (all comments)Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 39 Figure 10 . Location of O nline S urvey R espondents by ZIP C odeTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 40 Figure 11 . Location of P ublic O pen H ouse A ttendees by ZIP C ode ( N ote: not all meeting attendees provided ZIP code information)Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 41



## V. Recommended Solutions and Principle Statements No single solution will enable the nonattainment area to reduce fine particle pollution sufficiently to achieve the federal air quality standard

. The task force is recommending use of a combination of strategies in the nonattainment area to improve air quality in a timely ma nner and to help the area reach attainment. The three main strategies recommended by the task force are:

1. Enhanced enforcement of burn bans
2. Establish ment of a date certain for removal of uncertified wood stoves and inserts 3. Implementation of the range of strategies to reduce fine particle pollution for gasoline vehicles, diesel vehicles, industries and ships.

As mentioned in the Evaluation Section of this report ( page 2 7 ) , approximately one

- quarter to one

- third of the emissi on reductions needed to meet the fine particle pollution standard by 2019 will be accomplished from new federal regulations and local initiatives related to reducing pollution from gasoline and diesel engines , ships, and industries

. Since wood smoke represents more than half of the fine particle pollution on peak fall and winter days, the task force focused most of its time discussing recommendations regarding ways to reduce wood smoke.

The task force discussed numerous variables with respect to the design of the recommended solutions

. However, it realized that circumstances may change as implementation plans are developed

. (For example, there is uncertainty about the amount of funding to implement these solutions

. ) As a result, the ta sk force recommendations include a combination of suggested program design features, and statements of principle that it suggest s be used to guide the future implementation of these solutions

. As mentioned earlier in this report ( see page 2 0 ), the Clean A ir Act allows education and voluntary measures to account for only 6 percent of the total emission reduction needed to achieve attainment (at least 9 micrograms) . Public education and voluntary outreach are not considered enforceable and are difficult to m easure. However, the task force firmly believes that the two wood smoke related solutions descri b ed below will not be successful without considerable public education
, community outreach and public involvement

. Local communities must first understand the n ature of the problem and then take ownership of the actions needed to improve air quality. Education and outreach are needed to help residents understand the causes and impacts of fine particle pollution, to encourage residents to take informed actions, and to overcome the skepticism many members of the public will have about new government regulations. Outreach and educ ation must include efforts to reach individuals who may not receive information from traditional civic or community organizations.

Task force members also suggested that there are opportunities to work with local public health agencies, and other governmen t and nonprofit organizations, to better inform the public about the health risks of fine particle pollution and the proposed solutions.

The task force expressed concern that the solutions being recommended could create an economic burden on residents in t he nonattainment area. As a result, they are proposing that the solutions be implemented in a manner that will provide some form of assistance to low

- income residents. They also raised concerns about how renters would be treated, especially in cases where the renters are lowTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 42

income. The statements of principle for the task force’s two major solutions include providing assistance to low

- income households or helping them find alternatives. (See the first statement of principle for Enhanced Burn Ban Enforcemen t, and the second statement of principle for Date Certain Removal of Uncertified Wood Stoves and Inserts.) The task force members wanted to be certain that provisions for low

- income households also included renters.

The task force acknowledged that the are a with the highest pollution levels (near the South L Street

m onitor in Tacoma) is also an area where many people burn wood. Finding ways to focus resources on that area is important both to reduce health impacts on nearby residents and to solv e the overal l pollution problem.

Overarching Principle Statement

 All r esidents and communities in the nonattainment area should contribute to the solution

. We

a re all in this together.

Common Principles for Implementing All Solutions

 Education efforts are a key compon ent to ensure effective implementation.

 Outreach should be broad

- based and include groups that are less likely to receive notice or support.

 Individual strategies should be consistent and complement other strategies.



### A. Enhanced Burn Ban Enforcement

Goal: Ens ure that those who are contributing the most to the fine particle pollution du ring periods of the poorest air quality reduce their emissions

. The task force felt that the primary value of this solution is that it would focus on those residents contributing the most to the air quality problems during the fall and winter months, and that it would focus resources on the specific times of the year when the area is out of compliance with the federal air quality standards. Task force members recommend that this t argeted approach will be an effective way to reduce fine particle pollution

. The task force discussed experiences in other communities that have significantly enha nced enforcement of burn bans. Although circumstances and conditions vary from one community to the next, they felt that programs in other areas of the country, such as Sacramento, demonstrated enough success to suggest promise for enhanced burn ban enforcement in this nonattainment area.

T he Clean Air Agency has been issuing burn bans for a numb er of years, so changes to the existing
progr am are needed to improve fall/ winter air quality

. The task force considered a number of changes to make burn ban enforcement more effective

. For example, as mentioned earlier, currently only eight
to 12 personne l are used to enforce burn bans and other clean air regulatory requirements in King
, Kitsap, Pierce, and Snohomish counties

. A relatively small number of notices of violation have been issued in Pierce County during burn bans

. The task force is recommendin g that considerably more personnel be used to enforce the burn bans in the nonattainment area

.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 43

Another change is that enforcement of a burn ban historically occurred only during daylight hours

. However, data suggest that there is a large increase in the l evel of fine particle pollution from wood smoke in the evening hours

. The task force is recommending that the Clean Air Agency explore the use of technologies that would allow for better evening enforcement of burn bans. Other recommended changes are liste d below

. In addition, task force members felt strongly that use of enforcement personnel alone would not result in the change of behavior needed to alter wood burning practices

. In addition to a significant increase in the use of enforcement personnel
, the task force believe d that community outreach and education are essential. The members suggested it would be particularly helpful to find opportunities for neighbors to talk with each other about air quality problems and the importance of complying with burn bans. They also suggested utilizing existing community

- based programs, where possible, to foster this type of education and outreach effort

. The Clean Air Agency works with the local media to help notify the public when burn bans are called.
However , task force members noted that many residents remain unfamiliar with the reasons for a fall/winter burn ban, and are unaware when burn bans are called. It was suggested that the Clean Air Agency do everything it can to work closely with local media outlet s to publicize burn bans
, and to inform the public about the causes and health impacts of fine particle pollution in the nonattainment area. (There was a specific suggestion to ask the local media to clearly indicat e in news accounts when burn bans were fi rst called. )

Key Features of Recommended Solution

 Ramp up enforcement presence during burn bans and in the fall and winter, phased in over several years

.

 Enforce violations based on visible emissions, in addition to smoke density

.

 Add nighttime enforcement, as practical

.

 Maintain a two

- stage burn ban, and consider changes to when and how the stages are called

.

 Provide exemptions and/or assistance for low

- income residents and households for whom the wood burning device is their only adequate sourc e of heat

.

 Include a registration program for wood burning devices

.

 Enhance outreach and education efforts

. Statements of Principle to Guide Implementation of Enhanced Burn Ban Enforcement

 Enhanced enforcement should be combined with a robust community outreach initiative to enable neighbors to talk with neighbors about the importance of obeying burn bans and burning cleanly when the community is not in a burn ban.

 Assistance should be provided for low

- income households who may be affected by this requir ement. Enforcement of burn bans should respect the challenges faced by low

- income burners and provide alternatives (e.g.
, financial assistance or exemptions) , even if the se residents have other sources of heat available.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 44

 Enhanced enforcement should be phas ed in to allow those who receive a first notice of violation to reduce or eliminate the initial fine if they engage in educational opportunities about proper burning practices and the importance of burn bans, or move to a cleaner source of heat. The initia l fine should be meaningful enough to provide sufficient incentive to participate in education activities and to discourage subsequent burning during burn bans.

 Enhanced enforcement should continue to accommodate households for whom a wood burning device i s their only adequate source of heat, while ensuring that the exemption is used only for those who qualify. Exemptions from burn ban enforcement do not exempt people from burning cleanly nor from other standards.

 Decisions about who provides enforcement sh ould be based first on who would be most effective, while respecting the need to consider any capacity challenges of local governments.

 When implementing a registration program, consider that the goal is to enhance effectiveness of enforcement staff and mi nimize unnecessary interactions with exempted households.

 Revisions to the Stage 1 and/or Stage 2 “trigger” levels should be considered, as they may enable burn bans to more effectively keep fine particle pollution below the federal daily standard during i nversions, and better protect public health.

 Both forecast and monitored data should be included in the burn ban system (as they are currently) to call burn bans.



### B. Date Certain Removal of Uncertified Wood Stoves and Inserts
Goal: Removal of the older, more polluting wood stoves and inserts from the nonattainment area

. This solution provides lasting emission reductions by removing one of the underlying causes of fine particle pollution from the community

— uncertified wood stoves and inserts

. The older uncert ified wood burning stoves and inserts are more polluting than are other sources of heat. However, this recommendation represents a considerable change from current practices in the community. As mentioned earlier, it is estimated that there are 24,200 unce rtified wood stoves and inserts in the nonattainment area , with an estimated 21,200 currently being used

. The Clean Air Agency previously removed about 1 , 200 of them during a voluntary changeout program.

The task force is recommending selection of a date for removal of uncertified devices that will strike a balance between several objectives: (1) provide sufficient time for local residents to make plans to accommodate this new requirement; (2) provide suff icient time for officials to attempt to secure implementation funding; but (3) not set a date too close to 2019 when the area must meet the air quality standards. With uncertainty about the rate of compliance for this proposal, the removal date must allow sufficient time prior to 2019 to adjust the solutions as needed. The task force is also recommending that the Clean Air Agency use a combination of “carrots and sticks” to encourage early adoption of this requirement

. This would allow for implementation to be phased, while still maintaining a clear date certain when all uncertified stoves and inserts would be required to be removed.

The removal program would work in concert with the enhanced burn ban enforcement

. For example, uncertified wood stove/insert users who receive a notice of violation during a burn ban could receive aTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 45

higher fine if they have not removed their device by the deadline . Also, prior to the deadline
, enforcement of burn bans could be used to help educate residents about the new removal requirement. This recommendation includes a proposal to create a registration system for all wood stoves and inserts

. This element of the program would benefit both the enhanced burn ban enforcement and date certain removal strategies

. By knowing who has an uncertified stove
, the Clean Air Agency can direct incentives to those residents, provide focused enforcement of a Stage 1 burn ban, and confirm removal of the uncertified device from those homes

. The task force is also recommending that once an uncerti fied wood stove is removed, the homeowner should be able to replace that stove (if the owner choose s ) with any other approved cleaner heating device, including a certified wood stove.

Key Features of Recommended Solution

 All uncertified wood stoves and inserts must be removed by end of August 2015.

 Use a combination of incentives, fines, education and regulations (carrots and sticks) to encourage residents to remove uncertified devices by the end of August 2015

.

 Create a r egistration system for all owners of wood stoves and inserts (both certified and uncertified)

.

 Create a “medium level” of confirmation regarding removal of uncertified stoves and inserts. This could include higher fines for using an uncertified device during a burn ban, or GPS

- marked photos to confirm removal. ( See pages 32

- 33 regarding low, medium and active confirmation.)

Statements of Principle to Guide Implementation of Date Certain Removal of Uncertified Wood Stoves and Inserts

 Households should have a range of options if they choose to replace their uncertified device ( including certified device, pellet stove, or other type of heat), but incentives could vary depending on the device they use.

 Assist ance should be provided for low

- income households who may be affected b y this requirement. The assistance could take several forms, including but not limited to, financial assistance for installing a new heating device, home weatherization, and/or providing additiona l time for low

- income households to meet this requirement.

 The solution should accommodate households for whom a wood burning device is their only adequate source of heat.

 Date certain removal should allow time for transitions, yet begin soon enough that t he date is meaningful. Timing of implementation should be equitable, be p ublically acceptable
, and allow time to find funding.

 Medium level of confirmation is the preference. B ut if that is not sufficient to achieve EPA approval or program effectiveness, a more active form of confirmation should be used. If more rigorous methods of confirmation are needed
, they should be equitable and as nonintrusive as possible.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 46

 The purpose of the registration program is to confirm widespread removal of uncertified devices

.

 Recognizing the current challenges in local, state
, and federal budgets, funds should be prioritized according to the task force’s ranking
, where possible. (See below.)

Allocation of Resources for Date Certain Removal Solution
There are a variety of ways that funds could be used to support this solution

— the date certain removal of uncertified wood burning devices

. But in these challenging economic times the availability of funding to support this solution is uncertain

. Task force members were asked to rat e several different potential uses of funds in order to recommend some priority for the future funding, when and if it becomes available

. The task force was provided with a list of five possible opportunities to use funds and asked to rank them from 1 to 5 , with 1 being the highest priority and 5 being the lowest priority

. Members were also given the opportunity to add other potential uses for funds

. The following table lists potential uses of funds and the average ranking created by the task force:

Table 5

. Task Force Ranking for Potential Use of Funds
Potential Use of Funds Average Ranking Assistance for low

- income households 1 Assistance to households with no other adequate source of heat 2 Incentive payments for early adopters 3 Incentive payments for cleaner heat 4 Assistance to all households (regardless of income) for removal of stoves/inserts 4 Other (each receiving one vote) :

 Incentives for weatherization for all households that remove stove/insert

 Assistance in retrofitting a fireplace with a certified wood heater or pellet heater

 Use the point of sale of a home to remove uncertified stoves/inserts



### C. Making Progress Toward Clean Air The task force was mindful of the need to meet the federal Clean Air standard, but also to reduce overall levels of pollution in the nonattainment area. Since high levels of fine particle pollution have been demonstrated to have impacts on human health, t he task force wanted the recommendations to first and foremost meet the federal standard. Using the progress meter described earlier in this report, the task force reviewed the combined effects of the proposed solutions to understand how much progress can be made to achieve both goals. The progress meter shown in Figure 12 demonstrates that attainment could potentially be achieved by 2017 assuming the programs were fully supported over the time frame

. By 2019, it is estimated that the nonattainment area would achieve fine particle pollution reductions well beyond what is required by the federal standard, and make progress toward the air quality health goal. It should be noted that there are a large number of assumptions in this estimat e that have significant uncertainty. (See Appendix E.)Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 47

Figure 13 below demonstrates the proportion each solution contributes to the total reduction by 2014, 2017, and 2019. By 2014, the pie chart illustrate s that the most immediate reductions come from non

wood smoke solutions. On the other hand, the 2017 and 2019 pie charts show that the wood smoke solutions make up the largest proportion of the reductions as these solutions are phased in over time.

Figure 12. Progress Thermometer for Task Force Recom mendations This thermometer represents an estimated sum of the solutions proposed by the task force. Note: This is a

compilation of a number of assumptions and has a significant level of uncertainty.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 48Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 49 Figure 13

. Proportion of Emission Reductions by Category in 2014, 2017, and 2019
The pie charts are the proportion of the reduction estimates from the thermometer above. 2014 is the target established by the Clean Air Act for communities to reach attainment; 2019 is the latest a community is allowed to achieve attainment; and 2017 is a mid

- term date used by the tas k force to measure estimated progress toward meeting the federal standard and the PSCAA health goal. Note: This is a compilation of a number of assumptions and has a significant level of uncertainty.



### D. Contingency Measures The State Implementation Plan submitted by Ecology to EPA must id entify the solutions the nonattainment area will use to meet the air quality standards, and anticipated target dates for making progress toward reaching those standards (i.e.
, how much improvement in air quality is expected by certain dates)

. If those targets are missed or if the area is not making sufficient progress toward meeting the fine particle standards, then further solutio ns m ust be adopted

. These additional solutions are called contingency measures

. The state’s Plan must identi f y potential contingency measures. These measures can be heightened use of the solutions included in the Plan , or new solutions previously untried.

The task force is recommending that the following contingency measures be considered for inclu sion in the P lan :

 That cleaner technologies be required for use of fireplaces, such as cost

- effective catalysts, starters, or filter technology that has been shown to work ( this technology has not yet been demonstrated successfully ).

 A requirement that in the nonattainment area
, only the cleanest burning devices (equivalent to emissions produced by a pellet stove) be allowed

. ( The Task Force acknowledged that because the EPA is currently revising its emission testing protocol for stoves, this measure may not be available at the time the SIP is subm itted, but could be added at a later date.)

 That the time of sale of a home be used as a n opportunity to confirm the removal of uncertified wood stoves or inserts (in addition to, as a backstop for “date certain”)

.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 50

 For households that have an uncertified w ood stove or insert as their only adequate source of heat, only those that are income qualified would receive assistance or be exempted from the requirement to remove their device

.


### E. Task Force Consensus on Recommendations
One of the ground rules adopted by the task force during its initial meetings was that the group would attempt to reach unanimous consensus on its recommendations. Unanimous consensus was defined as all members could support or could live with the recommendations

. (The term “live with” mea nt that a member may have some reservations about a topic but they could accept the solution being part of the task force recommendations.) The ground rule also state d that if the recommendations were not unanimous, th e differences of opinion would be noted.

There is unanimous consensus on the major solutions of enhanced enforcement, removal of uncertified devices
, and getting reductions from vehicles, industry
, and ships. For the detailed components of those solutions, there was also unanimous consensus with one exception

. The majority of task force members supported the recommendation that a system of registration be created for all wood stove and insert owners in the nonattainment area

. However, three members did not support that recommendation

. They did not support the registration system for the following reasons:

 Only a small portion of wood burners may respond to a voluntary program, raising questions about whether the effort is worth the c ost to implement such a program

.

 A registration program may create resentment (particularly among responsible wood burners) that could hinder efforts to reduce wood smoke pollution. It may be seen as government being too intrusive.

 Residents may have difficulty knowing if their stoves are certified or uncertified

.

 A registration program could be confused as needing permission to use a wood burning device

.

 Residents may misinterpret a registration program as providing approval for use of their device, even if it is an uncertified wood stove (i.e.
, once the device is registered they may feel they have the authority to use it).

 A registration program could start as voluntary and informational, but could be used over time in a more regulatory/punitive fashion

.

 Registration will not re sult in fewer uncertified stoves and could result in impression of a new government program that would foster less self

- sufficiency

. The task force discussed several ways of including fireplaces in the major solutions but did not come to consensus, other t han to include fireplaces in the education about clean burning practices. Information presented to the task force included the facts that fireplaces are estimated to be 34 percent of the wood burning devices in use in the nonattainment area (see Table 1) a nd produce 21 percent of the wood smoke fine particle pollution. Based on this information, s ome task force members felt that fireplaces should be included in the major solutions.

On the other hand , the task force also learned that masonry fireplaces are exempted from Washington emission standards, although manufactured fireplaces must meet a state fireplace standard. 25 AllTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 51

fireplaces are required to be shut down during Stage 1 and Stage 2 burn bans, so enhanced enforcement will address fireplace use during burn bans. There is currently no cost effective safe technology to assist fireplaces in burning more cleanly, although some technologies show promise. Closing off or removing fireplaces would be a considerable expense for homeowners, and some task force m embers were concerned that such changes would reduce the value of the home. For these reasons, other task force members felt that fireplaces should not be included in the solutions.

There was consensus to include a provision about fireplaces in the contin gency measures.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 52



## VI. Next Steps
With this report the task force is transmitting its recommendations to the Puget Sound Clean Air Agency. The Agency’s board of directors will review the task force report as part of their process for making recommendations to the State Department of Ecology. In 2012
, Ecology will consider the recommendations from the Clean Air Agency, conduct further analysis, and prepare a State Implement ation Plan. That plan will be submitted to the federal Environmental Protection Agency by December 2012 for their review and approval. The EPA will review the state Plan to e nsure that it complies with the requirements of the Clean Air Act. During Ecology ’s development of the SIP
, there will be opportunities for public review and comment o n the Plan.

Parallel with the development and approval of the SIP, the Clean Air Agency will be developing plans and implementing actions to improve air quality in the n onattainment area. The SIP will include the timeline for the implementation of the rules.

Any local rules or state laws required to implement the solutions need to be in place before the SIP is submitted to EPA. Because of that, the Clean Air Agency will s eek state legislation in 2012 to clarify its existing authority for implementing the recommended solutions.

Task force members expressed interest in being kept informed about implementation plans as they are developed, and future opportunities for public review and comment on these recommendations and on the state SIP.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 53 

## Appendix A Demographics of the Nonattainment Area
Clean Air Agency staff provided the task force with a demographic snapshot, based on census d ata

. See the table below

. With respect to population density, in general the Tacoma neighborhoods in the nonattainment area tend to have population densities in the range of 5,000

– 10,000 people per square mile. Much of the remainder of the nonattainment area has population densit ies in the range of 1,000

– 5,000 people per square mile.

Nonattainment Area Demographics
Category Characteristic Measurement Population Total population 533,000
Households Total households 222,000 Percent owner occupied households 58%

Race/Ethnicity (Note: percentages total more than 100% because Hispanic can be any race) American Indian/Alaska Native 1%
Asian 7%
Black 9% Hispanic (any race) 10%
White 69%
Other race 6%
Two or more races 8% Language Residents who report they do not speak English “very well” (for all of Pierce County) 12.7%

Major languages for those who do not speak English “very well” Korean, Khmer (Cambodian), Russian, Spanish, Vietnamese
Income Median income $51,458 Poverty rate in Pierce County 12.3%
Nonattainment area households at 150 percent the federal poverty level Approx. 25,000 (17%)

Sources: US Census Bureau, Cen sus 2010 Block Group Data (2011); U.S. Census Bureau
, 2005

- 10 American Community Survey by census tract (2010) 10 , 11Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 54 

## Appendix B Ground Rules : Clean Air Task Force

Final 6/16/11

Principles that will guide our work:

 Transparency in creating a thorough and open process

 Respect for one another’s perspectives

 Commitment to recommending the best solutions for Pierce County

1. The task force is encouraged to think creatively about potential solutions for the issues the group has been asked to address

. Task force members will agree to keep an open mind to possible new ideas, and to consider the diverse interests of all Pierce County resid ents.

2. The task force is comprised of people with a variety of perspectives and interests

. Differences of opinion are to be expected and will be respected by the task force and its members

. Task force discussions will be characterized by careful deliberat ion and civility. Task force members will work to understand the different points of view and perspectives of other members

. Questions to better understand each member’s interests are encouraged.

3. The task force will operate by consensus

. The goal will be to reach unanimous consensus

– meaning that all members can support, or live with, the task force recommendations

. If unanimous consensus cannot be reached
, differences of opinion will be noted and included as part of the task force final recommendations.

4. The task force is advisory to the Puget Sound Clean Air Agency Board

. The Agency has ultimate responsibility for making decisions about which actions to recommend to the State.

5. Task force members are strongly encouraged to participate in every meeting t o achieve continuity in discussions from one meeting to the next

. If members cannot attend a meeting
, it is his/her responsibility to be informed about the topics discussed by the next meeting

. An absent member may ask someone to attend a meeting on their behalf to listen to the discussion, but that person will not be able to participate in discussions or votes

.

6. If a task force member cannot attend a meeting and wishes to make a statement regarding an issue that is on the agenda for that meeting, he or sh e may provide the facilitator with a written statement, which will be read to the full group when the issue is being considered at the meeting.

7. Meeting materials will be sent via email to task force members and posted on the Clean Air Agency project web s ite in advance, whenever possible

. Any handouts at meetings will be emailed, or mailed, to members who were not present.

8. Meeting summaries will be prepared and distributed via email or mail to all task force members in a timely manner

. If task force membe rs have comments or concerns about the summaries, they are to notify the facilitator promptly. The facilitator will work with members to resolve those issues and make sure that the final summary reflects any revisions made. Once the task force members have had anTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 55

opportunity to review the draft summary and after any revisions are made, the summaries will be distributed to the task force and posted on the project web site.

9. Task Force members have a wide range of knowledge about air quality issues

. Deliberations will need to strike a balance between creating a common base of knowledge and information and moving expeditiously to development of recommendations

. It is the intent of the task force to use the limited meeting time efficiently. The facilita tor may consider creation of task force sub committees to explore selected issues and report back to the full task force. Once consensus on an issue has been reached the issue will not be reopened for discussion until the full “package” of final recommenda tions can be reviewed and considered as a whole

.

10. Any member may speak to the media or other groups or audiences regarding issues before the task force, provided s/he speaks only for her or himself

. Inquiries from the media or others can be directed to th e facilitator or project manager

. Members are asked to let the process reach its conclusion before describing potential strategies or ideas as task force recommendations. Members agree to bring issues or concerns to the task force before raising them with others in a public fashion.

11. It is understood that task force members may need to consult with their organizations before making commitments on behalf of their respective organizations

. However, each member will work hard to understand any issue or concern raised by their organization and will communicate those issues in a timely fashion to the full task force.

12. All meetings will be open to the public

.

13. Meetings will start and end on time.

14. The task force does not plan to take formal public testimony

. Howev er, the task force will accept comments or questions from the public at the conclusion of meetings.

15. The facilitator will communicate with task force members between meetings to better understand issues and search for consensus on solutions.

16. Clean Air Age ncy staff will be responsive to the information requests from the task force

. However, it may not be possible to meet all information requests

. Please make information requests outside of the task force meetings to the Agency project manager or the facilit ator.

Role of the Facilitator In addition to the roles described above, the facilitator will:

 Work with the task force and Agency staff to set the agendas for meetings

 Work to resolve issues regarding process or schedule

 Open the meetings and manage the flow and timing of the topics on the agenda

 Make sure that all task force members have opportunities to participate in discussions

 Prepare draft recommendations based on task force discussions

 Occasionally make presentations, in partnership with task forc e members, to outside groups about the work of the task force, as requestedTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 56 

## Appendix C Evaluation Tool s
WORKSHEET FOR TASK FORCE MEMBERS’ EVALUATION
Name: _____________________________________________

Solution Maintainability

(V

– S

– N) Cost

Commensurate with Benefit (V

– S

– N) Public and

Political Acceptance (V

– S

– N) Economic

Well

Being of County (V

– S

– N) Minimize

Burden on Vulnerable Communities & Populations (V

– S

– N) Minimize

Unintended Consequences (V

– S

– N)

Definitions:

 Maintainability

– Will improve air quality over time; addresses the underlying causes of poor air quality.

 Cost commensurate with benefit: The cost of the solution is commensurate with the air quality benefits that it will achieve.

 Public and political acceptance: There w ill be sufficient public and political support for the solution.

 Economic well

- being of County: Will enhance the economic development potential for the county.

 Minimize burden on vulnerable communities and populations: Will minimize the economic burden on individuals and households.

 Minimize unintended consequences: Will minimize the likelihood of unintended consequences.



### How well does the solution meet each of the criteria below? Rating scale: V (Very well), S (Somewhat/mixed), N (Not well)Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 57

Example of completed evaluation form:Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 58 

## Appendix D Solutions Developed by T ask Force: Organized by Potential for Pollution Reduction Ranked Brainstorming Potential Solutions

DRAFT , 9/7/11

Notes:

 Reductions potentials are preliminary.

 Solutions are categorized only by their potential to reduce fine particle pollution and are based on the technical model. Any hurdles that might impede timely implementation are not considered, for example funding availability

 There may be other air quality, public health, or other benefits, unintended consequences, or impact on other community v alues not accounted for here. Major Reduction Potential (See assumptions at end at table)

Identifier Solution Initial Estimates of Reductions A Required removal of uncertified stoves and replace with non

- wood burning device (gas, oil, electric) , weatherization, and registration program:
Create mandatory registration program for wood burning devices (with fee based on efficiency, more efficient lower fee). Require weatherization, uncertified stoves to be removed by a certain date and, if a replacement is necessary, replace with natural gas. Include assistance for low income. Weatherization with sliding scale and high incentives for low income so it i s fully paid for; higher fees for people who chose not to do changeout. For rentals, fee goes to owner, not tenant. Total reduction of 1.6 ug by end of 2014, 5.9 ug by end of 2019

B Require changeout of uncertified stove and allow replacement with certified stove, weatherization and registration program:
Create mandatory registration program fo r all wood heating devices (fee based on efficiency, more efficient lower fee). Registration requires changeout of uncertified devices and Total reduction of 0.7 ug by end of 2014, 2.4 by end of 2019Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 59 weatherization of houses by a certain date. Include assistance for low income. C Require removal or changeout of uncertified stoves at time of sale:

Adopt a program requiring removal, decommissioning or changeout of uncertified stoves when homes are sold Total reduction of 0.7 ug by end of 2014, 2.2 ug by end of 2019

D Increase enforcement capacity:

Increase number of enforcement personnel to enforce burn bans (consider contracting out for private enforcement personnel). Total reduction of 0.5 ug by end of 2014, 2 ug by end of 2019

Assumptions: Removal and changeout solutions (A, B, and C): 50% of people do the removal or changeout by end of 2019 2,000 households per year Start Jan 2013 Assumed 1/3 of the 2,000 per year needed weatherization creating a 5% reduction in heating requirements Time of Sale Solution (C) Would require legislation and so could not start until 2013 3

- 5% of houses are sold each year (low

- high) The fraction of uncertified devices in houses that are sold is the same as in all houses Some houses will be resold, but w ill n o t be double count ed Assume 75% compliance So, each year 2.2

- 3.7% of devices are removed (the number removed decreases each year) Enhanced Enforcement Solutions (D) 4 Notices of Violation per Day per Field Team No change of behavior based on Word of Mou th No Outreach in Scenario 90% of burners that receive a notice of violation never violate a burn ban again. 10 Burn Ban Days per Year 2 Workers per Team (30 Total Teams) Enforcement on Weekends, Weekdays, and HolidaysTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 60



### Supplemental Solutions for Major Solutions A, B, & C

– Registration Program and Weatherization with Removal or Changeout of Uncertified Stoves, Remove or Changeout Uncertified Stoves or Fireplaces at Time of Sale of Home

Identifier Solution Key Informatio n A/B/C 1 Use incentives as a motivation to change

out high emission wood burning appliances (fireplace, old technology wood stove) anytime to EPA certified /WA State approved stove, pellet stove, or natural gas/propane/electricity. Incentives could inclu de tax incentives, cash, grants to pay some/all of costs, low interest loans.  Provides funding options

 Based on the response to previous voluntary changeout and removal programs, it does not attract enough people to have a significant reduction.

A/B/C 2 Have utilities pay for gas line extensions.  Provides more options for changeouts and removals

 Less expensive to operate than electric baseboard or oil A/B/C 3 Explore how residents can pay the utility

over time for extensions 

###  This is already an option wit h PSE

A/B/C 4 Create a bank where pollution sources pay

in and the funds are used where and as needed for sources that will make a difference (similar to offsite mitigation)  Likely to be small amount of money

so w ill n o t make a large reduction



###  Provides funding options for removing or changing out stoves A/B/C 5 Allow utility rate payers to opt in

(volunteer) to pay for change outs (like PSE’s Warm Home Fund)  Likely to be small amount of money

so w ill n o t make a large reduction

 Provides funding options for removing or changing out stoves A/B/C 6 Offer a coupon for changeouts or removals

at point of sale  Provides incentive

A/B/C 7 Either remove or “board up” fireplaces at

time of sale or require gas/propane log retrofit, certified insert, or pellet inse rt. 

###  Total reduction of 0.3 ug by end of 2014, 1 ug by end of 2019



###  Could supplement removal or changeout of uncertified stoves and inserts at time of sale



### Supplemental Solutions for Major Solution D

– Burn Ban Enforcement Related

Identifier Solution Key Information D 1 Require registration of wood heat systems that are the only adequate source of heat prior to enforcement Registration by itself does n o t provide reductions, but can increase burn ban compliance if:

 Used to Identify homes with only adequat e source of heat

 Used to identify which homes have certified and which have uncertifiedTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 61



### Identifier Solution Key Information devices

 Combined with enhanced enforcement and other burn ban enforcement supplemental solutions D 2 Registration at times of purchasing new stove or change out Registration by itself do es n o t provide reductions, but can increase burn ban compliance if:

 Used to Identify homes with only adequate source of heat

 Used to identify which homes have certified and which have uncertified devices

 Combined with enhanced enfo rcement and other burn ban enforcement supplemental solutions D 3 Take advantage of point of sale of homes for registration requirements Registration by itself do es n o t provide reductions, but can increase burn ban compliance if:

 Used to Identify homes wi th only adequate source of heat

 Used to identify which homes have certified and which have uncertified devices

 Combined with enhanced enforcement and other burn ban enforcement supplemental solutions D 4 Change current burn ban program to a single stage burn ban equivalent to Stage 2

. Total reduction negligible with current burn ban compliance, but if combined with enhanced enforcement and other burn ban enforcement supplemental solutions makes it more effective. D 5 Make standards during non

- attainment clear and understandable

– i.e., no visible smoke Total reduction negligible with current burn ban compliance, but if combined with enhanced enforcement and other burn ban enforcement supplemental solutions makes it more effective. D 6 Ban on wood heat a s only adequate source of heat for all households, existing and new; tied to financial assistance for other energy costs and change outs/ Wood burning devices should not be only adequate source of heat in non

- attainment area.  Total maximum reduction about 0.5 ug

 Would eliminate exemption in burn bans, allowing better enforcement and compliance

 If combined with enhanced enforcement and other burn ban enforcement supplemental solutions makes it more effective. D 7 Improve enforcement of burn bans using infra red viewer/camera for night

-  Total reduction negligible with current burn ban complianceTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 62



### Identifier Solution Key Information

time enforcement  Allows enforcement at times when fine particle pollution is highest

 If combined with enhanced enforcement and other burn ban enforcement supplemental s olutions makes it more effective.

 Cannot distinguish what type of device is creating the heat

– could be something other than a wood burning device D 8 Reduce “rates” for other sources of heat during non

- attainment periods (assumed to mean during burn bans) Total reduction negligible with current burn ban compliance, but if combined with enhanced enforcement and other burn ban enforcement supplemental solutions makes it more effective.



### Supplemental Solutions Applicable to All Major Solutions

– Wood Mo isture Related

Identifier Solution Key Information All 1 Use/distribute/educate on moisture content devices to wood burners (requirement?).  Reductions due to optimum wood moisture are not quantifiable. However, general consensus is that wood in the 15

– 25% range burns more cleanly than wood with either higher or lower wood moisture.

 Help reduce fine particle pollution at times outside burn bans All 2 Central wood seasoning station or swap

program – provide people with efficient fuel.  Reductions due to optimum wood moisture are not quantifiable. However, general consensus is that wood in the 15

– 25% range burns more cleanly than wood with either higher or lower wood moisture.

 Help reduce fine particle pollution at times outside burn bans All 3 Voucher for dry firewood, based on

renter’s income not landlord.  Reductions due to optimum wood moisture are not quantifiable. However, general consensus is that wood in the 15

– 25% range burns more cleanly than wood with either higher or lower wood moisture.

 He lp reduce fine particle pollution at times outside burn bans All 4 License wood fuel sellers to create certified wood exchange.  Reductions due to optimum wood moisture are not quantifiable. However, general consensus is thatTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 63



### Identifier Solution Key Information wood in the 15

– 25% range bu rns more cleanly than wood with either higher or lower wood moisture.

 Help reduce fine particle pollution at times outside burn bans All 5 Provide free moisture checks for cordwood fuel.  Reductions due to optimum wood moisture are not quantifiable. However, general consensus is that wood in the 15

– 25% range burns more cleanly than wood with either higher or lower wood moisture.

 Help reduce fine particle pollution at times outside burn bans All 6 Create home fuel storage requirements.  Reductions d ue to optimum wood moisture are not quantifiable. However, general consensus is that wood in the 15

– 25% range burns more cleanly than wood with either higher or lower wood moisture.

 Help reduce fine particle pollution at times outside burn bans All 7 Pr ohibit sale or use of cordwood fuel with 20%+ moisture content using Department of Ecology approved moisture meter.  Reductions due to optimum wood moisture are not quantifiable. However, general consensus is that wood in the 15

– 25% range burns

more cleanly than wood with either higher or lower wood moisture.

 Help reduce fine particle pollution at times outside burn bans



### Low Reduction Potential

Identifier Solution Key Information L 1 Explore filtering technology for wood stoves to determine if it i s effective and affordable  Very limited applicability of existing filter technology to wood stoves

 Other non

- filter technologies like catalytic combustors, natural gas firestarters, and grates may reduce emissions



###  Not enforceable measure L 2 Is there a w ay to change utility billing to become aware of energy use?  PSE currently provides comparison of usage to the previous year for both electricity and gas.

 May not reduce emissions if it encourages people with non

- woodTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 64 sources of heat to switch over to wood to keep usage down.

 Not enforceable L 3 Change Second Stage burn bans for non

attainment area

. Call second stage burn ban when PM 2.5 levels have reached 20 micrograms

- down from 25

– current law Would help if there was a large buildup of fine particles throughout a burn ban, but it generally goes down during the day and back up at night. L 4 Impede burning of non

- cordwood fuels.  According to PSCAA survey, for Pierce County, on average, 92% of people burn only cordwood in their fireplaces, wood stoves a nd inserts.

 Missing key information

- how much

non

- cordwood is burned by the remaining 8% and emission factors for

non

- cordwood, but reduction is likely low

.
 Current law prohibits burning of anything besides seasoned cordwood. L 5 Recycling incentive fo r non

- cordwood wood waste so it does n o t get burned for heat.  According to PSCAA survey, for Pierce County, on average, 92% of people burn only cordwood in their fireplaces, wood stoves and inserts.

 Missing key information

- how much

non

- cordwood is burne d by the remaining 8% and emission factors for

non

- cordwood, but reduction is likely low

.
 Current law prohibits burning of anything besides seasoned cordwood. L 6 Traffic signal synchronization Less than 0.2 ug/m3 reduction L 7 Improving traffic flow Less than 0.2 ug/m3 reduction L 8 Expand commute trip reduction program to “new” communities Less than 0.2 ug/m3 reduction

L 9 Auto trade

- out program for bikes and/or fuel efficient autos Less than 0.2 ug/m3 reduction

L 10 Complete HOV lanes on I

- 5 Les s than 0.2 ug/m3 reduction L 11 Light rail extension from King County to Tacoma Less than 0.2 ug/m3 reduction

L 12 Land use policies that make it easier for people to avoid use of vehicles Less than 0.2 ug/m3 reduction

L 13 Planning denser communities

– more bike lanes and sidewalks Less than 0.2 ug/m3 reduction

L 14 Evaluate projects in I

- 5 Joint Base study to determine value to this issue Less than 0.2 ug/m3 reductionTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 65



### Public Education and Outreach (some of these could be part of an enforceable solut ion which may allow full credit)

1. Public education on vehicle idling similar to British Columbia signs
2. Target education of people with wood burning devices at times of burn ban 3. Promote programs that have multiple public benefits

– i.e., safe routes to school
4. Educate fireplace burners
5. Find opportunities to collaborate with other agencies

– i.e., health 6. Better targeting of educational outreach

– i.e., have doctors share the message with families with asthma attack visits to hospitals
7. More use of social m edia to promote good practices and burn ban 8. Mothers against dirty air campaign 9. Education re: acceptable practices on idling 10. Add fun to the mix

– competition for “clean cities”

. Create incentives for winners

– rewards like the winning city gets free electr ic car plugins, Best of Western WA.
11. Help people plan ahead for winter
12. Use more aggressive media campaign during burn ban periods 13. Take advantage of point of sale of homes for registration requirements, or education.
14. Explore list from previous brainstormin g re: marketing/outreachTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 66 

## Appendix E Assumptions Made in Solution Analysis

Appendix: Evaluation Tool Notes

Major Solution: Increase Enforcement Capability during Burn Bans

Solution Description: Increase number of enforcement personnel to carry out burn bans (consider contracting out for private enforcement personnel).

General Assumptions:

The main assumption of this scenario that results in pollution reduction is that a major percentage of people who receive a burn ban civil penalty never burn again during a ban. The scenario to make this idea quantifiable is to increase the number of inspectors from the current 12 to 75 (likely using a subcontractor).

1. This assume s calling 10 burn bans days per year in Pierce County. This was based on the calculated average number of days over 35 micrograms per cubic meter over the last 5 years.
2. 75 Field Workers (ramped up

– year 1: 25 workers, year 2: 50 workers, year 3+: 75 workers). 3. 1 Worker pe r Field Team.
4. 7 Hours of Enforcement on weekends and weekdays during daylight hours (daytime enforcement only).
5. 1.25 Notices of Violation (NOV) per Hour per Worker

– a rate estimated from compliance staff at PSCAA. 6. 80% Rate of NOV to Civil Penalty

– a rate estimated from compliance staff at PSCAA of the percentage of NOVs that result in a civil penalty.
7. 0% Word of Mouth Percent to Neighbors about Civil Penalty

– Unknown and took conservative assumption . No information is available on whether anyone tells th eir neighbors they got an NOV or paid a fine. 8. 25% Repeat Offender Percent

– This means that 25% of the people who receive a civil penalty from PSCAA continue to burn during burn bans. This percentage is highlighted as it was increased after being presented this to the task force. Initially the assumption was 10%, but there was some consensus from the Clean Air Task Force that compliance with burn bans was worse and should be lowered. PSCAA’s system is not set up to track if people are repeatedly receivin g notices of violation, so there is a high level of uncertainty in this assumption. 9. 25% Percent Burners during the Day

– This means 25% of the people who have a wood burning device and use it will be burning during the day. This is based on recent surveys of Pierce County and Puget Sound residents. This figure puts a maximum number of burners that could be burning during the day if none were complying with the burn ban. 10. 80% Percent of All Devices Burning During Burn Ban

-- This means 80% of the people do N OT comply with the burn bans, and 20% do comply. This is based on surveys in the nonattainment area on burnTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 67

ban compliance. Additionally, it factors in people simply not burning (busy, on vacation, etc.). This assumption sets another upper bound on how m any devices can be enforced and are burning during a burn ban.
11. The scenario assumes enforcement based on visible emissions alone, not smoke density (opacity) as is currently done. 12. There is an exemption for income

- qualified households to burn during a burn ban. 13. Assumes some form of registration program to identify only adequate source of heat burners, income

- qualified households, and certified devices.
14. Higher night enforcement presence.
15. Large burn ban advertising campaign (approximately $200,000 or 50% of th e county audience is reached more than 3 times via television, radio, and online ads). Conservatively estimated only 5% additional compliance from uninformed burners

– high level of uncertainty on this estimate. 16. Assumes current two

- stage burn ban program (no alterations to trigger levels, fines, etc).

Cost Assumptions:

1. Cost of Field Staff per year including all costs: $560,000.
2. Cost of Legal/Administrative Staff per year including all costs: $220,000.
3. Cost of training for all field staff per year: $40,000.
4. Vehicle Costs for 10 burn ban days per year: $30,000.
5. 1 Hour to Process 1 NOV

– a rate estimated from compliance staff at PSCAA, includes administrative staff time, interaction with individuals, paperwork, etc. 6. Night Enforcement Devices (infrared cameras): $90,000.
7. Civil penalties collected: $530,000.
8. Burn Ban Advertising: $200,000.

Agency Evaluation of Each Criterion with Rationale:

Reduction

By 2014: 1.4 micrograms per cubic meter (about 15% of the minimum reduction needed) By 2019: 6.8 micrograms per cubic meter (about 75% of the minimum reduction needed)

Economic Feasibility

$1.2M per microgram per cubic meter

Maintainable:

Somewhat/Mixed = Does not improve air quality over time significantly by 2014, but does with ramp up by 2019. It does not address some of the underlying causes (such as wood is still a source of heat and the potential is there if enforcement funding ended).Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 68

Implementa tion:

Somewhat/Mixed = May be hard to find 75 inspectors to work 0

- 2 weeks on

- call each fall/ winter. There is, however, a commitment to enforce burn bans as the program is already established through PSCAA and adequate authority already exists in Washing ton State law.

Unintended Consequences:

Somewhat/Mixed = May be public backlash that endangers the burn ban program, unexpected staff time burden processing notices of violation, unexpected staff time and costs to run program, unexpected financial burden on the public.

Funding Availability:

Somewhat/Mixed = Funding could potentially be secured based on prior commitments from the legislature focusing on wood smoke. There is a lot unknown with the current budget, but funding may be plausible.

Technicall y Feasible/Sound:

Somewhat/Mixed = PSCAA ha s been enforcing burn bans in Washington for over 20 years. With increased enforcement that would curtail future burning, it is possible to estimate what the future emission reductions would be. However, night enforcement can be technically challenging

. PSCAA is exploring current technologies to increase current capability.

Timing/Timely:

Very Well = Can implement before 2014 if a contractor could be lined up and trained for enforcement. A lot of knowledge and infrastructure is already established from PSCAA’s experience.

Enforceable:

Very Well = Is already in Washington State law and would quali fy with EPA’s criteria as enforceable.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 69

Major Solution: Date Certain Removal of Uncertified Devices

Solution Description:

1. Require uncertified stoves to be removed by a certain date. 2. Add measures to make program more equitable (e.g home weatherization w ith removal, incentives, subsidize for low income households an alternative source of heat for homes with no other heat source, etc). Assumptions:
Assumptions that Effect Emissions:

1. Removal rate of 1,000 uncertified devices removed per year.
2. Expect actual compliance/disclosure rate of 33% (7,000 uncertified devices removed out of 22,000).
3. Assumes 50% of households that remove uncertified devices purchase their own certified device on their own money. This is based on PSCAA agency records of change

- out pro grams where 50% chose a certified wood burning device when given the option to replace with another heat option, even when the incentive was smaller. Also includes 2% growth of certified devices each year with new construction.
4. Actual date certain is the e nd of August 2015, with first 1,000 removed before this date with incentives. 5. Assumes some form of registration of all wood stoves and inserts (not including fireplaces) to confirm removal of uncertified devices. Assumptions that Effect Cost:

The following are just an example of potential programs that could be included based on if funds were available to implement all of these. If the compliance assumption is raised, the costs would similarly increase for most categories:

1. Free removal for all uncertified devices . Costs about $4M over the life of the program.
2. Free weatherizing to all income qualified households as this scenario potentially removes a cheaper source of heat and makes household more reliant on utility. 12% of Pierce County is below the povert y level (2005

- 2009 data). Used 150% of the poverty level or 18%. Weatherization assumptions from PSE’s 2010 Integrated Resource Plan. Includes percentage of single family residence estimates where weatherization is possible. Also includes cost estimates for each type (weather stripping, floor, wall, and attic insulation). Costs about $4M over the life of the program.
3. If only adequate source of heat, program will provide subsidy to purchase and install a new sources of heat . About 300 devices will be rep laced by other non

- wood heating sources for low income residents (0.20% to 28.3% of wood device owners could be primary burners based on wood stove change

- out data). Conservatively, used ratio of uncertified devices to get total from primary burners (34%)

. Costs of replacement devices from experience withTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 70 PSCAA’s change out programs ($2500 for certified stove, $6500 for natural gas stove/insert, $4500 for heat pump, $9500 for whole house heat pump, $4500 for propane). Costs about $2.5M over life of progra m. 4. $500 reward if uncertified device is removed within the first year (up to 3,000 devices). Costs no more than $1.5M over life of program.
5. Registration program . Staff costs for maintaining program conservatively estimated at $200K/yr.
6. Expanded outreach to ensure that the message gets out to all communities and ample efforts are made to communicate to low income and other groups regarding heat/weatherization/etc. Assumes 5% of program costs ($280K).

Agency Evaluation of Each Criterion with Rationale:

Re duction

By 2014: 0.7 micrograms per cubic meter (less than 10% of the minimum reduction needed). By 2019: 2.5 micrograms per cubic meter (about 25% of the minimum reduction needed).

Economic Feasibility

$5.4M per microgram per cubic meter if all the programs above were implemented.

Maintainable:

Very Well = Will improve air quality (2.3 micrograms per cubic meter by 2014), does address some underlying causes.

Implementation:

Somewhat/Mixed = May be difficult to enforce required removals, but expected compliance set low in model. May be implementable with enough incentives. No current commitment or authority to do so.

Unintended Consequences:

Not Well = May be public backlash that endange rs the burn ban program, unexpectedly low level of compliance, unexpected staff time burden processing notices of violation, unexpected staff time and costs to run program, unexpected financial burden on the public.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 71

Funding Availability:

Somewhat/Mixed = All funding would not likely be secured by 2014, possibly beyond. This criterion is highly dependent on which program options are chosen and how it drives the costs.

Technically Feasible/Sound:

Very Well = Emission reductions would be easily measured.

Timing/Timely:

Very Well = Good reductions by 2014 and 2019.

Enforceable:

Very Well = Qualifies as an enforceable measure in EPA criteria.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 72 

## Appendix F Health Effects Studies

Puget Sound Clean Air Agency 

## Fine particle pollution:

Information from Health Studies

The following is an overview of the findings from health studies and reviews during the past decade about the health effects of breathing fine particulate matter.

What is fine particle pollution? Fine particles (PM 2.5 ) are tiny particles of soot, and dust suspended in the air. These particles come primarily from combustion (burning) activities. Main sources include wood smoke (from burning of wood) and vehicle exhaust (from burning of fossil fuels). Some PM 2.5 also comes from industry a nd other sources. PM 2.5 is very small, with a diameter of 2.5 micrometers

-- approximately 1/30 th the diameter of a human hair. This very small size allows PM 2.5 to travel deeply into the lungs, even into the bloodstream.

How can fine particle pollut ion affect health? Exposure to fine particles can affect both the lungs and the heart. This exposure has been linked to increased hospital admissions and emergency room visits, and to death from heart or lung diseases. Studies have found that even short

- term exposures can cause health problems, especially in infants and young children, elderly people, and in people who have heart or lung or diseases, chronic obstructive pulmonary disease (COPD), asthma, or high blood pressure.

 Respiratory (lung) hea lth effects: Many studies have linked fine particles to health problems affecting the lungs and respiratory system. The main respiratory effects include 1 :

 Inflammation of lungs and airways (also systemic and heart inflammation)

 Reduced lung function (red uced lung capacity or more difficult breathing)

 Asthma trigger (worsening of asthma symptoms)

 Lung cancer (for long

- term exposure to PM 2.5 , especially fine particles from diesel engines 2 )

 Increased risk of death from respiratory illnesses
 Cardiovascular ( heart) health effects: Many health studies have stressed the association between fine particulate matter and cardiovascular health. The main cardiac health effects include:

 Worsening of heart and vascular diseases, high blood pressure

1 See EPA’s Particulate Matter

– Health web page ( http:// www.epa.gov/airquality/particlepollution/health.html )

. 2 California Of fice of Environmental Health Ha zard Assessment , Health Effects of Diesel Exhaust Fact Sheet, http://oehha.ca.gov/p ublic_info/facts/dieselfacts.html

.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 73

 Altered cardiac fun ction

 Increased atherosclerosis (clogging of vessels)

 Increased risk of illness and death from heart attack

 Increased risk of illness and death from stroke



### A sampling of peer

- reviewed health studies Respiratory Health Effects:

 Fine particle pollution was linked to lung cancer and cardiopulmonary mortality in a large ongoing mortality study with about 500,000 participants. Pope, et al. Lung Cancer, Cardiopulmonary Mortality, and Long

- Term Exposure to Fine Particulate Air Polluti on. Journal of the American Medical Association. 287, 1132

- 1141. March 6, 2002.

 A study of over 1,500 children in 12 southern California communities showed that exposures to elevated concentrations of fine particle pollution between the ages of 10 and 18 were associated with clinically and statistically significant reduction of lung function. Gauderman, et al. The Effect of Air Pollution on Lung Development from 10 to 18 Years of Age. The New England Journal of Medicine. Volume 351:11, 1057

– 1067. Sep tember 9, 2004.

 A study of cystic fibrosis patients showed that exposures to elevated fine particle pollution levels were associated with reduced lung function and an increase in the odds of a patient having two or more exacerbations. Goss, et al. Effect of Ambient Air Pollution on Pulmonary Exacerbations and Lung Function in Cystic Fibrosis. American Journal of Respiratory Critical Care Medicine

. Volume 169, 816

- 821. January 12, 2004.

 An Oakland, California cross

- sectional study of more than 1,000 scho ol children suggested an association between respiratory symptoms and traffic

- related pollution. Kim, et al. Traffic

Related Air Pollution near Busy Roads. American Journal of Respiratory and Critical Care Medicine. Volume 170, 520

- 526. 2004.

 A Tacoma , Washington study showed an association between elevated fine particle pollution levels and asthma emergency room visits at six Tacoma hospitals. Asthma emergency room visits increased two to three days following elevated fine particle events. Data were collected form air quality monitors and hospitals from January 1998 to May 2002. Mar et al. Associations between asthma emergency visits and particulate matter sources, including diesel emissions from stationary generators in Tacoma, Washington. Inhala tion Toxicology , 22(6): 445

- 448. 2010.

Cardiovascular Health Effects:

 A German study of 691 patients with cardiovascular disease showed a statistically significant association between transient exposure to traffic and the onset of a myocardial infarction within one hour afterward. Peters, et al. Exposure to Traffic and the Onset of Myocardial Infarction. The New England Journal of Medicine . Volume 351:17, 1721

- 1730. October 21, 2004.

 A Boston study of almost 500 older men enrolled in the Normative Aging Study showed associations between short

- term exposures to fine particulate and ozone, and alterations in cardiac function (measured by heart rate variability). Park, et al. Effects of Air Pollution on HeartTacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 74

Rate Variability: The VA Normative Aging Study. Environmental Health Perspectives. Volume 113:3, 304

– 309. March 2005. ( http://ehp.niehs.nih.gov/members/2004/7447/7447.pdf ).

 A Los Angeles study of 798 patients showed an increased caro tid artery thickness with greater particulate matter concentrations. Thicker carotid arteries are considered a measure of atherosclerosis, considered a process/precursor of cardiovascular disease. Kunzli, et al. Ambient Air Pollution and Atherosclerosis i n Los Angeles. Environmental Health Perspectives. Volume 113:2, 201

- 206. February 2005

. ( http://ehp.niehs.nih.gov/members/2004/7523/7523.pdf ).

 A 2007 study showed that PM 2.5 concentrations are linked with increased risk of death from heart attack and stroke in postmenopausal women. The study of 66,000 postmenopausal women from the Women’s Health Initiative (WHI) showed that, for every 10 ug/m3 increase in PM 2.5 concentrations , the risk of dying from a stroke or heart attack went up 76%. Miller, et al. Long

- term Exposure to Air Pollution and Incidence of Cardiovascular Events in Women. The New England Journal of Medicine . February 1, 2007 ( www.nejm.org ).

 A study of six cities showed higher overall mortality rates in cities with the highest fine particle pollution when compared to cleaner cities. [Often referred to as the Harvard Study.] Dockery ,et al. An Association Between Air Pollution and Mortality in Six US Cities. New England Journal of Medicine . 1993.



### Health reviews and studies

 In 2010 the American Heart Association updated its 2004 scientific statement “Particulate Matter Air Pollution and Cardiovascular Disease.” This statement provides a summary of studies and reached several new conclusions. These conclusions include that “exposure to PM 2.5 over a few hours to weeks can trigger cardiovascular disease

- related mortality and nonfatal events”; and that exposure over a fe w years can reduce life expectancy by several months to a few years. The report also finds that reduced particulate matter levels are associated with reductions in cardiovascular mortality within a time frame as short as a few years. Brook, et al. Parti culate Matter Air Pollution and Cardiovascular Disease. An Update to the Scientific Statement from the American Heart Association. Circulation, Journal of the American Heart Association. May 10, 2010. ( http://ci rc.ahajournals.org ).

 EPA strengthened its daily PM 2.5 standard in 2006 based on an extensive review that highlighted cardiac effects nationwide. ( http://www.epa.gov/ttn/naaqs/standa rds/pm/s_pm_index.html ).

 In October 2008, the California Air Resources Board adopted a concentration response of 10% increase in risk of premature death for every 10 micrograms per cubic meter increase in exposure to PM 2.5 . Their analysis is based on a comprehensive review of epidemiological and toxicological studies. ( http://www.arb.ca.gov/research/health/pm

- mort/pm

- mort_final.pdf ).

 The Bay Area Air Quality Management Distr ict keeps an extensive list of toxicologic and epidemiologic studies that examine the association between health effects and wood smoke (a type of fine particle). ( http://www.sparetheair.org/~/media/STA/Files/1/Particulate%20Matter/woodburning_health effects.ashx ).Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 75

 California EPA comprehensively reviewed human and animal cancer and non

- cancer studies to assess health risk from diesel particles (a type of fine particle). The California unit risk estimate for carcinogenicity is used in several studies (including local Puget Sound evaluation). A full risk assessment is included in Appendix B. Proposed Identification of Diesel Exhaust as a Toxic Air Contaminant. California EPA, May 1998. ( http://www.arb.ca.gov/regact/diesltac/diesltac.htm ).

 Health Effects of Wood Smoke (1992, updated 1997) by the Washington State Department of Ecology offers a comprehensive look at the health risks associated with indoor wood burning. ( http://www.ecy.wa.gov/biblio/92046.html ).

 “The toxicology of inhaled wood smoke” reviews animal and human data over the last 30 years. Zelikoff, et al. Journal of Toxicology and Environmental Health, Part B, 101

- 114, 2002.



### Why is it important to clean up the air?
A few recent studies show that improving air quality also results in a reduction of mortality rates:

 An eight

- year follow

- up of six cities showed that, as fine particle pollution levels decreased, total mortality risk also decreased. This study was a follow

- up of the Harvard study, with 8,096 participants in cities with varying PM 2.5 levels. Mos t mortality is attributed to cardiovascular and respiratory disease (not lung cancer). Laden, et al. Reduction in Fine Particulate Air Pollution and Mortality. American Journal of Respiratory and Critical Care Medicine. Volume 173, 667

- 672. March 2006.
See also the 2010 American Heart Association scientific statement about fine particles, summarized above.Tacoma

– Pierce County Clean Air Task Force Report and Recommenda tions, Dec. 2011 76

Endnotes

1 International Agency for Research on Cancer (IARC) (2010). “Overall Evaluation of Carcinogenicity to Humans. Group 2A: Probably Carcinogenic to Humans

. ”
2 W ashington State Department of Ecology, “Health Effects and Economic Impacts of Fine Particle Pollution in Washington,” December 2009, Pub. No. 09

- 02

- 021.
3 US EPA, Federal Register, “PM 2.5 and Ozone Clean Air Implementation Rule,” Vol. 72, No. 79, April 25, 2007, p

. 20585.
4 Values used in the figures are from EPA, which calculates using the method outlined in 40CFR50 Appendix N.
5 These values are a compilation of fine particle data from 2000

- 2010 at the Tacoma South L Street monitor. Federal Reference Method data were used when possible. Where data was missing, Federal Equivalent Method data were used. Next instrument of priority was the Tapered Element Oscillating Microbalance (TEOM) and lastly the nephelometer. Calculating the 98 th percentile is found in 40CF R50, Appendix N.
6 Ogulei, David, Washington Dept of Ecology, 2010, Sources of Fine Particles in the Wapato Hills

- Puyallup River Valley PM 2.5 Nonattainment Area. Available at http://www.ecy.wa.gov /pubs/1002009.pdf

. 7 National Research Center, Puget Sound Clean Air Agency Indoor Wood

- Burning Emission Inventory Survey of King, Kitsap, Pierce and Snohomish Counties (2007).
8 Washington State Department of Ecology, “The State of Washington’s Proposed Wapato Hills

- Puyallup River Valley PM 2.5 Nonattainment Area,” February 22, 2008. http://www.ecy.wa.gov/programs/air/Nonattainment/ProposedWHPRVPM2.5NonattainmentArea.pdf
9 Letter from the US EPA to Governor Gregoire of the State of Washington, dated August 18, 2008. http://cle anairpiercecounty.org/7A_EPA_Approval_of_Nonattainment_Area_Boundary.pdf
10 U.S. Census Bureau, 2010 Census, Population Census Block Group Data, published 2011.
11 U.S. Census Bureau, 2005

- 2009 American Community Survey, Census Block Group Data of Wood as a Primary Source of Heating Fuel, published 2010.
12 Puget Sound Clean Air Agency records of self

- identified primary and secondary heat sources from historical record of wood stove changeout program, 2007

- 2011.
13 Pierce County Tax Assessor, “2008 Pierce Count y parcel data,” 2009.
14 US EPA, Federal Register, Vol. 53, p. 5873, February 26, 1988, “Subpart AAA

- Standards of Performance for New Residential Wood Heaters,” 40 CFR 60, subpart AAA.
15 Washington Administrative Code 173

- 433

- 100.
16 Revised Code of Washingt on Section 70

- 94

- 473 “Emission performance standards.”
17 US EPA, Clean Air Act , Title I, Part D

– “Plan Requirements for Non attainment Areas

. ”
18 Pierce County Assessor

- Treasurer data: http://www.co.pierce.wa.us/pc/abtus/ourorg/at/Reports.htm ; NWMLS data provided by Dennis Jones to PSCAA on Oct ober 3, 2011.

19 Based on written correspondence with Oregon Department of Environmental Quality (ODEQ).
20 Revised Code of Washington 70

- 94

- 477.
21 Revised Code of Washington 70

- 120A

- 010

. 22 Based on written correspondence with Puget Sound Regional Council.
23 http://www.epa.gov/otaq/fuels/dieselfuels/index.htm
24 http://www.epa.gov/otaq/oceanvessels.htm#north

- america n 25 Washington Administrative Code 173

- 433

- 100