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: 206.343.7522
Tacoma–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, South 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 Council & Pierce County Regional Council (term 

ended in December 2011)

Kelly McGourty Puget Sound Regional Council

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 Director of Centro Latino

Lisa Rennie Tacoma Public Utilities

Catherine Rudolph Tacoma-Pierce County Association of Realtors

Tim Sexton Washington State Department 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 iii
Tacoma–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

III. Task Force Process for Developing Recommended Solutions........................................................23

A. Evaluation Criteria and Tools..........................................................................................................24

B. Potential Solutions..........................................................................................................................25

C. Focusing 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.......................................................................................................................56
Tacoma–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 Health 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 Street 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...........................................................................................................53
Tacoma–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 Plan
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 communitybased 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 operating 

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 

solutions 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 problem will not be solved by addressing only wood 

smoke, but it cannot be solved 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 “nonattainment area” for fine particle pollution (or PM2.5) 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. Fine 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 operations.

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 elevated 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.

Pollution Sources

More 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 highest pollution levels occur at night 

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 Recommendations, Dec. 2011 2

Implications of Nonattainment

Not attaining federal air quality standards impacts health and potentially impacts regional economic 

development. The fine particle 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, although children, 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 the 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. 

Their plan would not necessarily clean up the problem in the way the local community might prefer. Not 

acting 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 Department 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 substantial 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 

solutions, the task force used criteria the federal Clean Air Act requires 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 Clean 

Air Agency staff reviewed the solutions for their potential to reduce the level of fine particle pollution in 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 3

the area, and grouped them into 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.). 

Evaluation 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 time 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. The 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 values 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 

solutions: 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 several 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. There 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) strong concerns about the economic impacts of the potential solutions, particularly for 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 4

low- 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 smaller 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 help 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 reduce fine particle pollution for gasoline vehicles, 

diesel vehicles, industries and ships. 

The 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 these 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. Local 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 encourage 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 civic 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 manner 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

are 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 Recommendations, Dec. 2011 5

The task force recommendations regarding reduction of wood smoke pollution include a combination of 

suggested program design features and statements of principle to 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 focus 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.

Proposed 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: revise the emission thresholds 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 

cleanly 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 educational 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 discourage 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 local 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 Recommendations, Dec. 2011 6

 Revisions to the Stage 1 and/or Stage 2 “trigger” levels (when 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 utilized 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 meter 

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 Uncertified 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 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. The task force felt that establishing one clear date when all 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 and 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 intrusion 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 may 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 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 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 Recommendations, 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 confirmation 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 challenges 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: 1st assistance to low-income households; 2nd assistance 

to households with no other adequate source of heat; 3rd incentive payments for early adopters; 

and tied for 4th incentive payments of cleaner heat and assistance to all households for removal 

of stoves/inserts. 

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).

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 of 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 another 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: Other Pollution Sources

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 process 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 vehicles, the most stringent automobile standards in the country. These standards will 

help to reduce fine particle pollution. Local 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. The 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 Recommendations, Dec. 2011 8

New federal standards for diesel engines and fuel also 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 have 

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 nonattainment 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 reviewing the

existing pollution controls and operations at these 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, new international standards require use 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 approximately 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 standards for more efficient engines 

and cleaner fuels. Continued 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 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, the task force wanted the recommendations to first 

and foremost, 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. The 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 pollution 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 toward its target date. These additional solutions are 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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, 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 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 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. 

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. Three members did not support the 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 

registration 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 make recommendations to the State 

Department of Ecology. Ecology will conduct further analysis and prepare a State Implementation Plan

(SIP). There will be opportunities for public review and comment on the Plan. Because any local rules or 

state laws required 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 Recommendations, 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 parts of Tacoma and Pierce County as a “nonattainment area” for fine 

particle pollution (or PM2.5) 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.

The pollution comes from a variety of sources. But with half of the emissions coming from indoor wood 

burning (see Figure 4, below), it is 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 particles in the air measure 2.5 

micrometers in diameter or smaller – commonly referred to as PM2.5. This is a fraction of the diameter of 

a human hair. In the Pierce County nonattainment area, fine particle pollution comes mainly from 

combustion (burning) of 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 motors (from cars, trucks, 

buses, ships, etc.), and some industrial operations. Less significant contributions 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 particles 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 

function, 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 short-term exposures to fine particles can cause 

health problems. See Appendix F for a summary of health effects studies and references. 

Certain types of fine particles are considered toxic. For example, both diesel exhaust and wood smoke 

contain chemicals known to cause cancer.1Each year millions of dollars are spent treating illnesses and 

health conditions stemming from fine particle pollution that are preventable.2

Nonattainment designation. The federal EPA, under the authority of the federal Clean Air Act, sets

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 particle 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 Recommendations, Dec. 2011 11

Much of Tacoma and Pierce County are currently in “nonattainment” for the 24-hour fine particle 

pollution standard (does 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 are set at levels 

protective of public health. As part of that review, the EPA set a stronger daily (24-hour) air pollution 

standard (limit) for fine particle pollution in 2006.3This action was in response to numerous scientific 

and health studies that concluded that exposure 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 cubic 

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 air 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 and Pollution Levels

The Clean Air Agency operates a network of air monitoring stations in the Puget Sound area. There is a

monitor in the South 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 (see 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. These monitors also collect data from which the Clean Air Agency can 

estimate the annual average concentration for fine particle pollution.

4
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 2002.4
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 standard, which represents the highest 

pollution days. 4

Fall and wintertime pollution pattern. The violations of the federal daily standard for fine particle 

pollution in the nonattainment area occur in the late fall and winter months (see 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 ensures that an area is not designated as nonattainment just 

because of one bad year.
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 14

Figure 3. Tacoma South L Street Fine Particle Pollution by Month, 2000 – 2010 

Air pollution levels at Tacoma South L Street monitor exceeded the standard 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 gasoline vehicles (see 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. These 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 when
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 15

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

rising. 

During 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. The 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 32 and 34

micrograms per cubic meter (a little over 20 percent), in order to reach 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 impact on their local air quality.
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 16

What Is the Area of Concern?

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, jurisdictional boundaries, and control of emissions.8In 2009, the EPA 

approved the boundary.9The nonattainment area includes most of Tacoma, including the Port of 

Tacoma and residential areas, and most of the Pierce County urban growth area, including the cities 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 exception 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 White 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 Recommendations, Dec. 2011 17

Figure 6. Map of Nonattainment Area, with Jurisdiction Boundaries 

Wood burning devices in use in the nonattainment area. The Clean Air Agency provided estimates of 

the number of households in the nonattainment area that have wood burning devices and the number 

in use (see Table 1), and of the number who use wood as their primary or sole heat source (see Table 2). 

These estimates were based on results of a survey done by the National Research Center in 20077 and 

U.S. Census data.10

Table 1. Wood 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 Indoor Wood-Burning Emission 

Inventory Survey of King, Kitsap, Pierce and Snohomish Counties (2007).
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 18

Table 2. Wood Use for Heat in the Nonattainment Area

Number of 

Households

Percent 

Use wood as primary source of heat11 3,446 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 heat13 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 sources 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 of 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 173-433-030).

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 

definition 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.

Even though a home may have working, non‐wood heating equipment that is sufficient to heat the 

home—such as a gas, oil or electric furnace, or electric heaters—a wood burner might consider his or 

her wood stove to be the home’s “primary source of heat.” According to the 2005‐2009 American 

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. Any wood stove or fireplace 

insert can last as long as 40 years, so there are still an estimated 21,200 uncertified wood stoves 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 50 percent less polluting) and are more 

energy efficient than older uncertified stoves. In 1988, the EPA issued standards of performance and 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 January 1, 1995, wood stoves offered for sale in the state of 

Washington must meet an emission limit that is more strict than the EPA standard.15 Certified wood 

stoves sold in Washington state 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 burn 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 

Washington state’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 state as among the 

lowest emission solid fuel heaters and on average 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 nonattainment 

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 

Washington die every year because of fine particle 

pollution.2

Nonattainment can also hinder economic development and tourism in the area and wider region. 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 equipment. These factors might prompt 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 clean up the problem in the 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 pollution
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 societal 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 cleaner air, Ecology 

must develop a State Implementation Plan (SIP) and submit it to the EPA by December 2012 for 

approval. The 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) describe how these actions will lead to meeting the air quality 

standard; and (3) project when air quality will meet the standard. 

The Puget Sound Clean Air Agency, as the regional air quality regulatory agency with jurisdiction within 

Pierce County, is working 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 daily fine particle pollution levels recorded at the Tacoma South L Street 

monitor to below the federal daily standard of 35 micrograms per cubic meter measured over a 

24-hour period. This requires reducing current levels by at least 9 (and possibly up to 11,

depending on the results of 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. 

 Address all sources of fine particle pollution.

 Use primarily enforceable actions 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 redesignation 

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 Recommendations, Dec. 2011 21

3. The SIP developed for the area has met the requirements of the federal 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 nonattainment areas. 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 

members were community leaders, elected officials and residents (see list on page ii). Craig Kenworthy, 

the Executive Director of the Puget Sound Clean Air Agency, and Stu Clark, the Air Quality Program 

Manager of the Washington State Department of Ecology, were ex-officio nonvoting members. The 

members were chosen for their expertise and experience in one 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 sources 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: 

wood 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 the 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 ground rules included 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 provided 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 opinion 

were to be noted and included as part of the task force’s final recommendations. 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 23

III. Task Force Process for Developing Recommended Solutions

The Tacoma–Pierce County Clean Air Task Force met a total of 11 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 responding 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, the task force worked 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

reductions 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 this process.

Figure 7. Process for Developing Task Force Recommendations

Note: The “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 Recommendations, Dec. 2011 24

A. Evaluation Criteria and Tools

Staff 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: reasonable, technically feasible, economically feasible, timely, and 

enforceable. 

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 criteria 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 requiring 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 for 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 criterion?, with the rating scale of very well (V), somewhat/mixed (S), and not 

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.

PSCAA Micrograms per 

cubic meter by 2014 

and 2019

Emission Reduction Reductions in the amount of emissions emitted 

from the sources.

PSCAA Tons of PM2.5

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 Force V, S, N

Economic Well-Being of 

the County

Will enhance the economic development 

potential for Pierce County.

Task Force V, S, N

Minimize Burden on 

Vulnerable 

Will minimize the economic burden on individuals 

and households.

Task Force V, S, N
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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. Emissions 

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. Has defined 

violations. Can identify liable person. Enforceable 

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 (see Appendix C).

B. Potential Solutions 

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 particle pollution, and brainstormed possible solutions for 

use in the nonattainment area. This process produced a list of more than 60 potential solutions. Clean 

Air Agency staff organized the list by emissions source—wood smoke, vehicles, other—and public 

education and outreach. 

The staff then reviewed the solutions in terms of their potential to reduce the level of fine particle 

pollution in the area, and grouped them in four categories (see 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 stoves by a date certain, with certified stoves allowed as 

replacements

C. Require removal or changeout of uncertified stoves at time of sale of the home

D. Increase capacity to enforce burn bans
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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, but 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. Task force members 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 second stage of burn bans in the nonattainment area 

(from 25 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 

the evaluations. 

4. Public education and outreach — 14 solutions. These were grouped separately because, while 

an important part of the overall solution, the 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 Solutions 

The Clean Air Agency staff provided the task force with an evaluation of each of the four major 

reduction solutions separately and combined 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 Stoves and Inserts:

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

 enforcing the ban more effectively during evening hours

 increasing awareness of burn bans
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 27

 increasing education and outreach

 Date Certain Removal of Uncertified Wood Stoves and Inserts with a Variety of Options:

o Date certain removal, and restrict replacements 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 

emissions) or a wood stove with 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 

information, 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 estimated 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 

time 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 for each 

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 quality standards. Figure 8 represents the “Progress Meter” used by the task force. The 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 to 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 included two potential reduction goals: a 

minimum reduction of 9 micrograms 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 Clean 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 change in the final SIP. 

Figure 8. Example of a Progress Thermometer

The blue lines signify the minimum reduction needed 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 

house is sold. The transaction of selling 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 and 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 29

removed. The Oregon program was adopted in 2009 and effective in 2010, so there are limited 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 Assessor-Treasurer’s reports from 2008 to 2010, and from 

Northwest Multiple Listing Service data provided by representatives from the Tacoma-Pierce 

County Association of Realtors.

18

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

program estimated a 75 percent compliance rate, but there are not 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 approximated 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 0.32 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 total 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. Task force members felt it would be 

inequitable to single out those households to reduce fine particle emissions, since they represent a small 

portion of the total number 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 was not used to burn 

wood.

In addition, task force members expressed concern about relying on this 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, given the need to make 

substantial progress toward 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 modifications 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 state law allows local agencies to restrict the use of 

residential wood 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 estimates 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 state 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 at 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 micrograms 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 pollution 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 the 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 – January 2011),

10 notices of violation were issued in Pierce County for violation of the ban.

Enhanced 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. (An 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.

 Increase 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 bans are 

called (i.e., consider changing the “triggers,” the forecasted levels of pollution, when burn bans 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 31

would take effect). This could better enable the community to use burn bans to avoid exceeding

the air quality standard.

 Provide assistance for low-income households so they are not forced to spend limited 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 

violation 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 civil penalty for violating a burn ban would not burn again 

during a burn ban.

 The number of inspection personnel would be ramped up over the first three years, resulting in 

potentially 4,000 notices of violation being issued in Year Three.

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 about 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 meter 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 focus action during 

the days of the year when fine particle pollution in the nonattainment area exceeds the federal air 

quality standards. 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 circumstances in other communities are not 

directly analogous 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 enforcement, the need to 

include considerable public education along with enhancing enforcement of burn bans, and others), but 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 32

concluded that these challenges could be solved and that the solution could achieve results in the nearterm and over time. 

Date Certain 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 and 

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 

stoves and inserts in nonattainment areas if it could be demonstrated that the wood smoke was found 

to be part of the air pollution problem, and if there were a program to assist low-income residents in 

complying with the regulations.

20 In addition, the legislation 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 this 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 uncertified device 

before the deadline, and stiffer fines for failing to remove 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 

removed is the end of August 2015.

This solution would 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 payments 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 solution 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 that residents should 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 being removed. Three levels of confirmation were considered: low, 

medium, and active. Low confirmation would include outreach and incentives, but would not include 

meaningful ways to confirm removal. This level of confirmation would not meet EPA requirements of 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 33

enforceability. The medium level of confirmation would 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 burning 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 could include 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 uncertified wood stoves and inserts.

Selected Key Assumptions: 

 The number of uncertified wood stoves and inserts that would 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 analysis 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 million.

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 would 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 Recommendations, Dec. 2011 34

Reductions in Other Sources of Pollution

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 pollution 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 Vehicles

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 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 fine 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 to gasoline 

engines: Pierce County, the City of Tacoma, and Tacoma Public Utilities have installed 20 electric vehicle 

charging stations in the area, and have purchased electric vehicles, along with vehicles that use 

biodiesel. Anti–automobile-idling programs have been adopted for schools, Washington State Ferry 

loading areas and for some public fleets.

The regional transportation plan adopted by the Puget Sound Regional Council has several policy goals 

that will help reduce fine particle pollution:

 Focus population 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-motorized 

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: highoccupancy vehicle (HOV) lane extensions on I-5 and SR 16; ramp metering on I-5 in the Joint Base LewisMcCord area; Sounder (commuter rail) improvements from Tacoma to Lakewood; and selected bicycle 

lanes, sidewalks and trails to encourage alternative means of travel.22

Diesel Vehicles

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 newer 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 school 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 idle-reduction program; use of biodiesel by all of the City of Tacoma, the Port of Tacoma and 

Tacoma Public Utilities diesel fleets; 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 trading 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 sources 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 Reasonably 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 Agency 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 lower sulfur fuel, beginning in 2012 and 

moving to a much stricter levels by 2015. These cleaner fuels will reduce the fine particle pollution from 

ships.

24 The Port of Tacoma and Totem Ocean Trailer Express have 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 Recommendations, 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 projects 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 smoke 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 come from changes in federal standards for more efficient engines and 

cleaner fuels. However, while the range of local initiatives does not add a significant amount to the 

estimates of emission reduction in the nonattainment area, continued efforts to reduce emissions from

these sources will contribute to the overall plan. 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 the 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 

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 concentrated during October

and November 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 approximately 200 people attended.

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

More than 400 comments 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 community.

 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 the 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 concerns, 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 economic 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 proportion 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 Themes from Combined Online, Public Open House, and Telephone Comments

Four major themes were common across all of the 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 Recommendations, Dec. 2011 39

Figure 10. Location of Online Survey Respondents by ZIP Code
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 40

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

(Note: not all meeting attendees provided ZIP code information)
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 manner and to help 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 reduce fine particle pollution for gasoline vehicles, 

diesel vehicles, industries and ships. 

As mentioned in the Evaluation Section of this report (page 27), 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 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 task force recommendations include a combination of suggested program design features, and 

statements of principle that it suggests be used to guide the future implementation of these solutions. 

As mentioned earlier in this report (see page 20), the Clean Air 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 measure. However, the task force firmly believes that the two wood smoke related solutions 

described below will not be successful without considerable public education, community outreach and 

public involvement. Local 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 encourage residents to take 

informed actions, and to overcome the skepticism many members of the public will have about new 

government regulations. Outreach and education 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 government 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 the 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 low 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 Enforcement, 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 area with the highest pollution levels (near the South L Street 

monitor 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 solve the overall 

pollution problem.

Overarching Principle Statement

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

are 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.

A. 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 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 targeted approach will be an effective way 

to reduce fine particle pollution. 

The task force discussed experiences in other communities that have significantly enhanced 

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.

The Clean Air Agency has been issuing burn bans for a number of years, so changes to the existing 

program 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 personnel 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 recommending that considerably more 

personnel be used to enforce the burn bans in the nonattainment area. 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 level 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 listed 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 believed 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 outlets 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 indicate in news accounts when 

burn bans were first 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 source 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 

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.
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 44

 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 educational 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 discourage 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 local governments.

 When implementing a registration program, consider that the goal is to enhance effectiveness 

of enforcement staff and minimize 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 inversions, 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 uncertified 

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 uncertified 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 sufficient 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 a 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 uncertified wood stove is removed, the homeowner 

should be able to replace that stove (if the owner chooses) 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 registration 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.

 Assistance should be provided for low-income households who may 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 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 the date is 

meaningful. Timing of implementation should be equitable, be publically acceptable, and allow 

time to find funding.

 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 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 Recommendations, 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 rate 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, the 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 estimate that 

have significant uncertainty. (See Appendix E.)
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 illustrates that the most immediate reductions come from nonwood 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 Recommendations 

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 Recommendations, Dec. 2011 48
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 task 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 identify 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 solutions must be adopted. These additional solutions are called 

contingency measures. The state’s Plan must identify 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 inclusion in 

the Plan:

 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 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, as a backstop for “date certain”).
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 50

 For households that have an uncertified wood 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” meant 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 stated that if the recommendations were not 

unanimous, the 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 cost 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 result 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 than 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) and produce 21 percent of the wood 

smoke fine particle pollution. Based on this information, some 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 All 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 members 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 contingency measures.
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 

Implementation 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 ensure 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 on 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 nonattainment 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 seek 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 Recommendations, 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 data. 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 densities 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, Census 2010 Block Group Data (2011); U.S. Census Bureau, 2005-10 American Community Survey 

by census tract (2010)10,11
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 residents. 

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 deliberation 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 to 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 she 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 site 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 members 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 an 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 facilitator 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 recommendations 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 the 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. However, 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 Agency 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 facilitator. 

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 force members, to outside groups about 

the work of the task force, as requested
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 56

Appendix C

Evaluation Tools

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 

WellBeing 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 will 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 Recommendations, Dec. 2011 57

Example of completed evaluation form:
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 58

Appendix D

Solutions Developed by Task 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 values 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 is 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 for 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 

2019
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 will not be double counted

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 Mouth

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 Holidays
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 Information

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 

include 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 with 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 will not 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 will not 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 insert.

 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 not 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 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 does not 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 

enforcement and other burn ban 

enforcement supplemental solutions

D 3 Take advantage of point of sale of 

homes for registration requirements

Registration by itself does not 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 

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 as 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 infrared viewer/camera for night-

 Total reduction negligible with current 

burn ban compliance
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 solutions 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 Moisture 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.

 Help 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 that 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 63

Identifier Solution Key Information

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 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 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 7 Prohibit 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 is 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 way 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-wood 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 nonattainment area. Call second stage burn 

ban when PM2.5 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 and 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 for non-cordwood 

wood waste so it does not 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 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 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 Less 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 reduction
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 65

Public Education and Outreach (some of these could be part of an enforceable solution 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 media 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 electric 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 brainstorming re: marketing/outreach
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 assumes 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 per 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 their 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 receiving 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 NOT comply 

with the burn bans, and 20% do comply. This is based on surveys in the nonattainment area on burn 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 many 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 the 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 Recommendations, Dec. 2011 68

Implementation:

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 Washington 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.

Technically Feasible/Sound:

Somewhat/Mixed = PSCAA has 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 qualify with EPA’s criteria as 

enforceable.
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 with 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 programs 

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 end 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 poverty 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 replaced 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 with
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 program.

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:

Reduction

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 endangers 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 Recommendations, 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 Recommendations, 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 (PM2.5) 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 PM2.5 also comes from industry and 

other sources. PM2.5 is very small, with a diameter of 2.5 micrometers -- approximately 1/30th the 

diameter of a human hair. This very small size allows PM2.5 to travel deeply into the lungs, even into the 

bloodstream. 

How can fine particle pollution 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) health effects: Many studies have linked fine particles to health problems 

affecting the lungs and respiratory system. The main respiratory effects include1: 

 Inflammation of lungs and airways (also systemic and heart inflammation)

 Reduced lung function (reduced lung capacity or more difficult breathing)

 Asthma trigger (worsening of asthma symptoms) 

 Lung cancer (for long-term exposure to PM2.5, especially fine particles from diesel engines2)

 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 Office of Environmental Health Hazard Assessment, Health Effects of Diesel Exhaust Fact Sheet, 

http://oehha.ca.gov/public_info/facts/dieselfacts.html . 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, Dec. 2011 73

 Altered cardiac function

 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 Pollution. 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. September 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 school children suggested an 

association between respiratory symptoms and traffic-related pollution. Kim, et al. TrafficRelated 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. Inhalation 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 Heart 
Tacoma–Pierce County Clean Air Task Force Report and Recommendations, 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 carotid 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 in 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 PM2.5 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 

PM2.5 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 PM2.5 over a 

few hours to weeks can trigger cardiovascular disease-related mortality and nonfatal events”; 

and that exposure over a few 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. Particulate 

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://circ.ahajournals.org).

 EPA strengthened its daily PM2.5 standard in 2006 based on an extensive review that highlighted 

cardiac effects nationwide. (http://www.epa.gov/ttn/naaqs/standards/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 PM2.5. 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 District 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 Recommendations, 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 PM2.5 levels. Most 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 Recommendations, 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 Washington 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, “PM2.5 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 98th percentile is found in 40CFR50, Appendix N.

6

Ogulei, David, Washington Dept of Ecology, 2010, Sources of Fine Particles in the Wapato Hills-Puyallup River 

Valley PM2.5 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 PM2.5 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://cleanairpiercecounty.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 County 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 Washington Section 70-94-473 “Emission performance standards.”

17 US EPA, Clean Air Act, Title I, Part D – “Plan Requirements for Nonattainment 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 October 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-american

25 Washington Administrative Code 173-433-100