1007 Live Oak Blvd. Suite B-3 Yuba City, CA 95991 (530) 634-7659 FAX (530) 634-7660 www.fraqmd.org

Christopher D. Brown, AICP Air Pollution Control Officer

April 11, 2014

Alex Krichevsky Stationary Source Division Air Resources Board akrichev@arb.ca.gov

Re: Submittal of FRAQMD Rule 3.17 W ood Heating Devices to U.S.EPA as a SIP revision

Dear Mr. Krichevsky,

The Feather River Air Q uality Management District has prepared the electronic submittal of Rule 3.17 Wood Heating Devices to the U.S. EPA as a SIP revision. The U.S. EPA has requested that any District rule which controls emissions of directly emitted PM2.5 or it’s precursors to be subm itted as a revision to the SIP. Rule 3.17 requires that any newly installed resident ial wood heating device meet performance and emission standards.

The Rule 3.17 was adopted by the District in June, 1996, and revised in October, 2009. When the Rule revision was adopted by the Board in October, 2009, the resolution did not specifically direct the District staff to su bmit it to the U.S. EPA as a SIP revision. Therefore, the District adopted Re solution 2014-02 in February 3 rd , 2014, directing staff to send the Rule, with minor changes discussed below, as a SIP revision.

Based on prior discussion with EPA and ARB the Dis trict is excluding portions of Rule 3.17 from the SIP submittal because they cont ain discretion or voluntary measures that would not be approved in a feder ally enforceable SIP rule. The sections to be excluded are sections E.8, F.2 and F.4. All portions of the Rule would st ill be in effect as a local rule, but would not be federally enforceable.

Section E.8 defines the term “unseasoned w ood” and allows the APCO discretion to approve other test methods outside of ASTM method D 4442-92 to determine percent moisture. The District has never used this compliance option; therefore excluding this section of the Rule should not have any im pact on emissions or enforcement of this rule.

Section F.2 provides a compliance option ye t does not list the test method to determine emission standards. The U.S. EPA has request ed that this section be excluded fromSubmittal of FRAQMD Rule 3.17 Wood Heating Devi ces to U.S.EPA as a SIP revision Page 2 of 2

the SIP submittal until such time as the Distr ict revises Rule 3.17 and can provide a list of approved test methods. The District st aff have never implemented this compliance option locally and agrees with U.S. EPA’s request.

Section F.4 states that t he APCO may issue an advisory to recommend actions for the use of wood heating devices whenever condit ions within the Distric t are projected to
cause an exceedance of a Stat e or National ambient air quality standard. This is a voluntary program that the District has im plemented since the Rule revision and is known locally as the “Stoplight: Check Be fore You Burn” program. However, this program is voluntary and emi ssion reductions from this measure are not relied on for attainment purposes.

Please accept this electronic rule submittal and expedite processing the rule to the U.S. EPA as a SIP revision. The U.S. EPA is wait ing to act on the District’s Redesignation Request and Maintenance Plan for the Yuba City-Marysville PM2.5 Nonattainment Area until all rules that include cont rol of emissions which assisted the area in meeting the standard are included in the SIP.

If you have any questions please contact Ms. Sondra Spaethe, Air Quality Planner, at (530) 634-7659 ext 210.

Regards,

Christopher D. Brown, AICP FRAQMD

CDB/sls File: Chron