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 Wood Heating Devices to U.S.EPA as a SIP 

revision 

Dear Mr. Krichevsky, 

The Feather River Air Quality 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 submitted as a revision to the SIP. Rule 3.17 

requires that any newly installed residential 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 submit it to the U.S. EPA as a SIP revision. 

Therefore, the District adopted Resolution 2014-02 in February 3rd, 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 District is excluding portions of Rule 

3.17 from the SIP submittal because they contain discretion or voluntary measures that 

would not be approved in a federally enforceable SIP rule. The sections to be excluded 

are sections E.8, F.2 and F.4. All portions of the Rule would still be in effect as a local 

rule, but would not be federally enforceable. 

Section E.8 defines the term “unseasoned wood” and allows the APCO discretion to 

approve other test methods outside of ASTM method D4442-92 to determine percent 

moisture. The District has never used this compliance option; therefore excluding this 

section of the Rule should not have any impact on emissions or enforcement of this 

rule. 

Section F.2 provides a compliance option yet does not list the test method to determine 

emission standards. The U.S. EPA has requested that this section be excluded from 
Submittal of FRAQMD Rule 3.17 Wood Heating Devices to U.S.EPA as a SIP revision Page 2 of 2 

the SIP submittal until such time as the District revises Rule 3.17 and can provide a list 

of approved test methods. The District staff have never implemented this compliance 

option locally and agrees with U.S. EPA’s request. 

Section F.4 states that the APCO may issue an advisory to recommend actions for the 

use of wood heating devices whenever conditions within the District are projected to 

cause an exceedance of a State or National ambient air quality standard. This is a 

voluntary program that the District has implemented since the Rule revision and is 

known locally as the “Stoplight: Check Before You Burn” program. However, this 

program is voluntary and emission 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 waiting 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 control 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