# pennsylvania

DEPARTMENT OF ENVIRONMENTAL PROTECTION

SECRETARY



### January 3, 2014



### Mr. 

### Shawn M. Garvin Regional Administrator U.S. Environmental Protection Agency, Region III 1650 

### Arch Street (Mail Code: 3RAOO) 

### Philadelphia, PA 19103-2029



### Dear Mr. Garvin:

Enclosed for your approval is a revision to Pennsylvania's State Implementation Plan (SIP) pertaining to the adoption by Allegheny County Health Department (ACHD) in June 2013 

### of Outdoor Wood-Fired Boiler regulations. The revision is identified as Revision No. 71 

### to the Maintenance Plan for ACHD's internal tracking.

The ACHD is a local health agency organized under Local Health Administration Law, Act 315 

### of August 24, 1951, 

### P.L. 1304, 

### as amended, whose powers and duties include the enforcement of laws relating to public health within Allegheny County. The ACHD has an air pollution control program that has been approved by DEP in accordance with Section 12 

### ofthe Air Pollution Control Act.

I have enclosed a hard copy and a compact disc of the supplemental SIP submittal materials. The supplemental materials consist of: documentation of the public hearing and comment period, and the comment and response document. I certify that the electronic files are exact duplicates of the hard copies.

The Commonwealth followed all ofthe procedural requirements of the State's laws and constitution in conducting and completing the adoption/issuance of the SIP revision.

Thank you for your attention to this matter. Should you have any questions concerning this SIP revision, please contact Joyce E. Epps, Director of Air Quality, by e-mail at jeepps@pa.gov or by telephone at 717.787.9702. 

### You may also contact Ms. Jayme Graham, Manager, Air Quality Program, ACHD, by e-mail atjgraham@achd.net or by telephone at 412.578.8129.



### Sincerely,

E. Christopher Abruzzo Secretary

Enclosures

cc: Joyce E. Epps Jayme Graham, ACHD Diana Esher, EPA Region III

----'R"'a""c'"h·el Carson State Office Building I P.O. Box 2063 1 Harrisburg, PA 17105-2063

717.787.2814 rp Printed on Recycled Paper 

### \6() www .depweb.state.pa.us

# COUNTY OF 

# ALLEGHENY

RICH FITZGERALD COUNTY ExEC UTiV E

Ms. Jo yce Epps, Director Department of Environmental Protection Bureau of Air Quality Rache l Carson Bui l ding 400 Market Street

, P.O

. Box 8468 Harrisburg, PA 17105-8468

Dear Ms. Epps: Augus t 5

, 2013

Enclosed are a pape r copy and an exact dup l icate of this paper copv on a compute r disk in searchable pdf file format of a revision to Allegheny County ' s port io n o f the Pennsylvania State Implementation Plan for the Attainmen t and Maintenance of the N atjonal Ambient Air Qualit y Standards. Changes made to Arti

. cle XXI
, Air Pollutio

. n Control Ru l es and Regulations

, and Cotm t y Ordinance 16782 involve th e addition of new Section 2 1 04.09, " Outdoor Wood-Fired Boilers. " and rela ted new definitions at Section 21 01 .20. Tills SIP revision is being t racked as

our internal Revisio n 71.

This SIP Revision was the s ubject of a public comment period from December 21

, 2011 until January 2 4, 20 11

, with a public hearing held on January 19

, 2011. It was approved b y the Board of Health on May 2. 20 1 2. enacted by County Counci l on May 22. 2013

, approved and signed b y the Allegheny COtm1y Ch i ef Execut i ve on May 29

, 2013

, and became effective June 8

, 20 1 3

.

We req u est tha t the Pennsylvan i a Department of Env i rorm 1 ental P r otect i on approve this re v is i on and forward the paper copy and disk to the U .S

. EPA Region HI wi th a r eco mmendation for approval. 

### if yo u have any questions

, please call m e at the number below or email me at jthompson @achd.net.

cc: Kirit Dalal Stephen Hepler

E

n closu re s

# ~f_**{p~J**
James T h ompson, Manager Air Quality Program

ALLEGHE N Y COU N TY H EALTH DEPARTMENT • AIR QUA LITY PROGRAM 301 39"' STREET BUILDING #7 • PmSBURGH. PA 1 520 1

· 18 i i P H ONE (4 1 2) 578-8103 • FAX ( 41 2) 578-81 4 4

### 1 REVISION TO ALLEGHENY COUNTY’S PORTION

of the

PENNSYLVANIA STATE IMPLEMENTATION PLAN

for the

ATTAINMENT AND MAINTENANCE

of the

NATIONAL AMBIENT AIR QUALITY STANDARDS

_______________________________ (Revision Tracking No. 71)

Outdoor Wood-Fired Boilers Regulations

### 2 

## ( Rev. No. 71) Table of Contents

**A. Outdoor Wood-Fired Boilers Regulations**

**1. Summary of action**

**2. Regulation**

**B. Documentation of Public Hearing and Certificatio ns** 

**Public Hearing Notice Proof of Publication of Hearing**  **Notices to US EPA and PA DEP Certification of Hearing**  **Summary of Comments and Responses Certification of Approval and Adoption** 

### 3 A.1 Summary of Action

New Outdoor Wood-Fired Boilers Regulations - State Implementation Plan (SIP) Revision

**ACHD is incorporating by reference into Article XXI , with a limited number of health**  **enhancing revisions as summarized below, the Pennsy lvania Department of**  **Environmental Protection’s (DEP) Air Pollution Cont rol Act at 25 Pa. Code §123.14,**  **Outdoor Wood-Fired Boilers and certain related defi nitions of 25 Pa. Code §121.1,**  **Definitions, as issued in 40 Pa. Bulletin 5571, Oct ober 2, 2010.** 

**The revisions to the PA DEP regulations include an increased setback requirement,**  **additional stack height criteria, use restrictions on Air Quality Action Days, and the**  **addition of simple reporting requirements at purcha se time.** 

**The incorporation of the PA DEP regulations supplem ented with the limited changes**  **described above tailoring the regulations to the sp ecific situations encountered in**  **Allegheny County, will allow the ACHD to address th e concern of emissions of fine**  **particulate matter, PM2.5, from OWB, which should b enefit of the health of the citizens**  **of this County.**

**Finally, ACHD will submit this regulation as a revi sion to the County’s portion of the**  **Pennsylvania State Implementation Plan.**

### 4 A.2 New Regulation



# PART D - POLLUTANT EMISSION STANDARDS

The following section is added to Article XXI:

.... §2104.09 OUTDOOR WOOD-FIRED BOILERS

{Section added Month, Day, 2012, effective Month, D ay, 2012} 

### (a) Applicability. Beginning on ( insert the effective date of this regulation ), this section applies to the following:
1. A person, manufacturer, supplier or distributor who sells, offers for sale, leases or distributes an outdoor wood-fired boiler for use in Allegheny County.
2. A person who installs an outdoor wood-fired boil er in Allegheny County.

3. A person who purchases, receives, leases, owns, or uses an outdoor wood-fired boiler in Allegheny County.
(b) Exemptions

.
1. This section does not apply to a person, manufactur er, supplier or distributor who sells, offers for sale, leases or distributes in th is County a non-Phase 2 outdoor wood-fired boiler if the person, manufacturer, supp lier or distributor demonstrates the non-Phase 2 outdoor wood-fired boi ler is intended for shipment and use outside of the Commonwealth of Pennsylvania

. 2. Subsections c, d and e do not apply to a permane ntly installed outdoor woodfired boiler that was installed prior to October 2, 2010, and is transferred to a new owner as a result of a real estate transaction.
(c) Phase 2 outdoor wood-fired boilers . Except as provided under Subsection b:
1. A person may not sell, offer for sale, distribut e or install an outdoor wood-fired boiler for use in this County unless it is a Phase 2 outdoor wood-fired boiler.
2. A person may not purchase, lease or receive an o utdoor wood-fired boiler for use in this County unless it is a Phase 2 outdoor wood- fired boiler.
(d) Setback requirements for new Phase 2 outdoor wood-f ired boilers . A person may not install a new Phase 2 outdoor wood-fired boiler in this County unless the boiler is installed a minimum of 150 feet from the nearest pr operty line, except that, where a new Phase 2 outdoor wood-fired boiler replaces an exist ing non-Phase 2 unit, the minimum setback required shall be 50 feet.

### 5

(e) Stack height requirements for new Phase 2 outdoor w ood-fired boilers. A person may not install, use or operate a new Phase 2 outdo or wood-fired boiler in this County unless the boiler has a permanently attached stack. The stack must meet all of the following requirements:
1. Extend a minimum of 10 feet above the ground.
2. Extend at least two feet above the peak of the h ighest residence located within 150 feet of the outdoor wood-fired boiler.
3. Be installed according to the manufacturer's spe cifications.
(f) Allowed fuels. A person that owns, leases, uses or operates an ou tdoor wood-fired boiler in this County shall use only one or more of the fo llowing fuels:
1. Clean wood. 2. Wood pellets made from clean wood. 3. Home heating oil, natural gas or propane that: A. Complies with all applicable sulfur limits. B. Is used as a starter or supplemental fuel for du al-fired outdoor woodfired boilers. 4. Other types of fuel approved in writing by the Depa rtment upon receipt of a written request. (g) Prohibited fuels. A person who owns, leases, uses or operates an ou tdoor wood-fired boiler in this County may not burn a fuel or materi al in that outdoor wood-fired boiler other than those fuels listed under Subsection f. (h) Use R estrictions on Air Quality Action Days. No person shall operate, or allow to be operated, any new or existing outdoor wood-fired bo iler on an Air Quality Action Day in this county, unless the OWB is the primary resident ial heating source.

(i) Applicable laws and regulatory requirements. A person may not use or operate an outdoor wood-fired boiler in this County unless it complies with applicable PA Commonwealth, County and local laws and regulations adopted thereunder, including the following Article XXI sections: 1. §2101.11.c, Prohibition of Air Pollution; 2. §2101.13, Nuisances; 3. §2104.01.a, Visible Emissions – General; and 4. §2104.04.a, Odor Emissions – General.

(j) Written notice and Recordkeeping. At the execution of the commercial sale or lease in this county of a new or used Phase 2 outdoor wood-f ired boiler, the distributor, seller or lessor shall:

1. Provide the buyer or lessee with a copy of this sec tion of Article XXI; and

2. Record the make, model name/number, and date of man ufacture of the outdoor wood-fired boiler sold or leased, the name and addr ess of the buyer or lessee as well as the address of the location where the unit will be installed if different from that of the buyer or lessee, and submit this information to the Department no later than 30 days after the end of the calendar year in which th e sale or lease occurred.

### 6

REVISIONS

§2101.20 Definitions. The following definitions are added to Article XXI :

“Air Quality Action Day” means a day for which a forecast has been issued by the Pennsylvania Department of Environmental Protection, the Alleghe ny County Health Department or the Southwest Pennsylvania Air Quality Partnership indi cating that ambient concentrations of ozone, particulate matter, carbon monoxide, sulfur dioxide , or nitrogen dioxide might reach unhealthful levels or exceed the National Ambient Air Quality S tandards.

“Btu - British thermal unit” means the amount of thermal energy necessary to raise the temperature of 1 pound of pure liquid water by 1° F at the temperature at which water has its greatest density (39° F).

“Clean wood” means dry, seasoned, natural wood that contains no paint, stains or other types of coatings, and has not been treated with preservativ es or chemicals, including copper, chromium arsenate, creosote and pentachlorophenol.

“New Phase 2 outdoor wood-fired boiler” means a Phase 2 outdoor wood-fired boiler that is installed on or after October 2, 2010.

“Non-Phase 2 outdoor wood-fired boiler” means an outdoor wood-fired boiler that has not been qualified by the EPA as meeting a particulate matter emission level of 0.32 pounds per million Btu output or lower and is not labeled acco rdingly as a Phase 2 outdoor wood-fired boiler.

“Outdoor wood-fired boiler” means:

a. A fuel-burning device that: 1. Is designed to burn, or is capable of burning, clea n wood or other fuels listed under §2104.09(f) (relating to outdoor wood- fired boilers). 2. Has a rated thermal output of less than 350,000 Btu per hour. 3. The manufacturer designs or specifies for outdoor i nstallation or installation in structures not normally intended fo r habitation by humans or domestic animals, including structures like gara ges and sheds. 4. Heats building space or fluid, or both, through the distribution, typically through pipes, of a fluid heated in the device, typ ically water or a mixture of water and antifreeze. b. The fuel-burning device may also be known as an: 1. Outdoor wood-fired furnace. 2. Outdoor wood-burning appliance. 3. Outdoor hydronic heater.

“Phase 2 outdoor wood-fired boiler” means an outdoor wood-fired boiler that has been qualified by the EPA as meeting a particulate matte r emission level of 0.32 pounds per million Btu output or lower and is labeled accordingly

### 7 B.

Documentation of Public Hearing and Certifications

**Public hearing notice Proof of publication of notice of hearing**  **Transmittals of hearing notice to EPA & PA DEP**

**Certification of hearing Comment and response document**  **Certification of Approval and Adoption**

### 8 NOTICE OF PUBLIC HEARING FOR PROPOSED AMENDMENTS TO ALLEGHENY COUNTY HEALTH DEPARTMENT RULES AND REGULA TIONS

ARTICLE XXI, AIR POLLUTION CONTROL

The Allegheny County Board of Health will hold a pu blic hearing on Thursday, January 19, 2012 , at 10:00 AM , Building #7 First Floor Conference Room, Clack Health Center, 301 39th Street, Pittsburgh, PA 1520 1 to take testimony on the following proposed modifications to County Ordinance 16782 an d Allegheny County Health Department Article XXI:

The addition of Article XXI, §2104.09 , Outdoor Wood-Fired Boilers; and

Revisions to Article XXI, §2101.20, “Definitions” a s it relates to outdoor woodfired boilers.

The proposed amendments will be incorporated as a r evision to Allegheny County’s portion of the Pennsylvania State Implemen tation Plan.

Copies of the proposed amendments may be examined b eginning Wednesday, December 21, 2011, at the Allegheny County Law Library, Room 921 City-County Building, Grant Street, Pittsburgh, PA 15219, from 8:30 AM to 5:00 PM; at the Allegheny County Health Department Library, Building 7, Clack Health Center , from 8:30 AM until 3:30 PM Monday thru Friday; on the Allegheny County Health Department web site: www.achd.net ; or by calling 412-578-8120 to request a mailed pr inted copy.

Oral testimony must be pre-scheduled by calling 412 -578-8008 no less than 24 hours in advance of the public hearing. Speakers will be li mited to five minutes and should bring a written copy of their comments.

The Board will accept written testimony beginning Wednesday, December 21, 2011
, and concluding Tuesday, January 24, 2011 , by mail to: Board of Health 3333 Forbes Avenue Pittsburgh, PA 15213 By email to BOH@achd.net By Fax to 412-578-8325

### 9 No. Term.

______ _ 

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# c**'01'\! ~C'~** **!!)'** Swo t 11 (() illld**:~. bscribed**  botforc. me thi s da) ' of: December 1 5

, 20 I I



# ' "

l h&.TCby em if**~clno ti** **co ,** 

### ~ S TA TE M ENT 01' AOVERTISiiXG C O S T S '" ALC'l'Y HEALTH

· LEGJ\L- fORBI::S JIVE JJ\ !'IET N O

RK

US
3333 FORBE;S AVE**~ITTSBURGH** P A 15213

To J>G Publ i s h i ng Co mp any


### To t al

----------------------------- S90.30

l )(j**'ub li** **g** Com pa n y, 01 Co rp ora t ion

. P ublbhc r of I J itL<; bu r g h**osl -Gaz~** **tt c:.**  :1. Newl"papc:r a f (ic nernl Circu lali n n

B y 

### •

### 10 DIRECTOR

Bruce W, Oix:on, M.D.

.\1s. Joyce Epps, Director AIR QUA LI TY PROGRA M 3()1 39"' Street- Bldg

. # 7 PoiiSbUIII h

, PA 1520 1-18 91

Phone: ( 412) 5 78- 8115 Fax: ( 4 12) 578-8 1 44

December 19,2011

Department of Environmental Protection Bureau of Air Quality Rachel Carson Building 400 Market Street

, P.O

. Box 8468 Harrisbu r g, PA 1 7105-8468

Dear Ms. Epps : BO ARD Of HEALTH

P•ul M. Kln9, Esq
., Q

. E.P

. cr.- Lee HiJfri$00, M.O. VlctOt.lr

AI M

. Ahmed, P .E. Rl!'l. Rod<y V. Burgess**~** s

. 8urf<e,**.o.** Hon • .Joan CleiN)', R .N

.**J•~** M

. Flynn, Jt. IJdiO C.**Turn~** M.D

. W iOm YOU>gblood

E

nclosed 

### is a Notice of Publi c Hearing scheduled to occur on January 1 9. 20 12

, regard i ng proposed revisions to the A llegh eny County Health Department R u l e s and Regulation s. Anic l c XX I

, Air Pollution Con tr ol and Coun t y Ordinance Number 16782

, to add Sect i on 2104

. 09. "Outdoor Woodfired Boilers," and add item s related to ou td oo r wood-fired boilers to Sec ti on 2 101 .20, ''Oeflllitions

. " These additions 

## -.;u also be submined as changes to Allegheny County ' s ponion oftbe Pennsylvania State Implementation Plan.

Your comments are welcome

.

ec: Arleen S hul man Steve Hepler Enclosures

• Public Hearing No ti ce Sincerely,

# 9~-_;-i-.JL- f .r
James Thompson. Ma n ager Ai r Qua l ity Pr ogr•m

• Proposed Article X.."<I.JSIP Re• ision

### 11 DIRECTO R

Bruce W

. DiXOn, M.D.

Ms

. Diana Esber, Directo r Air Protection Di\is ion Region ID (3APOO) AIR QUALITY PROGRA M 30 1 39"' S1roet

- Bldg

. #7 Pt ttob<Jrglt PA 1 S2 0 H891

Phone : ( 41Z) 578·611 5

Fu :**412 )**  578-81 44

December 19

, 2011

U

. S

. Enviroomemal Protec1ion Agency 1650 Arch Street Philadelphi a, PA 19103-2029

Dear Ms

. Es h er: BO ARD O F HEALTH

Pllu11'1

. Kl<lg, Esq

.. Q

. E. P. CN • l H**M~mso 1**  N

. D

. lk

• Cft • .r

AIM

. Ahmed, P

. E. Rev

. Ric ky V. 8or9ess DonaldS. Bt u +.e , M.D. Hon. loon Cleo r(

, R

. N

.

Jom<>s M. Fl)m, Jr IJdia C. Turui, M.D.**.~.-Mn** Young blood

E :

nc los ed is a Noti c e of Public H ea

rin g sc h e dule-d t o occ ur o n Janu ary 1 9

, 2012, rega rd i n g pro posed revisions t o the i\Jie g beny Cou nt y H ea l th De partment Rules and Regulat io ns, An i c l

c XXI. Air Pollution Co ntrol and County Ordinance Number 167 8 2. to a dd Sect i o n 2104

. 09, "Outdoor WoodFired**Boilers,~** and add i tems related to outdoor wood-fired boilers t o Section 2 1 01.20, " Definitions

. . , These additions "ill also be submitted as changes to Allegheny County's portion of the Pennsyl"ania State Implementation Plan

.

Your comments an: wdcome

.

Enclosures

• Public Hearing Notice

# y;;**ft,Jl~ ~**  James Thompson

, Manager Air Qua l i

ty P rogram

• Proposed Article XX!JSIP**evi~ion**

### 12 Revision 71

SIP Submittal for O u tdoor Wood

- F i red Boiler R egula ti ons
Cenifi<:atjon 11f Hearjn•

Thomas Lattner deposes 3lld says that he 

### is an Air Pollution ContrQI Engineer in 

### the Air Quality Progrnm of the Allegbeny Cow11y Heahb Deprutmem:llld hereby cenifies that 

### a Public Hearing wa< held on January 19. 2012 on the proposed adoption of the addition of Section 2104.09, Outdoor Wood-Fired Boilers and a change to Section 2101.10. Defmitions. of Anicle XX I, " R ules and Regulations of the AUegheoy County Health Department for Air Poll m ion Control," 

### :and amendme nt to County Ordinance No. 1 6782; that t h is change is 

### to be 

### i n oo t p o rate d a< 

### a c h o n ge to A ll eg h e n y Cou nt y's P ortio n of th e 

### Pennsy l vania State I mplementation Plan for the Attaimnen t an d Maintenance of Nat i o n al Ambient Air Quali t y Standardl;; that the opportunity for written comments was 

### given in 

### accordance 

### with the requirements of 40 

### CFR Sl

. 102; that notice of such hearing was 

### given by publication in a newspaperofgencml circulation on December IS. 2011: and (0 

### the be$t of his knowledge. belief 3lld undc:rstoncling. such 

### proceedings wen: 

### in full compliance with all applicable 

### State and 

### Federal laws, regulatioos.lllld 

### other requiremerus

.

Thomas Lm m c r

. 

### Ai r Pollut i on Control Enginee r Air Quality Progrnm Allegheny County Health Depattmcnt

### 13 SUMMARY OF COMMENTS AND RESPONSES for the Proposed SIP Revision 71 Article XXI, Section 2104.09, Outdoor Wood-Fired Bo ilers Regulations.

January 19, 2012 Public Hearing

SUPPORT FOR OWB REGULATIONS STRONGER THAN THE STATE ’S

1. Comment : Penn Future applauds the Allegheny County Health De partment for proposing regulations on the use of Outdoor Wood-Fi red Boilers that improve upon the state’s regulations. The use of these boi lers can be a nuisance to the owner’s neighbors, can contribute to the poor air q uality in the county and can pose serious health risks to those who live around the boiler. 

### Commenter : Tiffany Hickman, Citizens for Pennsylvania’s Fut ure. Similar comments were received from Jamin Bogi with Group A gainst Smog and Pollution (GASP), Ivy Steinberg, and the Citizens of Carnegie

Response : The Health Department considers all public comme nts.

2. Comment: The State’s regulations simply aren’t protective enough for us here, considering the density of Allegheny County. 

### Commenter : Jamin Bogi, GASP. Similar comments were received from Ivy Steinberg, and the Citizens of Carnegie

Response : The Health Department considers all public comme nts.

3. Comment : The federal Clean Air Act requires states to ach ieve attainment...Allegheny County has been designated “no nattainment” of the NAAQS for fine particulate matter PM2.5...ACHD’s promulgati on and enforcement of an OWB regulation must be guided by its duties to prot ect public health and the safety and well being of the County’s citizens and the pub lic generally and to bring the County into attainment with the national ambient ai r quality standard for PM2.5. Commenter : John K. Baillee, Penn Future

Response : The Health Department considers all public comme nts.

4. Comment : ...children are more susceptible than adults to th e adverse health impacts of wood smoke...ACHD should also consider the benefit s that a stronger rule will have on improving children’s health in Allegheny Co unty. Commenter : John K. Baillee, Penn Future

Response : The Health Department considers all public comme nts.

### 14

OPPOSITION TO THE OWB REGULATION 5. Comment : Central Boiler opposes the proposed County regul ations for “outdoor wood-fired boilers” because the County Board of Hea lth appears to have adopted the PA DEP regulations in March 2011. Commenter : David McDonald, Environmental Relations, Central Boiler, Inc. A similar comment was made by the Hearth, Patio and Barbecue Association.

Response : The Board of Health did not adopt the PA DEP regu lations at its March 2011 meeting. Instead, this was the first time the issue of OWB regulations was presented to the Board. At this meeting, the ACHD A ir Program requested approval to begin work to address the issue of OWB regulatio ns with the incorporation of the PA DEP regulation as a starting point and requested permission to investigate making certain changes that might result in a more stringe nt regulation that would provide increased health protection to County residents. Th e Board granted that approval.

6. Comment : Central Boiler opposes the proposed County regul ations for “outdoor wood-fired boilers” because the PA DEP already expl icitly regulates OHHs regarding PM emissions, installation, siting and operation re quirements. Commenter : David McDonald, Environmental Relations, Central Boiler, Inc. A similar comment was made by the Hearth, Patio and Barbecue Association.

Response : The proposed ACHD OWB regulation incorporates th e majority of PA DEP regulation for OWBs as is, with some language c hanged to provide enhanced health protection for the citizens of Allegheny Cou nty.

7. Comment : Central Boiler opposes the proposed County regul ations for “outdoor wood-fired boilers” because the U.S. EPA plans to i nclude OHHs in the NSPS this

summer. Commenter : David McDonald, Environmental Relations, Central Boiler, Inc.

Response : The proposed ACHD regulation will address the is sue of OWBs in a timely fashion based on the already existing regula tory structure.

### 15

SUPPORT FOR BANNING OWBS

8. Comment : More and more municipalities in the US are banni ng Outdoor Wood Boilers. In fact, the state of Washington has bann ed them completely. It would best serve the public health of Allegheny County and wou ld be another step forward to cleaner air if we enact a ban as well. Commenter : Julie Bergo, Board Member, GASP. Similar comment was received from Perry Bergman.

Response : The ACHD regulation is consistent with the PADEP regulation and does not ban new or existing OWBs.

9. Comment : The Council believes that a complete ban on OWBs is necessary to adequately protect Allegheny County residents from the health effects of OWBs. This position is based on the harmful and intrusive natu re of wood smoke, a study finding setback and stack height requirements are insuffici ent to protect neighbors, and the population density of Allegheny County. Commenter : Clean Air Council.

Response : The ACHD regulation is consistent with the PADEP regulation and does not ban new or existing OWBs.

10. Comment : To address emissions from older units, Penn Futu re urges the ACHD to incorporate a similar ban (i.e., similar to Washing ton state) into the Allegheny County’s OWB regulation

. Commenter : John K. Baillee, Penn Future

Response : The ACHD regulation is consistent with the PADEP regulation and does not ban new or existing OWBs.

SETBACK DISTANCE NOT LONG ENOUGH 11. Comment : The County proposes to increase the setback to 1 50’, a jump from the state’s 50’. Even a 150’ setback is not enough of a setback to f ully protect the health of all County citizens. 

### Commenter : Jamin Bogi, Group Against Smog and Pollution.

Response : The setback proposed in the ACHD regulation is with in the range of setbacks established in various state and local regulations.



### 12. Comment : We also recommend a setback requirement of 200 f eet from the nearest residence not being serviced by the OWB in addition to the 150 foot setback from the nearest property line required in the proposed regulation. Much of the nuisance problems associated with outdo or wood boilers can be mitigated with aggressive setbacks to protect nearb y properties. Commenter : Tiffany Hickman and John Baillie, Citizens for P ennsylvania’s Future.

### 16

Response : The setback proposed in the ACHD regulation is with in the range of setbacks established in various state and local regulations.



### 13. Comment : If the Board decides not to implement a total ba n, the Board must at least tighten the proposed regulations to better protect County residents. For example, Allegheny County has a population density more than ten times that of New Hampshire. New Hampshire requires an OWB be at leas t 200 feet from the nearest residence (as opposed to the proposed 150 feet from a property line) and requires the stack to be at least two feet higher than the peak of any residence up to 300 feet away (as opposed to the proposed 150 feet away). Commenter : Clean Air Council.

Response : The setback proposed in the ACHD regulation is with in the range of setbacks established in various state and local regulations.



### 14. Comment : A 2006 - 2007 study by the New York Department o f Health proves that smoke from OWBs trespasses onto properties and into homes further than 1,000 feet way. This study clearly demonstrates that a setbac k of 150 feet is inadequate. Commenter : Julie Bergo, Board Member, GASP.

Response : The setback proposed in the ACHD regulation is with in the range of setbacks established in various state and local regulations. Also, the timeframe of the cited study would preclude the possibility that the OWBs in ope ration were the Phase 2 OWBs to be required by the new ACHD regulation.

15. Comment: Mirroring the state, the County proposes all new OWBs must be qualified as Phase 2, an EPA label given to units t hat theoretically have lower emission levels only reachable under optimal condit ions, nothing near what happens in reality. 

### Commenter : Jamin Bogi, Group Against Smog and Pollution.

Response : The ACHD regulations provide additional protections against sub-optimal conditions.



### 16. Comment : I have witnessed personally OWB emissions from unit s set back from a neighboring house at least 150 feet. This distance was not enough to protect me from breathing in the toxic smoke from the boiler while in the neighboring yard. 

### Commenter : Ivy Steinberg.

Response : The setback proposed in the ACHD regulation is with in the range of setbacks established in various state and local regulations.



### SETBACK DISTANCE TOO BIG 17. Comment : The proposed rules impose unnecessary lengthier setback requirements than required for EPA Phase 2 Qualified OHHs.

### 17

The proposed 150-foot setback requirement from the property line applicable to any Phase 2 OHH is unnecessary to protect neighboring p roperty owners from OHH emissions...dispersion modeling analysis supports a m ore reasonable 50 foot setback... specific modeling shows that for a boiler with an emission rate of 0.60 lb/MMBtu (note that .60 is an older EPA Phase 1 sta ndard), along with a stack height of two feet above neighboring structures and a setb ack of just 50 feet, would keep the unit safely in compliance with the new 24-hour NAAQ S for fine particulate matter (PM 2.5 

### ).

Phase 2 compliant OHHs emit even less particulate, 0.32 lb/MMBtu heat output. A 50 foot setback from the property line is more than adequate to assure NAAQS compliance. The 50-foot setback from the property line which has already been established in PA DEP Regulations is reasonable whe n installing the newest state of art products developed under the EPA Phase 2 progra m. Commenter : David McDonald, Environmental Relations, Central Boiler, Inc. A similar comment was made by the Hearth, Patio and Barbecue Association.

Response : The setback proposed in the ACHD regulation provide s additional protection to the citizens of the County. This is the same set back originally proposed by the PA DEP. ACHD feels that the additional setback is requ ired for the County’s dense population and complex terrain.



### 18. Comment : Modeling completed by HPBA to evaluate the ambie nt impacts of models that qualify under the EPA phase 1 emission target clearly shows that these models, when installed with stack heights consisten t with manufacturer’s instructions, have ambient impacts well below the revised 24 hour PM2.5 National Ambient Air Quality Standard (NAAQS), at the closest receptor t o the unit (10 meters, or roughly thirty feet) that can be modeled.

...All maximum predicted PM2.5 concentrations are in compliance with the National Ambient Air Quality Standards (NAAQS) and all are b elow the Significant Impact Levels (SIL).

Accordingly, there is no justification, from the st andpoint of protection of the NAAQS, to require outdoor wood-burning boilers that meet the emissions limit of 0.32 lbs/MMBtu heat output to be installed at a dis tance of 150 feet from the property line. Commenter : Hearth, Patio and Barbecue Association.

Response : The setback proposed in the ACHD regulation provide s additional protection to the citizens of the County. This is the same set back originally proposed by the PA DEP. ACHD feels that the additional setback is requ ired for the County’s dense population and complex terrain.

### 18

19. Comment : ...it is difficult to understand why this specific (setback) provision allows for two different installation criteria when the in stallation of a replacement appliance is allowed if installed per PA DEP Regulation but a n entirely new install requires a greater setback. Commenter : Hearth, Patio and Barbecue Association.

Response : The regulation makes it possible for the owner of an existing installed nonPhase 2 boiler to upgrade to a Phase 2 OWB even whe n the property does not permit the establishment of the 150 foot setback, thus avoidin g a situation where the regulation could have unintentionally prevented an upgrade to a less polluting OWB.



### 20. Comment : The following are setback requirements already es tablished for Phase 2 appliances in some other States and are similar to the requirements established in PA DEP Regulations: State of Maine –50 feet from a property line or 70 feet from a neighboring residence State of New Hampshire – 50 feet from a property li ne State of Massachusetts –50 feet from a property lin e and 75 feet from a neighboring residence State of Vermont –100 feet from neighboring residen ces but Vermont does not regulate chimney height requirements for OHHs State of Rhode Island – no setback requirement State of Indiana – no setback requirement NESCAUM – Model Rule does not require setbacks or c himney height Commenter : Hearth, Patio and Barbecue Association.

Response : The setback proposed in the ACHD regulation provide s additional protection to the citizens of the County. This is the same set back originally proposed by the PA DEP. ACHD feels that the additional setback is requ ired for the County’s dense population and complex terrain.



### 21. Comment : Any setback requirement applicable to Phase 2 OW Bs, beyond those already required in PA DEP Regulations, lacks a rat ional basis and is discriminatory.

• Twenty four (24) of twenty five (26) EPA Hydronic Heater Phase 2 Program (the “EPA Program”) Qualified Appliances have been shown to have lower emission rates than the federal NSPS limits for ind oor woodstoves (7.5 g/hr).

• The maximum allowable individual test run of 18 g /hr established in the EPA Program is the same g/hr cap established in the New Source Performance Standards (“NSPS”) for indoor wood stoves.

Indoor wood stoves that meet current federal NSPS m ay be installed in the Commonwealth and Allegheny County without any setbacks. Since there are no required setbacks in the Commonwealth or Allegheny County for the installation of NSPS indoor wood stoves, any setback requirement applicable to Phase 2

### 19 OWBs, beyond those already required in PA DEP Regul ations, lacks a rational basis and is discriminatory. Commenter : Hearth, Patio and Barbecue Association.

Response : The setback proposed in the ACHD regulation provide s additional protection to the citizens of the County. This is the same set back originally proposed by the PA DEP. ACHD feels that the additional setback is requ ired for the County’s dense population and complex terrain. With respect to the statement that it is discrimina tory that there are no setback requirements for NSPS indoor wood stoves, while hav ing such setback requirements for Phase 2 OWBs, the ACHD regulation is no more discri minatory than the PA DEP regulation, no matter the distance of the setback.



### 22. Comment : The proposed setback requirement would actually prevent residents of the Commonwealth and Allegheny County from insta lling lower emission Phase 2 OWBs to replace an existing higher emission indoor wood heating appliance(s). Commenter : Hearth, Patio and Barbecue Association.

Response : The regulation makes it possible for the owner of an existing installed nonPhase 2 boiler to upgrade to a Phase 2 OWB even whe n the property does not permit the establishment of the 150 foot setback, thus avoidin g a situation where the regulation could have unintentionally prevented an upgrade to a less polluting OWB. See Subsection (d), specifically, “except that, where a new PhaSe2 outdoor wood-fired boiler replaces an existing non-Phase 2 unit, the minimum setback required shall be 50 feet.”



### 23. Comment : Many OWBs are installed to replace existing indo or, non-certified wood heating appliances. Sometimes one OWB are inst alled to replace multiple noncertified wood heating appliances. Commenter : Hearth, Patio and Barbecue Association.

Response : That this is a possible situation, is duly noted.



### COUNTY MODELING 24. Comment : The ACHD’s own air dispersion “modeling” does no t support an increased setback requirement. Central Boiler had ACHD’s information reviewed... In summary, ...the ACHD modeling offers no scientific basis for increasing the 50 ft. setback requirement required in state regulations for installing OHHs in the State of Pennsylvania. More importantly , the ACHD modeling is not relevant because their modeling:

• Over-Estimated Emissions and Under-Estimated Disper sion;

• ACHD Emission Factors Used Do Not Represent EPA Pha se 2 Qualified OHHs; and

• ACHD Concentration Maps Show No Violations Commenter : David McDonald, Environmental Relations, Central Boiler, Inc. A similar comment was made by the HPBA.

### 20

Response : The ACHD modeled two existing OWB that were neither Phase 1 or Phase 2 OWB, but may have been home-made. The commenter may have performed its analysis of the ACHD modeling without this realization and t hus treated the ACHD modeling as an attempt to model a Phase 2 OWB, which it was not

.



### STACK HEIGHT REQUIREMENT

(e)2. Extend at least two feet above the peak of th e highest residence located within 150 feet of the outdoor wood-fired b oiler.

25. Comment : The study by the New York Department of Health, also proves that the height requirement for smoke stacks is irr elevant. Since OWBs burn incompletely, the smoke comes out cool, falls to th e ground and travels in a plume, not dissipating. Therefore, raising the stac k height, along with a 150 foot setback, in no way will protect neighbors. Commenter : Julie Bergo, Board Member, GASP. Similar comment made by John Baillee, Penn Future.

Response : The stack height requirement proposed in the ACHD r egulation provides additional protection to the citizens of the County

.



### 26. Comment : The proposed rules impose unnecessary taller chi mney height requirements than current PA DEP regulation which a re more than adequate. The requirement in the proposed County rule that Ph ase 2 compliant OHHs be installed with a chimney height requirement taller than what is required in PA DEP Regulation ignores how much land a resident owns an d how far away a neighboring residence
, not served by the OHH
, is located. Commenter : David McDonald, Environmental Relations, Central Boiler, Inc. A similar comment was made by the Hearth, Patio and Barbecue Association.

Response : The stack height requirement proposed in the ACHD r egulation provides additional protection to the citizens of the County and is similar to the recommendations made by the Hearth, Patio and Barbecue Association’ s Outdoor Furnace Manufacturers Caucus in its “Outdoor Wood Furnace Best Burn Pract ices.”



### 27. Comment : The (HPBA) Caucus recommends that the proposed l anguage in section (e)(2) be eliminated ... if a manufacturer specifies a chimney height taller than the minimum chimney height established in the PA DEP Re gulation (10ft.) – then existing PA DEP Regulation already governs it by re quiring “(2) Be installed according to manufacturer’s specifications.” Commenter : Hearth, Patio and Barbecue Association.

Response : The stack height requirement proposed in the ACHD r egulation provides additional protection to the citizens of the County and is similar to the recommendations made by the Hearth, Patio and Barbecue Association’ s Outdoor Furnace Manufacturers Caucus in its “Outdoor Wood Furnace Best Burn Pract ices.”

### 21

28. Comment : The chimney should not be required to extend hig her than a consumer’s own residence if no other residences are located ne ar the consumer’s property. Commenter : Hearth, Patio and Barbecue Association.

Response : The stack height requirement proposed in the ACHD r egulation provides additional protection to the citizens of the County and is similar to the recommendations made by the Hearth, Patio and Barbecue Association’ s Outdoor Furnace Manufacturers Caucus in its “Outdoor Wood Furnace Best Burn Pract ices.”



### SEASONAL RESTRICTION 29. Comment : The proposed regulation calls for prohibition on use of outdoor wood-fired boilers on Air Quality Action Days. We b elieve that in addition to the proposed ban, use should be prohibited during t he non-heating season. For neighbors who want to keep windows and doors open a nd spend time outdoors during the warmer months, this can be an especially hard time to live next to an operating OWB. It is also a time when heating a home via an OWB is less necessary. Therefore, we support a seasonal prohibi tion on operating OWBs between the dates of May 1 and September 30. Commenter : Tiffany Hickman and John Baillee, Citizens for P ennsylvania’s Future.

Response : The ACHD appreciates the concern expressed by the c omment and expects the protective features in the regulation to mitiga te the causes for that concern in the nonheating season. However, the ACHD will modify the l anguage at Subsection h such that it prohibits the use of OWB on Air Quality Action D ays during any time of year, unless the OWB is the primary source of heat for the resid ence.



### CLEAN WOOD 30. Comment : ACHD should not assume that fuel restrictions wi ll resolve the problem of pollution from OWBs. ACHD proposes to prohibit all fuels in OWBs besides clean wood, wood pellets made from clean wood, some oil, gas or propane, and other fuels approved by ACHD. However, limiting combustio n to manufacturer-approved materials does not, by itself, prevent air pollutio n that impacts neighbors...Therefore, ACHD needs a combination of effective measures (inc luding, but not limited to, fuel restrictions) to protect the public from all harmfu l emissions from OWBs, including those emissions from wood smoke

. Commenter : John Baillee, Penn Future.

Response : The ACHD expects that the regulation, as written , will provide the measures the commenter mentions as necessary to pro tect public health.

### 22

REGISTRATION REQUIREMENT FAVORED

(j) Written notice and Recordkeeping. At the execution of the commercial sale or lease in this county of a new or used Phase 2 outdo or wood-fired boiler, the distributor, seller or lessor shall: 1. Provide the buyer or lessee with a copy of this section of Article XXI; and 2. Record the make, model name/number, and date of manufacture of the outdoor wood-fired boiler sold or leased, the name and addr ess of the buyer or lessee as well as the address of the location where the unit will be installed if different from that of the buyer or lessee, and submit this i nformation to the Department no later than 30 days after the end of the calendar year in which the sale or lease occurred.



### 31. Comment : Outdoor wood-fired boilers can be challenging fo r Allegheny County Health Department personnel to locate due to their nature of operation and location on residential and commercial properties. For this reason, United States Steel Corporation suggests that a registration requiremen t be included in the regulation. Commenter : Coleen M. Davis, United States Steel Corporation

. Response : Subsection (j) provides the registration require ment that the commenter mentions.

32. Comment : Penn Future supports these (i.e., notice and rec ordkeeping requirements) aspects of the proposed rule. The proposed informat ion collection will allow ACHD to track locations and concentrations of OWBs and p romote the effective implementation of the rule and facilitate the monit oring of ambient air impacts from OWBs

.

Commenter : John K. Baillee, Penn Future

Response : The ACHD expects that the registration requireme nt will have the benefits mentioned by the commenter.

REGISTRATION REQUIREMENT NOT FAVORED 33. Comment : Notice of Sale and Recordkeeping Requirements ar e an unreasonable burden to small businesses in Allegheny County. Small businesses located in Allegheny County, and a ny others conducting business with residents of Allegheny County will be adversel y impacted under this requirement. It unreasonably interferes with their business and adds a reporting burden. Commenter : David McDonald, Environmental Relations, Central Boiler, Inc. A similar comment was made by the HPBA.

Response : The ACHD regulation includes a “Written Notice a nd Recordkeeping” requirement just as the national model rule does, b ut in fact ACHD has simplified the notice provisions by simply requiring that the sell er provide the buyer with a copy of Section 2104.09 of Article XXI, approximately three pages in length, and requires

### 23

only once a year reporting as opposed to the nation al model rule requirement to report within seven days of a sale. Therefore, the ACHD ha s significantly reduced the time that a business will have to spend on meeting this feature of the regulation.

34. Comment : There appears to be no “written notice or record keeping” for sales of other wood or coal heating appliances that can be s old and installed within the County. It appears these many of these other wood or coal heating appliances do not have to meet any PM emissions, setback or chimney h eights of any kind. These other wood or coal appliances are allowed throughout the county with no review of health impacts. Commenter : David McDonald, Environmental Relations, Central Boiler, Inc. A similar comment was made by the HPBA.

Response : The issue of how other heating appliances are re gulated is outside the scope of this regulation.

35. Comment : The (HPBA) Caucus believes that this requirement in the proposal is poorly written. It appears that the County plans to regulate small businesses located outside the County and throughout the Commonwealth with special “County” requirements. Commenter : Hearth, Patio and Barbecue Association.

Response : The regulation states that the “Written Notice a nd Recordkeeping” requirements are to be undertaken by the distributo r, seller or lessor “At the execution of the commercial sale or lease in this county of anew or used Phase 2 outdoor woodfired boiler.” It is possible that this could affec t businesses outside the County.

STRONG ENFORCEMENT NECESSARY 36. Comment : Strong enforcement of existing and these new regula tions is critical...We are asking that these proposals be as strict as pos sible. If OWBs are not banned outright, they must be vigorously monitored by the County. B ecause existing units are grandfathered in nothing in the proposed regulation s will help...other than enforcement of the malodor, opacity, and nuisance provisions...We expect the County to shut down units that repeatedly violate these regulations. 

### Commenter : Jamin Bogi, Group Against Smog and Pollution.

Response : The ACHD regularly implements effective enforcement of all Article XXI regulations, and expects to do the same with the pr oposed new OWB regulations.



### 37. Comment : The Board should also include provisions in the proposed regulations that require ACHD to take swift action in investigating and rectifying neighbor’s complaints regarding OWBs. Residents should not hav e to suffer from OWB pollution for prolonged periods as they await assis tance from government authorities. Commenter : Clean Air Council.

### 24

Response : The ACHD regularly implements effective enforcement of all Article XXI regulations, and expects to do the same with the pr oposed new OWB regulations.



### SUPPORT FOR APPLICABLE LAWS AND REGULATORY REQUIREM ENTS (i) Applicable laws and regulatory requirements. A person may not use or operate an outdoor wood-fired boiler in this County unless it complies with applicable PA Commonwealth, County and local laws and regulati ons adopted thereunder, including the following Article XXI sections: 1. §2101.11.c, Prohibition of Air Pollution; 2. §2101.13, Nuisances; 3. §2104.01.a, Visible Emissions – General; and 4. §2104.04.a, Odor Emissions – General.



### 38. Comment : Penn Future supports Section (i) “Applicable law s and regulatory requirements” of the regulation. The operation of O WBs raises compliance issues under all of these regulations, and ACHD needs all available tools to respond. Commenter : John K. Baillee, Penn Future

Response : The Health Department considers all public comme nts.

39. Comment : Other jurisdictions, including the Commonwealth of Pennsylvania, have acted to address public health and nuisance concern s from OWBs. Allegheny County must ensure that its regulations reflect, at a mini mum, the best measures adopted in other states, and be prepared to enforce these rule s . Commenter : John K. Baillee, Penn Future

Response : The Health Department believes that it has the r egulations in place necessary to protect public health.

40. Comment : ACHD must provide effective outreach and enforce ment to prevent public health and nuisances form OWBs, including: p rovide consumer information on economic and health issues involved with OWBs; trai n at least one OWB specialist; log all complaints and record follow up actions; br ing all enforcement tools to bear on OWB violations; prepare reports on sales and operat ion of OWBs in Allegheny County and evaluate the rule against its goal of pr evention of threats to public health and nuisances. Commenter : John K. Baillee, Penn Future

Response : The ACHD considers all comments with respect to improving its means to protecting public health, and expects that it ha s the necessary enforcement tools.

### 25

41. Comment : The OWB rule should require notice to buyers tha t compliance with the regulation may not shield them from all liability a nd should explicitly affirm that it is not intended to limit other remedies that may be av ailable to those who are adversely impacted by OWB emissions.

Given the widespread effects of OWBs, it is import ant that all remedies remain available to citizens impacted by this pollution af ter ACHD adopts a new OWB rule. As a general matter, compliance with a statute or r egulation “does not establish as a matter of law the exercise of due care.”

... ACHD’s proposed rule should require notice to OWB b uyers that the stack height and setback requirements set forth in the rule may not be adequate in some areas of County due to terrain that could render the operati on of the OWB a nuisance or public health hazard. Penn Future also requests that ACHD modify the rule so that it explicitly states that its requirements are minimum standards only, and that those provisions are not intended to limit other remedies that may be available to citizens who are adversely impacted by emissions from OWBs. Commenter : John K. Baillee, Penn Future

Response : The language of Subsection (i) alerts buyers to the need to comply with all applicable Commonwealth, County and local laws and regulations.

OBJECTIONS TO INCLUSION OF APPLICABLE LAWS AND REGU LATORY REQUIREMENTS 42. Comment : The proposed rule incorporates existing opacity requirements that are environmentally unnecessary and would be difficult to enforce. The proposed rules incorporates an existing County opacity requirements which the ACHD states is already applicable to OHHs – making it’s inclusion into the proposed County rule unnecessary.

The PA DEP Regulation which includes installation, siting, and operational requirements combined with the EPA Phase 2 emission limits (0.32 lbs/MMBtu heat output) will already insure that Phase 2 compliant units will not cause significant adverse air quality impacts.

In addition, it will be extremely difficult, time-c onsuming, and expensive to obtain reliable opacity readings of emissions from OHHs wh ich is unfair for owners of OHHs in the County...Even for qualified observers, co nducting a proper visible emission reading is difficult... OHH owners will not be able to determine whether they are in compliance with the proposed inclusion of opacity emission standards... Even for qualified observers, visible emissions rea dings are also highly subjective. The EPA’s own documentation for Test Method 9 ackno wledges that trained observers are likely to overestimate opacity:

Combined, the inability of OHH owners to check thei r own visible emissions, the difficult requirements for a qualified observation, the subjective nature of the reading, the proven likelihood of positive errors, and the r edundancy of opacity requirements

### 26

with emissions limitations, sighting and operations requirements all weigh against applying opacity requirements to homeowners in the County that seek to heat their homes with wood.

Commenter : David McDonald, Environmental Relations, Central Boiler, Inc. A similar comment was made by the HPBA.

Response : The specific Article XXI Sections 2101.11.c, 210 1.13, 2104.01.a and 2104.04.a, were included at new Subsection (i) to m ake them readily available to buyers of new Phase 2 OWB. ACHD believes that thos e OWB consumers unfamiliar with Article XXI would find it helpful to have the most applicable sections of Article XXI in the new OWB regulation for ready reference.

### 27 CE RTIFICATIO N of 

### AP PROV AL and ADOPT IO N

To th e b est of my kn owledge, infor ma tio n

. and belief, I th e undersigned h e r

eby certify that the

add it io n of Sect i o n 2 1 04

. 09 to, a nd th e amendment 

### ro Section 2 1 01.20 of. Art i c l e XXI
, Rul es and

R

egu l ations of t he A ll eghe n y Cou nt y H ea lth D epa 1 1me nt, A ir P o llut ion Contro l

, and Ordinance

No

. 16782 o f th e Co unt y of A ll eghe n y

. a dop ted by th e A ll egheny Cou m y Board o f Hea l t h on May 2, 20 1 2, e n ac t e d by th e Alleg h e n y County Co unci l on May 22, 2013 (O r d in ance 1 5-13- 0R), appr oved by th e Alleg h e n y Coun t y C hi ef Executive on May 29, 2013, and effec tiv e Jun e 8

, 2013, as a revision t o th e County's P o1 tion o f t h e P en

. nsy l v ania Sta t e Impl e menta t i o n P la n f o r the

Aua inm e nt a nd Mainte n a n ce of the Nationa l Am b ie nt Air Qual ity Standards

, were duly and

prope rl y e n acte d as pre scribe d by the Loc a l H e a lth Administra ti o n La w a nd the Secon d Ctiass

Co unt y Cha rt er Law
, and as suc h

, a r e fu l l y a nd legally e nfor ceab le by t h e Alleg h e n y Co un ty

Hea lt h D e par t m e nt a n d th e Coun t y of A ll eg h eny as prov i ded fo r by the wi th i n authority.

e r Assista nt So l i c i ror Allegheny County H ea lth Departme

- nt

C OMMONW EA LTH OF PENNSYLVANIA )

C O UNTY OF AL LEG HENY 

### ) s.s.

O n th eAuay

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. Parker Versol?a uy appeared b efo r e me , t he u nde r s i g n e d au t horit y, s at isf actorily

prove n t o m e t o be th e pe r so n w h ose nam e appears abo ve, and d id in m y presence execute the

ab o ve ce rtific at i on fo r t h e purp oses co ntain ed th e r ein.

WHEREFORE, I have h ereun t o 

### se t m y han d and of fic i a l sea l th e 

## P- day

### o~, 2013.

# 9-&A&~Ln./ NOTARY P UBLIC

N

OTARIAl SEAL JANET M NORKUS

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otary Pub lic PITTSBURGH CITY. ALLEGH E N

Y COU NTY My Commi ss ion EJI) Ir es May 29

. 2015