## Attachment E Comments and Responses from Public Hearing Notice (Received After August 24, 2009)E-mail comment received from Duraflame, Inc on August 21 st

Comment #1: We recommend the District abandon its voluntary no burn program, as the levels of proposed restriction are far below what is necessary to be protective of air quality. The San Joaquin Valley Air District has demonstrated that a simplified program with one threshold for no burn days is easy to communicate and an effective method to reduce emissions from wood burning on bad air days. Eliminating the voluntary program also improves the simplicity of communicating the program to the public.

Response: This recommendation is consistent with staff's original proposal and would be easier to communicate. However, the voluntary curtailment program informs the public when PM2.5 concentrations are elevated, but not to the extent that a mandatory curtailment is warranted. M any members of the public will choose not to burn as a result of this message resulting in an improvement in air quality. Messaging for the District’s Check Before You Burn program clearly differentiates between voluntary requests and mandatory requirements.

Comment #2: We do have concerns about the emissions threshold level the District has proposed for the one-stage mandatory curtailment and recommend the

level be set at the Federal 24

- hour standard for PM2.5 emissions

violations.

Response: The threshold for Option A, that is the one stage option, is 30 μg/m 3 , which is the same as San Joaquin Air Pollution Control Districts adopted rule. This is threshold is recommended to be slightly below the federal health standard, to account for forecasting uncertainties.

Comment #3: We do not support the District’s proposal to implement a contingency measure that would automatically reduce the emissions threshold for no burn days in 2015.

Response: The contingency measure is an option for the Board to consider, but is not recommended at this time. The San Joaquin Air Pollution Control District adopted a contingency measure in Rule 4901 in October 2008.

E-mail comment received from Sharon Lynes on August 22 nd

Comment #4: The new proposal is just more government regulation.

Response: See response to Comment #28 in Appendix F. The District is charged with protecting public health, in this case reducing the health risks from high levels of particulate s in the air. There are many incentive strategies and regulations already in place to reduce particulate pollution problems, including reducing pollution from cars, trucks, buses, construction equipment, industrial and commercial boilers and power plants. Because fireplaces and wood stoves contribute 54% of directly emitted particulates, the Board adopted Rule 421 in 2007 to reduce wood smoke only on those days when air quality was forecast to be poor. However, the PM2.5 levels in the county are still above the federal health standards. Staff recommends adjusting this rule as the most effective way to achieve additional reductions in ambient PM2.5 levels with the least impact.Comment #5: Many jobs and family incomes are reliant on the firewood industry.

Response: See response to Comment #197 in Appendix F. If all of the reduced sales were borne entirely by independent wood dealers that did not increase their wood prices, there would be 3 jobs lost; from the staff recommendation. Obviously, , some wood is sold in grocery stores and other larger retail outlets, therefore the actual number of jobs lost, if any, would be less. For more details see the “Socioeconomic Impact” section of the Staff report and ERG’s Socioeconomic Report in Appendix G of the Staff Report (Attachment C).

Comment #6: Diesel exhaust from trucks, buses, and autos with diesel engines has no regulations such as Smog II on gasoline engines in autos in the

Sacramento Area.

Response: See response to Comment #71 of Appendix F. Heavy duty trucks and buses have been subject to inspection for excessive smoke conducted by the California Highway Patrol weigh stations and other roadside locations since 1998. CARB has several other programs that subject heavy-duty diesel vehicles to periodic se lf inspection and idling regulations.

Other diesel vehicles are under state law to be incorporated into the Smog Check Program beginning January 2010.

Comment #7: Consider the fact that in the late fall and winter when the dew point is reached in the evening, any particulate matter in the atmosphere acts as nucleii for the dew, thus helping to clean the air nightly.

Response: See response to Comment #110 of Appendix F. Fog does remove fine particles from the air through the effects of scavenging and deposition processes. A recent study 16 suggested that fog may be relatively better at removing some organic carbon emissions from wood smoke, and less effective at removing polycyclic aromatic hydrocarbons, which are toxic compounds emitted from burning wood. Fog also may increase some types of secondary organic aerosol fine particles when soluble volatile organic compounds are converted to nonvolatile products that are released when fog evaporates. In addition, fog interactions with inorganic aerosol species have been more widely researched. Nighttime aqueous phase reactions occur during which the liquid water in fog combines with nitrogen oxide compounds to form nitric acid. The nitric acid then reacts with available ammonia in the air to form ammonium nitrate particulate aerosols. Ammonium nitrate is the largest source of secondary PM2.5. The science regarding the competing processes of PM2.5 production and removal continues to evolve 17

.

Comment #8: I would encourage the SMAQMD to divert their energy to attacking the air pollution sources that are with us the entire year, not just for 4 months in

16 "Examination of the Influence of California Regional Particulate Air Quality Study Fog Episodes on

Aerosol Formation and Remova l" by Collett, Herckes, Chang, and L ee of Colorado State University and Pandis and Fahey of Carnegie Mellon University, January 13, 2005.

17 "The ammonium nitrate particle equivalent of NOx emissions for wintertime conditions in Central

California's San Joaquin Valley" by Stockwell, Watson, Robinson, Steiner, and Sylte, Atmospheric Environment 34 (2000) 4711-4717.the late fall and winter. What is SMAQMD doing about NOx pollution and -smog in the summer in areas around Folsom and Roseville?

Response: The District has many rules which regulate sources that emit NOx and VOC. In addition, the District has committed to adopting several other control measures in the 2008 Attainment Plan for the 8-hour Ozone standard that also provide wintertime PM2.5 air quality benefits. However, as this source represents over 50% of wintertime PM2.5 emissions, this rule provides critical air quality

benefits.

E-mail comment received from Larry Pinney on August 24 th

Comment #9: Anyone with an older wood burning insert is not being offered an alternative to our investment. If you want to limit us in any way then you need to offer us something like a catalytic converter so that we don’t have to start all over again.

Response: EPA has required the new wood stoves and inserts meet the emission

standards since 1992. Devices that don’t meet these standards are at least 17 years old. Wood smoke is the single la rgest directly emitted PM2.5 emissions source and noncertified wood burning devices (pre-1992 units) are the largest

contributor to residential wood combustion emissions. For this reason, Rule 421 already prohibits wood burning in an uncertified device on both Stage 1 and Stage 2 No Burn days.

Written comment received from June Chan on August 26 th

Comment #10: I’m in support of tougher air pollution regulations and less burning of any type and an increase in the number of no burn days in Sacramento County. There is a need for tougher air quality restrictions.

Response: See response to Comment #16 of Appendix F. Thank you for your support for air quality goals.

E-mail comment received from Zina Powning on August 30 th

Comment: We heat our small house with wood. We live on a fixed income and cannot afford high PG&E heating costs. Please do not make it even harder for us to stay warm by increasing the number of days when we

can’t burn.

Response: See response to Comment #111 of Appendix F. Burning wood only provides a clear cost savings if wood is obtained without any costs associated with cutting and transporting the wood. However, some residents, like yourself, report lower fuel bills from using wood, particularly as a supplemental heat source. See the “Impact on Businesses and Public” section of this memorandum for more details. Consequently, staff recommends the smallest increase in the number of no burn days of the options considered to provide greater health protections, and to potentially avoid other costs on businesses and farmers.