Attachment E 

Comments and Responses from Public Hearing Notice 

(Received After August 24, 2009) 
E-mail comment received from Duraflame, Inc on August 21st

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. Many 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/m3

, 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 22nd

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 particulates 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 self 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 study16 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 evolve17. 

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 Removal" by Collett, Herckes, Chang, and Lee 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 24th

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 largest 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 26th

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 30th

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.