EPA-450/2-89-015
Guideline Series
Guidance Document for Residential
Wood Combustion Emission Control Measures
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park NC 27711
September 1989
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This report has been reviewed by the Air Quality Management Division of the Office of Air Quality Planning
and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not
intended to constitute endorsement or recommendation for use. Copies of this report are available through
the Library Services Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, North
Carolina 27711; or, for a fee, from the National Technical Information Services, 5285 Port Royal Road,
Springfield, Virginia 22161.
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CONTENTS
Section Page
1 INTRODUCTION 1-1
1.1 Scope of This Document 1-1
1.2 Background 1-4
1.2.1 RWC Emissions: Extent of the Problem,
Causes, and Control Techniques 1-4
1.2.2 EPA's Programs for Reducing RWC Emissions . 1-9
1.3 Health Effects from RWC Emissions 1-12
1.4 Application of Emission Credits for PM-10 SIPS . . 1-15
1.4.1 PM-10 Emission Reduction Credits 1-15
1.4.2 Priority of Emission Control Measures ... 1-19
2 PUBLIC INFORMATION AND AWARENESS 2-1
2.1 Attitudes Toward Wood Heat 2-1
2.2 PA Program Goals 2-2
2.2.1 Health Risks 2-2
2.2.2 Operation and Maintenance 2-3
2.3 Communicating the PA Program Element 2-6
2.3.1 Direct Public Contact/Public Education
Medium 2-8
2.3.2 Broadcast Medium 2-11
2.3.3 Print Medium 2-11
2.4 Program Effectiveness 2-20
2.4.1 Minimal Level of Effort - Use of One
Medium Only 2-22
2.4.2 Medium Level of Effort -- Broadcast Plus
Public Contact 2-22
2.4.3 High Level of Effort -- Multimedia/Extensive
Effort 2-23
2.5 Tracking 2-24
3 IMPROVING WOOD BURNING PERFORMANCE 3-1
3.1 Introduction 3-1
3.2 Certification Program 3-2
3.2.1 Introduction 3-2
3.2.2 State Programs 3-4
3.2.3 Ban on Resale or Installation of Used
Uncertified Wood Heaters 3-6
3.3 Installation Quality Assurance 3-10
3.3.1 Introduction 3-10
3.3.2 Installer Training and Certification .... 3-11
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CONTENTS (continued)
Section
3.3.3 Inspections 3-12
3.3.4 Installation Credits 3-13
3.4 Technology Requirements 3-14
3.4.1 Introduction 3-14
3.4.2 Pellet RWC Devices 3-14
3.4.3 Phase II Certified RWC Devices 3-16
3.4.4 Retrofits 3-17
3.4.5 Accelerated Changeover Requirements .... 3-18
3.4.6 Accelerated Changeover Inducements 3-20
3.5 Fuel Quality Requirements 3-21
3.5.1 Introduction 3-21
3.5.2 Wood Moisture Content Regulations 3-22
3.5.3 Trash Burning Prohibition 3-23
3.6 Weatherization 3-24
3.7 Opacity Limits 3-25
REDUCING USE OF RWC DEVICES IN A COMMUNITY 4-1
4.1 Backup Heat or Alternative Energy Sources 4-3
4.1.1 General 4-3
4.1.2 Facilitating Availability of Alternative
Fuels 4-3
4.1.3 Economic Incentives 4-9
4.2 Limiting New RWC Devices 4-12
4.2.1 Emission Offset Requirement 4-13
4.2.2 Taxes on New RWC Devices 4-14
4.2.3 Ban on RWC Devices 4-15
4.3 Eliminate Existing RWC Devices 4-18
4.3.1 Incentives to Remove and Disable Existing
RWC Devices 4-18
4.3.2 Regulatory Prohibition Against Operation of
RWC Devices 4-20
CURTAILMENT 5-1
5.1 Curtailment Plan 5-3
5.1.1 Voluntary Versus Mandatory Programs .... 5-3
5.1.2 Affected Area 5-5
5.1.3 Public Acceptance 5-6
5.1.4 Forecasting Episodes 5-9
5.1.5 Action Points 5-10
5.1.6 Exemptions 5-11
5.1.7 Adopting the Plan 5-16
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CONTENTS (continued)
Section Page
5.2 Communication Strategy 5-17
5.2.1 No Burn Notification Procedures 5-17
5.2.2 Internal Communications 5-21
5.3 Surveillance 5-22
5.4 Enforcement 5-25
5.5 Program Effectiveness/Credits 5-29
6. REFERENCES AND SOURCE MATERIAL 6-1
6.1 List of Personal Contacts 6-1
6.2 Written References 6-1
6.3 Bibliography 6-1
Appendices
A. Techniques for Estimating RWC Emissions A-l
B. Report Sponsor, Authors, and Reviewers B-l
C. Example Ordinances C-l
D. EPA Fact Sheet on Health Effects from RWC Emissions . . D-l
E. How to Apply Estimates of Effectiveness to Determine
Total PM-10 SIP Emission Reduction Credits E-l
F. Summary Table of Program Elements F-l
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FIGURES
Figure No. Page
2-1 Some representative brochures discussing a variety of RWC
devices 2-19
5-1 Text of pre-recorded message from the Juneau Program . . 5-19
5-2 Newspaper notification in Washoe Co 5-22
5-3 Example of violation notice form used in Lewis and
Clark County 5-28
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TABLES
Table No. Page
2-1 Strengths and Weaknesses of Three Different Public
Information Media 2-7
2-2 Print Media Used in Public Awareness Programs 2-13
2-3 Three Levels for Hypothetical Public Awareness Program
Elements 2-21
3-1 Summary of Effectiveness of Program Elements Improving
Wood Burning Performance 3-7
4-1 Summary of Effectiveness of Program Elements Limiting
Population of RWC Devices 4-7
5-1 Curtailment and Complementary Program Elements From
Selected RWC Emission Control Programs 5-2
5-2 How Different Programs Determine When to Curtail Wood
Burning 5-12
5-3 Exemptions to Curtailment and Criteria for Qualification
for Exemptions 5-13
5-4 Methods of Notifying Residents of No Burn Conditions . . -5-18
5-5 Methods of Surveillance for Identifying Curtailment
Noncompliance 5-24
5-6 Penalties and Disincentives for Noncompliance 5-26
5-7 Reported Curtailment Program Effectiveness Levels .... 5-30
5-8 Recommended Features for a Voluntary Curtailment Program
Element 5-31
5-9 Recommended Features for a Mandatory Curtailment Program
Element 5-32
6-1 List of Personal Contacts 6-2
6-2 Written References 6-4
6-3 Bibliography 6-7
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SECTION 1
INTRODUCTION
1.1 SCOPE OF THIS DOCUMENT
The purpose of this document is to assist state and local officials in
developing plans for controlling emissions from residential wood combustion
(RWC) devices. Specifically, this document is designed to provide guidance to
officials in areas that are required by the U.S. Environmental Protection
Agency (EPA) to demonstrate through the State Implementation Planning (SIP)
process that they will attain the national ambient air quality standard
(NAAQS) for particulate matter of 10 micrometers in aerodynamic diameter or
less (PM-10).
None of the measures discussed in this document, except the New Source
Performance Standards, are "national measures." Some of these measures could
be adopted by state or local areas that exceed a federal or state particulate
matter standard or areas where RWC emissions are a community concern.
This introduction includes a background section (1.2) that describes the
extent of the RWC emission problem, the causes of RWC emissions, and the means
of controlling these emissions. This section also provides a brief overview
of the two regulatory mechanisms for addressing the RWC emissions problem on a
national basis: EPA's new source performance standard (NSPS) for wood heaters
and the PM-10 NAAQS. Section 1.3 briefly discusses the health effects issues
associated with RWC. Section 1.4 presents a hierarchy of effectiveness and
reliability of emission control measures.
Sections 2 through 5 describe four categories of RWC emission control
measures. The first of these four control measures, public awareness (PA), is
addressed in Section 2. A basic assumption behind PA is that RWC emissions
can be reduced if the wood-burning public knows why RWC emissions are harmful,
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is aware of the full range of benefits from reducing RWC emissions, and knows
how to reduce these emissions. (Note: This document does not focus on the
emission control technology required by the NSPS.)
Section 3 addresses control measures that have as their objective an
improvement in combustion efficiency. These measures include: (1) banning
specific types of solid fuel-burning residential heating (RWC) devices, (2)
ensuring proper installation of RWC devices, (3) upgrading fuel quality, and
(4) reducing demand for fuel use through weatherization of residences,
conservation, and other techniques.
Section 4 discusses measures that have as their objective, the reduction
in the use of RWC devices impacting the airshed. This occurs through conver-
sion to alternative fuels and by requirements to remove or limit wood heaters.
Section 5 addresses episodic curtailment -- the temporary cessation of
wood burning to avoid periods of high ambient concentrations of woodsmoke.
Each of these sections includes an estimate of the effectiveness of each
type of control measure. These estimates are provided in order that state and
local communities can use them to develop their plans to reduce RWC emissions
to a targeted level and for EPA regional staff to use in awarding emission
credits when evaluating PM-10 SIPs. These estimates are based primarily upon
the informed judgment of the authors of this report and especially the
consensus of the Technical Review Committee, which was composed of knowledge-
able authorities in the field.
Many of these estimates of effectiveness are intended to be examples of
the credits or range of credits that would be granted for a particular control
measure. A state or local agency may be able to demonstrate that a different
credit would be justified in a particular situation. This could be accom-
plished through discussion with the EPA Region prior to SIP submittal.
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With a few exceptions, each of the individual measures discussed in this
document are currently being used in several states and local areas. This
document is based, in large measure, upon scores of telephone interviews with
officials who are operating these RVC emission control programs. Although the
experiences of these local programs are referred to extensively in this
document, this document is not intended to be a survey of all state and local
RVC emission control programs. The list of those interviewed was drawn from
recommendations from EPA staff in EPA Regions where RWC emissions contribute
significantly to PM-10 nonattainment and where RWC control programs are most
developed. These interviews were supplemented by literature describing the
programs. The names of those interviewed and other literature used in this
document are cited in the references in Section 6.
In order to apply a quantitative estimate of effectiveness (or credit),
it is important to develop a good estimate of RWC emissions. Methods for
developing RWC emission estimates are presented in Appendix A along with
additional references for those interested in conducting community RWC surveys
to develop an RWC data base.
Appendix B lists the Technical Review Committee members and others who
prepared this report. Appendix C contains copies of ordinances and regula-
tions that provide the legal authority and description of various programs
discussed in this document. Appendix D is a four-page "Fact Sheet" on the
"Potential Health Effects Associated with Woodsmoke." This is a useful
summary prepared by EPA and suitable for inclusion in state and local PA
programs. Appendix E shows, by way of a hypothetical example how these
emission reduction credits can be applied in an RWC emission control program
consisting of separate program elements. Finally, Appendix F is a summary
description of all control measures and associated credits.
A final note on terminology and the scope of this document: although the
topic is residential wood combustion, often many of the programs can be aimed
broadly at all solid fuel combustion (which would include coal-fired heaters)
in residences as well as other nonresidential settings (stores, shops,
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offices, schools, etc). On the other hand, some programs pertain only to
certain types of solid fuel combustion devices while exempting others. To
avoid confusion, the words "RWC devices" will be used to address all solid
fuel emission sources generically. Fireplaces, wood stoves, wood heaters,
pellet burners, wood-fired central heaters and furnaces, and coal-fired
appliances are all specific types of RWC devices. Similarly the term "RWC
emissions" will be used to refer to PM-10 emissions from RWC devices.
The word "program" refers to a community's collective efforts to control
RWC emissions through several "control measures" or "program elements."
1.2 BACKGROUND
This section briefly discusses the extent of the RWC emissions problem,
the cause of the problem, the means of reducing these emissions, and EPA's
regulatory strategies for promoting these controls.
1.2.1 RWC Emissions: Extent of the Problem. Causes, and Control Techniques
1.2.1.1 Extent of the Problem --
Estimates of the number of RWC units in the United States vary. A 1983
survey conducted for the Consumer Product Safety Commission indicated that
there were 27 million RWC devices in use (43). More than half of these were
either the traditional masonry fireplaces or the metal zero clearance or
freestanding fireplaces. The remainder were enclosed fireplace inserts,
woodstoves, or furnaces. Counting coal-fired appliances (which usually make
up at least four percent of solid fuel heater sales) and adding the roughly
one million new RWC units sold each year, it is reasonable to estimate that by
1989 there were approximately 30 million RWC units (49).
RWC devices are one of the largest man-made sources of PM-10 and carbon
monoxide (CO) in the country. In gathering data to support the development of
national emission standards for enclosed wood heaters (i.e., primarily wood
stoves and fireplace inserts), EPA estimated that in 1985, wood heaters
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annually emitted 2.7 million tons of PM-10 and 7.4 million tons of CO. Of
special concern is the portion of PM emitted by RWC devices that consists of a
class of compounds referred to as polycyclic organic material (POM), some of
which are known carcinogens. The 1600 tons per year of POM emitted by RWC
devices accounts for the majority of POM emissions from all stationary sources
(50).
In many areas of the country with PM-10 nonattainment problems, RWC
devices account for a large fraction of the PM-10 emissions. These emissions
result in high human exposure because they are emitted near ground level in
residential areas -- unlike other traditional sources of PM-10 which often
have tall stacks, large areas for dispersion, and are located in nonresiden-
tial areas. As discussed in Section 1.3, there are serious health effects
associated with high concentrations of wood smoke from RWC emissions.
In addition to health effects from ambient (outdoor) concentrations,
emissions from RWC devices result in degradation of visibility. Maximum
visibility impairment is caused by particles of about 2.5 micrometers (/Llm) or
less in size. Eighty percent of RWC emissions are less than 2.5 |Um. RWC
devices are a source of odor complaints and they create soiling from the
deposition of particles on windows, vehicles, clothing, and buildings.
Finally, RWC emissions are a major cause of indoor air pollution problems
(51).
1.2.1.2 Causes of RWC Emissions --
Simply put, the PM-10 and CO emissions from RWC devices with enclosed
fire boxes are the result of incomplete combustion. The control of the
burning or burn time from any enclosed RWC device (i.e., wood stove), with the
exception of pellet stoves, is accomplished by restricting the amount of air
that can enter the fire box. This means of control creates an oxygen-starved
combustion situation in which CO is formed and the PM-10 and organics are
emitted as particles of incomplete combustion. A conventional wood stove --
typical of those sold before state and federal regulations were developed --
will convert to useful heat only about one half of the total potential energy
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available in the wood. The remainder is emitted through the chimney in the
form of CO, condensible organics, or ash particles.
The key to reducing PM-10 emissions is to improve combustion efficiency
by burning most of the unburoed organics. This can be accomplished in two
ways: (1) improved emission control technology for wood heaters, and (2)
improved RWC operation and maintenance by consumers. These two approaches are
discussed below.
1.2.1.3 Techniques for Reducing RWC Emissions --
Wood heater manufacturers have responded to requirements for reducing RWC
emissions by either of two approaches: catalytic controls or noncatalytic
design modifications. Both catalytic and noncatalytic approaches result in
improved combustion efficiencies and in emission reductions --as measured in
the laboratory --of between 70 and 90 percent of emissions levels charac-
teristic of conventional wood heaters. Field testing of these models,
however, has indicated more modest emission reductions. This is to be
expected as one would not expect in-field operations to realize the same
impressive reductions in emissions that are shown in the laboratory tests.
Accordingly, control strategies should account for these differences.
Following is a brief discussion of both catalytic and noncatalytic
control techniques and how consumers can reduce RWC emissions through proper
operating and maintenance. The advent of high technology models and advanced
designs has increased, not diminished, the role of operation and maintenance.
Control technology: catalytic--Introduced in the late 1970s, catalytic
technology emerged around 1980 as a means of improving combustion efficiency
and reducing creosote. It is the same technology used in automobile exhaust
catalysts. The catalyst used on the combustor is a thin molded ceramic base
coated with a slurry containing palladium or platinum that allows nearly all
the organics and other combustible products in the smoke to burn at tempera-
tures much lower than usual. Combustors are generally mounted above the
primary combustion zone in the firebox, or retrofitted in the flue, where high
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temperatures are maintained but where flame impingement does not occur. When
a combustor reaches its light-off temperature of about 450 degrees F, it
causes the PM (mostly in the form of unburned organics) and the CO to burn,
releasing heat, water vapor, and carbon dioxide. Generally catalytic wood
heaters have achieved greater emission reductions in laboratory testing than
have noncatalytic devices.
However, there are drawbacks to the use of catalytic combustors. They
are not effective on fireplaces where the amount of combustion air is high
relative to fuel burned. They deteriorate over time ,with use. They can be
inactivated, temporarily or permanently, by burning the wrong fuels (such as
coal or treated wood). Combustors can break from thermal or mechanical shock.
Repeated cycles of heating and cooling frequently result in poorly fitting
gaskets that allow untreated flue gas to bypass the gasket. Finally, it is
easy for consumers to forget to engage their catalysts by closing the bypass
damper after their fires are started. These are reasons why EPA's NSPS set an
emission limit that encourages both catalytic and noncatalytic technologies.
These are also reasons why some local RWC emission control programs that
permit only certified wood heaters also require that in order for the permits
to be renewed the units must be inspected periodically by a building inspector
or other qualified professional.
Control technology: noncatalytic approaches--The term "noncatalytic"
refers to RWC units that have secondary combustion chambers or other design
modifications designed to control emissions. In secondary combustion, the
first combustion area liberates unburned hydrocarbons because the lack of air
restricts the combustion process. The unburned hydrocarbons and CO are then
channelled to the area of secondary combustion where they are combined with a
fresh source of air to enhance combustion.
Noncatalytic approaches include designs that increase firebox tempera-
tures, increase turbulence for better mixing of air and fuel, increase the
length of time combustion gases stay in high-temperature zones, introduce
preheated secondary air, and combine these and other features.
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Two other noncatalytic designs that differ significantly from the
conventional wood heater are the high-mass heaters and pellet burners. High-
mass heaters have hundreds of pounds of ceramic firebrick around a small fire
chamber. An open, nonrestricted, hot fire heats the bricks as hot gases pass
through a convoluted duct. After the fire has died down to coals only, the
fire box is sealed and the heat is slowly released by the thermal mass for
several hours.
Pellet-fired wood heaters burn small cylindrical compressed pellets made
up of wood, wood chips, sawdust, and sometimes agricultural residue. Most
pellet-fired heaters are freestanding units or central heaters; a few are
fireplace inserts. The pellets, sold by the bag or in bulk, are manually
loaded into hoppers attached to the heaters. An average hopper may hold more
than 100 pounds of pellets. This is enough to heat a house for more than a
day. The pellets are fed to the firebox by a motorized screw auger either on
a timed basis, or as governed by a thermostat. This creates a drawback to
pellet stove operation, however, in that these units will not operate, or not
operate properly, if electric power is disconnected or if there is a power
outage. Pellet heaters in general have the lowest emissions of PM-10 and CO,
because combustion control is achieved by controlling the rate at which fuel
is fed to the unit, rather than by controlling the availability of combustion
air (51).
Improved operation and maintenance--In addition to improvements in the
design of RWC devices, consumer practices significantly affect combustion
efficiency and emission control. These practices include fuel use (e.g.,
burning only seasoned and dry firewood), stove operation (e.g., wood loading,
avoiding starving the fire of air and thereby creating slow smoldering fires),
and maintenance (e.g., replacing catalytic combustors and gaskets). The
advent of the high-technology low-emitting catalytic and noncatalytic
woodheaters has increased, rather than decreased, the importance of proper
operation and maintenance. A well-designed wood heater operated by someone
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who does not make the proper adjustments or does not maintain the unit
correctly will not achieve significant emission reductions.
The committee of industry, EPA, state government, and environmental
participants that produced the NSPS for new wood heaters required that all
wood heater operating manuals include certain operating and maintenance
instructions. This regulation also makes it a violation of federal law for
consumers to operate their wood heaters contrary to these instructions. These
provisions could be enforced at the state and local levels if the regulation
is adopted at that level. These provisions also indicate the importance of
proper consumer operation and maintenance of RWC devices. The need for an
informed wood-burning public is one reason why all state and local RWC
emission control programs include a PA element.
1.2.2 EPA's Programs for Reducing RWC Emissions
EPA's strategy for reducing RWC emissions addresses both newly manufac-
tured wood heaters and, for those areas with RWC emission problems, existing
wood-burning units as well. These programs -- the wood heater NSPS and the
PM-10 nonattainment SIP process -- are discussed below.
1.2.2.1 The Wood Heater NSPS: An Overview
Drawing upon the experience of similar programs in the States of Oregon
and Colorado, a committee composed of representatives from the EPA, state
governments, STAPPA-ALAPCO, test labs, consumer and environmental interests,
and the wood heating industry developed an NSPS requiring all new wood heaters
to be certified by EPA to meet emission limits. This regulation was promul-
gated in early 1988 (Federal Register. February 26, 1988). The final standard
was agreed to by all participants in the regulatory negotiation and all
parties agreed to support the final standard. The key features of this NSPS
are summarized below.
The standards control PM-10 emissions from new wood heaters
manufactured on or after July 1, 1988, or sold on or after July
1, 1990. A second, more stringent, emission limit will take
effect on July 1, 1990, for wood heaters manufactured on or
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after that date or sold on or after July 1, 1992. Small
manufacturers (who produce fewer than 2,000 wood heaters per
year) have an additional year to comply with the first phase of
the standards.
Open fireplaces, high mass heaters, boilers, furnaces, and
cookstoves are not covered under these standards; the regula-
tion primarily affects "airtight" woodstoves and fireplace
inserts.
The standards are being implemented under a certification
program whereby the manufacturer submits a representative wood
heater to a laboratory accredited by EPA to be tested according
to a prescribed set of conditions.
The certification is good for 5 years and may be renewed.
Model lines which have been certified by the Oregon Department
of Environmental Quality and which meet minimum burn rate
requirements may be certified by EPA (for the 1988 standard
only) without additional testing.
Separate emission limits apply to catalytic and noncatalytic
wood heaters as indicated below:
Phase I (7/1/88) Phase II (7/1/90)
Catalytic 5.5 grams per hour 4.1 grams per hour
Noncatalytic 8.5 grams per hour 7.5 grams per hour
On or after July 1, 1988, all new wood heaters affected by the
standards offered for sale will be labeled. Permanent labels
will be used by enforcement personnel to determine compliance
status. Temporary labels will be used by prospective
purchasers to make comparisons in emissions and efficiency, and
to determine the heat output of the various models.
The standards will be enforced by label and parameter inspec-
tions of completed wood heaters and by emission audit tests on
production line units.
Manufacturers will be required to conduct two types of quality
assurance programs -- one designed to ensure that components,
dimensions, and materials of production are essentially the
same as the model originally tested for certification, and
another requiring emission testing at prescribed production
intervals.
Manufacturers are required to maintain records of certification
testing data, QA program results, and production volumes.
Accredited test labs are required to maintain testing records.
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Unlike most other NSPSs, relatively little of the implementa-
tion (i.e., the certification program and enforcement) will be
delegated to the states.
1.2.2.2 The PM-10 Ambient Standard
The Clean Air Act requires that all areas of the country be in attainment
of the NAAQS, In 1971, EPA established an NAAQS for particulate matter,
measured in terms of total suspended particulates. On July 1, 1987, EPA
promulgated a new NAAQS for only the particles with aerodynamic diameters of
10 micrometers or less (PM-10). Particles of this size are respirable and of
greatest health significance (i.e., they penetrate deep into the tracheo-
bronchial and alveolar regions of the lung). Respirable particles can damage
the lungs and aggravate cardiopulmonary diseases.
The PM-10 NAAQS limits the amount of PM-10 in the air to 150 Mg/m3 when
averaged over a 24-hour period and 50 /ig/m3 when averaged over an entire year.
Only one exceedance of the 24-hour average is allowed each year for an area to
remain in attainment of the PM-10 NAAQS.
RWC devices are one of many possible source categories of PM-10. Auto
exhaust, wintertime road sanding, and industrial fugitive and point sources
are others. The PM-10 NAAQS does not directly mandate RWC controls. However,
of the 58 Group I areas (i.e., areas that have a greater than 95 percent
probability of exceeding the PM-10 standard) in the country, approximately
one-third were significantly affected by RWC emissions. Additional areas
significantly affected by RWC emissions may be identified as the PM-10 monito-
ring program matures. The PM-10 SIP development process therefore is forcing
many areas of the country to deal with the problem of RWC emissions from
existing wood heaters.
Over time, the NSPS will result in reduced emissions from RWC as older
high-emitting wood heaters are replaced by the certified low-emitting models.
However, the relatively slow rate of improvement and concerns over the long
term emission control performance of certified wood heaters requires that
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additional control measures be employed in many PM-10 areas with high RWC
emissions.
1.2.2.3 Co-controls
The RVC emission control program for PM-10 compliance has the benefit of
addressing other emissions from RWC devices. The concept of reducing other
pollutants while addressing a target pollutant (in this case PM-10) is called
"co-control." Catalytic and noncatalytic technology as well as improved
operating and maintenance reduces CO and the toxic constituents. The extent
of co-control may not be proportionate with PM-10 reduction for any specific
technique (e.g., catalytic devices are proportionately more effective for
reducing CO than are non-catalytic devices). Nevertheless, it is generally
true that a technique that reduces RWC PM-10 emissions will also reduce CO and
toxic air pollutants as well. The concept of co-controls can be used to help
persuade the public to accept local PM-10 RWC control measures.
1.3 HEALTH EFFECTS FROM RWC EMISSIONS
Research conducted in recent years has dispelled the popular notion that
wood smoke is a relatively innocuous substance. Appendix D is an EPA "Fact
Sheet" on health effects from RWC emissions. Several areas have found that if
the health effect information is communicated clearly and convincingly to
local policymakers, the press, and the general public, the RWC emission
control program becomes more acceptable. A simple but effective approach is
to first show the levels of RWC concentrations and emissions in the community
(as compared to all PM-10 sources and as compared to the NAAQS) and then to
present the health effects data -- perhaps with the assistance of a health
professional.
In the State of Washington, where the Department of Ecology and the Puget
Sound Air Pollution Control Agency have made a special effort to communicate
to the public and to state legislators the health effects from exposure to
wood smoke, the public and legislative support for a stringent set of controls
has been strong. Staff members from these two agencies have teamed with
researchers at the University of Washington to investigate the health effects
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literature. The following is a summary excerpt of part of their findings
Wood smoke is a complex mixture of substances which individually and
collectively are associated with both chronic and acute health
effects. These substances include PM-10, CO, aldehydes, nitrogen
oxides, and polycyclic organic materials (POM) specifically includ-
ing polycyclic aromatic hydrocarbons (PAH) .
PM-10. Fine particulate matter is of concern to public health
because this size particle has been shown to be readily
inspired into the lungs. The finest particles deposit more
deeply in the lung where some can remain indefinitely and cause
morphological and biochemical changes. Several studies suggest
that the declines in lung function that are associated with
episodic exposures to PM-10 occur rapidly and persist for up to
two to three weeks before recovery.
Carbon monoxide (CO) . The current outdoor standard for CO is 9
parts per million (ppm) for an 8 hour period or 35 ppm for any
given hour. CO combines with hemoglobin, thus decreasing the
oxygen carrying capacity of the blood. One physiological
response to CO is the increased incidence of angina among
persons with cardiac disease.
Aldehydes (including formaldehyde and acrolein) . Exposure to
formaldehyde at concentrations above 0.4 ppm has been as-
sociated with upper airway irritation, headaches, and other
neurophysiologic dysfunctions. Also, a federal panel concluded
that formaldehyde should be presumed to pose a carcinogenic
risk to humans. Acrolein, another aldehyde found in wood
smoke, is an even more potential eye and respiratory tract
irritant. Wood burning has been shown to be a major source of
aldehyde pollution, with emission levels comparable to those
from power plants and automobiles.
Nitrogen oxides (NO,,) . At high concentrations, NOX is known to
cause accumulation of fluid in the lung (edema) and scarring in
the lung (fibrotic changes).
NOX can have both acute and chronic effects. Studies have
shown that children from homes with gas cooking stoves
(which emit NOX) experience a greater frequency of respir-
atory illness than do children from homes with electric
stoves. However, consistent lung effects in children due
to NOX exposure have been difficult to characterize.
Polycyclic Aromatic Hydrocarbons (PAH) are complex hydrocarbons that
are formed during the combustion of many organic materials. Many
PAH compounds have been shown to be carcinogenic in animal studies.
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Studies have shown that workers with 15 years or more exposure to
coke-oven emissions have a 16-fold excess risk of developing lung
cancer compared to the general population. Wood smoke contains many
of these same PAH compounds primarily adsorbed onto the PM-10 that
is emitted. One of the PAH compounds, benzo(a)pyrene, is a proven
animal carcinogen.
Airborne wood smoke fumes, collected both inside and outside homes
using wood stoves, were analyzed for their toxic properties and were
shown to contain mutagens (substances that cause changes in the
genetic material) which produced up to 100 times as much mutagenic
activity as some well-known carcinogens. In addition, the mutagen-
icity of wood smoke increases up to ten times when smoke interacts
with other pollutants (such as NOX or ozone) in the atmosphere.
This is of special concern in urban areas where there are signifi-
cant sources and quantities of other pollutants (40). Other studies
reported that emissions from both traditional- and advanced-technol-
ogy wood stoves caused sister chromatic exchange (SCE) -- chromo-
somal defects --in mammalian cells. Even though the newer stoves
produced less PM-10 and CO, in the chromosomal tests the emissions
from these stoves were as mutagenic as emissions from a conventional
stove.
In addition to the health effects described above, there are other
possible chronic health effects due to exposure to substances
present in wood smoke. They include:
1) increased airway resistance (difficulty in breathing);
2) decreased vital capacity of the lung;
3) increased susceptibility to respiratory infection in
children;
4) increased respiratory symptoms of cough, phlegm, and
dyspnea (shortness of breath) in people with chronic
obstructive pulmonary disease; and
5) aggravation of asthma.
Although EPA's focus has been on ambient (i.e., outdoor) air
quality, wood smoke is particularly troublesome to health re-
searchers because it is a major contributor to indoor air pollution.
Indoor air pollution from both airtight and non-airtight stoves
produces measurable PM-10 and PAHs within the home. One study
showed that emissions from non-airtight stoves resulted in indoor
concentrations of up to 650 Mg/m3 of PM-10. (The new EPA standard
for PM-10 is 150 Mg/m3 for a 24-hour period.) Airtight stoves,
however, do not contribute as much to indoor air pollution.
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EPA has prepared a fact sheet that presents a concise review of the
potential health effects from wood smoke. EPA recommends that this fact
sheet, contained in Appendix D, be used for public awareness purposes in state
and local programs.
1.4 APPLICATION OF EMISSION CREDITS FOR PM-10 SIPS
Most of the remainder of this report deals with a variety of RWC emission
control measures. These measures are discussed by major categories: public
awareness, measures that improve wood burning performance, measures that
reduce the use of wood burning devices in a community, and curtailment. Each
emission control measure is described, with particular attention paid to
existing programs where a particular measure has been adopted and implemented
for the control of RWC emissions. In addition, the report describes the
factors that determine the effectiveness of each control measure in reducing
or limiting PM-10 emissions. Finally, an emission reduction credit is recog-
nized for each program element.
As discussed below, the emission credits represent the reduction in PM-10
emissions expected to result from the adoption and implementation of a par-
ticular program element. An example describing the application of these
emission reduction credits is contained in Appendix E.
1.4.1 PM-10 emission reduction credits
Credit defined. A PM-10 emission reduction credit is the measure of
reduction in PM-10 emissions from RWC devices that EPA projects would be
accomplished through adoption and implementation of one of the program ele-
ments described in this report. The emission reduction credits are applied to
the inventory of PM-10 emissions from RWC devices in a community or airshed to
determine the reduction in PM-10 emissions from individual sources, as well as
the reduction in emissions community-wide.
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The emission reduction credits are planning tools that can be used by a
state or local air quality agency in designing an RWC emission control pro-
gram. Through the use of the credits identified in this report, an agency can
investigate alternative SIP regulations and determine which combination of
program elements will reduce existing or projected PM-10 emissions from RWC
devices by an amount that is sufficient to lead to attainment and maintenance
of the NAAQS for PM-10.
These suggested credits are not designed to be applied automatically to
different types of programs or regulations that are included in a SIP.
Rather, EPA recognizes that the effectiveness of RWC control programs and
regulations can vary widely, depending on a number of factors such as the
strength of the State or local agency's implementation program, the charac-
teristics of the wood typically used for fuel in the area, and the nature of
any public education programs. The suggested credits included in this
guidance, therefore, should be viewed as the starting point in assessing the
effectiveness of RWC control programs and regulations. State and local
agencies should evaluate their programs or regulations in light of the
discussions in this guidance (such as Table 5-9). The application of credit
must be accompanied by a justification of the credit claimed for their
specific program or regulation. All justifications and ascribed credits shall
be subject to review.
Derivation of credits. The emission reduction credits identified in this
volume are derived from two sources. The first type of credit is based on
actual measurements that have been made in the field or laboratory to estimate
a change in stove emissions. Two examples of this are the changeover to Phase
II stoves and the field surveillance of curtailment program effectiveness. In
such cases, the credits were based on the measurement data. The technical
review committee interpreted the measurement data in the context of represen-
tativeness of the data and of the equipment or situation they represent when
making their final determination of credits.
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Where the information available was limited, a combination of theory,
available data, enforceability, determinations, estimates of the percentage of
homes or appliances affected, and the collective judgement of the technical
review committee was used to establish the credits. The programs where
effectiveness was estimated at < 5 percent were of this type. The discussions
found in Sections 3, 4, and 5 of this document contain more information on the
derivation of credits for specific program elements.
Application of credits. Depending on the measure being described, a PM-
10 emission reduction credit may be expressed as:
a reduction in current levels of emissions from exist-
ing RWC devices,
a reduction in growth in emissions from new RWC
devices, or
a reduction in PM-10 emissions from both current and
expected emission levels.
This distinction is due to the fact that different program elements are
applicable to different types of RWC devices.
Control measures that apply only to new RWC devices that are pur-
chased and installed in a community restrict the rate of growth in PM-10
emissions, but do not affect PM-10 emissions from existing RWC devices. The
current EPA certification program is an example of a measure that restricts
emissions from new sources but does not directly affect emissions from
existing sources.
On the other hand, control measures that apply only to existing RWC
devices reduce current levels of emissions, but do not limit emissions
growth. The requirement that retrofit control devices be installed on
existing devices, as discussed below in Section 3, would reduce existing
emissions but would not affect emissions growth. Finally, measures that are
applicable to both new and existing RWC devices, such as a firewood moisture
ordinance, reduces existing emissions while restricting emissions growth.
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Characteristics of emission reduction credits. As used in develop-
ing SIP programs for RUC emissions, several facets of PM-10 emission reduc-
tion credits should be recognized. First, these credits are EPA's best
estimate of the effectiveness of the control measures described in reducing
PM-10 emissions. These credits will be recognized by the Agency where the
program proposed by the state or local agency conforms to the program
elements described in this manual. However, these credits are not intended
to operate as limits on what a state or local authority can propose or
adopt. Instead, these credits are meant to encourage programs to go beyond
the requirements described for the individual program elements, to make
these programs more effective in controlling PM-10 emissions, and to qualify
for greater emission reduction credits than listed in this volume.
Where evidence or data are presented to support a greater (or
lesser, in extenuating circumstances) rate of PM-10 emission reduction for a
particular program element, EPA may, at its discretion, revise the credit
recognized for that program element. The final judgment on the level of
emissions reduction recognized as a credit against current or future PM-10
emissions, however, rests with the EPA regional offices. Such determina-
tions should begin prior to SIP submittal.
Program evaluation. Second, the importance of evaluation in
implementing these programs should be emphasized. Each RUC emission control
program should include specific provisions for determining the program's
effectiveness in achieving the expected emission reductions. Evaluation is
particularly important for those elements that are based on voluntary
compliance with a control program, such as voluntary curtailment programs
described in Section 5, but are also necessary to measure the effectiveness
of mandatory programs as well. This requirement could mean conducting
follow-up interviews of RWC device owners, as described in Appendix A, as
well as tracking changes in ambient levels of PM-10 in the community as
control measures are implemented.
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Enforceability. Similarly, any program calling for mandatory
controls on PM-10 emissions from RWC devices should be clearly enforceable.
In the descriptions in Sections 3 and 4, no credits are recognized for
certain program elements because these measures are generally unenforceable.
This includes, for instance, a prohibition on the resale of used, uncer-
tified RWC devices. Because existing regulatory programs ban the sale of
these devices through retail channels, the resale of used devices would have
to take place through informal transactions such as flea markets, newspaper
classified advertisements, and personal contacts. The nature and variety of
these transactions would make enforcement of a prohibition against resale
expensive in both time and effort, rendering meaningful enforcement imprac-
tical and diverting state and local agency resources from more productive
measures. However, unenforceable measures do have some value as a deter-
rent.
Credits for new measures only. In calculating the emission reduc-
tion credits that will be recognized for an RWC emission control program,
credit will only be recognized for program elements that go beyond any
existing controls that a state or local agency may be implementing. The
emission reductions achieved through the application of existing RWC control
programs is included when calculating current emission levels, as described
in Appendix A. Therefore, to recognize credit for additional reductions
based on those same control programs would result in credit being given
twice for the same program element, once in calculating current emissions
and again in projecting the effectiveness of the new PM-10 emission control
program.
1.4.2 Priority of emission control measures
A technical committee of EPA regional and headquarters personnel, as
well as representatives of state and local air quality agencies, met to
discuss a draft of this report. One of the areas of consensus that emerged
from this meeting was the need to prioritize RWC emission control measures
1-19
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according to their long-term effectiveness and the reliability of the
measures to actually reduce RWC emissions.
The technical review committee believes that state and local policy-
makers should distinguish between measures that rely on the good will of the
community and those-that can be readily enforced; and between measures that
offer a temporary solution versus those that result in a long-term reduction
in emissions. The committee concluded that, in general, the following
hierarchy of control measures exists:
Measures that result in fuel switching (e.g., from solid
fuels to natural gas) and/or overall conservation are the
most effective and the most certain to achieve the goals
of reduced RWC emissions.
Measures that result in improved combustion performance as
a result of technology (e.g., mandated upgrade from
conventional devices to EPA Phase II certified stoves) are
the next most effective and reliable category of measures.
Measures that achieve temporary emission reductions, most
notably episodic curtailments, are less desirable long-
term strategies for addressing the RWC emission problem.
Measures that rely on public awareness and upon voluntary
cooperation are less desirable than either fuel switching
or the technology-based measures. Although the committee
believes that the role of the consumer in operating and
maintaining RWC devices is critical, the committee
believes that voluntary and education-based measures are
difficult to enforce and therefore are not as reliable and
consistently effective as the "technical fixes."
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SECTION 2
PUBLIC INFORMATION AND AWARENESS
The success of any RWC emission control program depends largely on an
effective public awareness (PA) program element. The PA program element
affects the degree of public acceptance of all other program elements. A PA
program element serves two essential purposes: (1) it acquaints citizens with
details of the RWC control regulation (or ordinance), their responsibilities
under the ordinance, and the justification for the ordinance while (2)
providing persuasion and reinforcement of the issues and principles behind the
ordinance. Effective compliance with RWC emission control requirements is
possible only through an informed and supportive public.
This section (1) points out the importance of tailoring a PA program
element to the community's values and attitudes, (2) the goals of a PA program
element, (3) how to communicate the messages, (4) a description of three
levels of PA program elements, and (5) tracking the effectiveness of PA
program elements.
2.1 ATTITUDES TOWARD WOOD HEAT
Variations in PA program elements reflect differences in community
attitudes and values. These, in turn, have a direct bearing on the way a
specific PA program element addresses its goals. For example, there are areas
where wood heat is a mainstay of rural heating habits and is perceived as a
"constitutional right". The issue of the individual's right to burn has
implications for how a PA program should approach its message for that area.
Obviously, the PA program element would be more effective at overcoming
entrenched resistance to regulation by adopting a stance that emphasizes the
benefits of more efficient and cleaner burning RWC devices rather than threats
of sanctions for failure to attain the standard.
2-1
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Another example of public attitudes is found primarily in winter recrea-
tional areas such as the ski resort towns of Colorado. Unlike the largely
rural, wood-burning population in parts of Washington and Montana, residents
in resort towns must contend with seasonal fluctuations of tourists for whom
wood-burning stoves and fireplaces are a fundamental part of an expensive
vacation amenities package. The guests have little vested interest in the
long-term effects of RUG emission problems in the community as a whole.
In summary, policymakers must take into account community attitudes and
values in developing the overall RUC emission control plan and specifically
the PA program element. PA program elements must also be targeted to dif-
ferent "publics." In addition to the general wood-burning public, depending
on the mix of other program elements, a PA program element may target real
estate agents, woodstove dealers, or home builders.
2.2 PA PROGRAM GOALS
The general goals of the PA program elements currently in place are
similar: (1) to communicate the potential health risk (as well as threats to
visibility and tourism) associated with wood smoke so that the community will
support other program elements and (2) to promote better wood-burning prac-
tices or selection of alternative heating systems. (Few areas rely on PA as a
stand-alone program element to achieve PM-10 attainment.) Although these
basic goals are shared by most PM-10 programs, the particular approach that
the PA program element takes to promote those goals can be quite varied.
2.2.1 Health Risks
A particularly effective approach to promoting RWC emissions control is
for a PA program element to stress the health risks from wood smoke.
Of the areas surveyed, the Puget Sound PA program element has taken one
of the most aggressive positions regarding PM-10 health effects. Working with
2-2
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a well-informed public information staff, the news media, and the medical
community, the PA program element has focused on air toxics from wood smoke.
This program element makes its case in three ways.
An ongoing public information effort has focused on drawing a
parallel between wood smoke and cigarette smoke - - both in
terms of associative respiratory problems and social respon-
sibility. Wood Heat, Wood Smoke and You (53) discusses the
major fumes found in wood smoke and their health effects. The
pamphlet even states explicitly that "many of these compounds
are also found in cigarette smoke, a known cause of lung cancer
and respiratory and cardiac diseases."
Individually and collectively, physicians are speaking out
against the effects of wood smoke. The PA program element has
publicized anecdotal links between bad air quality related to
wood smoke and increased incidence of pulmonary disease.
The program element makes the health effects more immediate and
personal by showing that wood smoke health risks begin in the
home. This approach dispels the misconception that wood smoke
is only a problem where it is visible. This approach is a
persuasive rebuttal to the belief that wood smoke, as long as
it is outside the home, affects only those who are breathing it
out there and cannot harm the people indoors. Their publica-
tion, Wood Heat, (45) provides health and safety information
about the effects of breathing indoor wood smoke.
2.2.2 Operation and Maintenance
Persuading owners of RWC devices to change the way they operate their
stoves is an effective means to control PM-10 emission levels. As part of
that effort, PA program elements educate the public about better burning
practices, and convince owners of RWC devices to abandon poor wood-burning
habits. The PA program element must take into account the prevalent burning
patterns and practices for a given area in order to know how to target those
habits that are unacceptable. The use of a survey, as described in Appendix
A, can provide this information. Such a survey is also useful in selecting
and developing program elements to mandate improved wood-burning performance
(see Section 3).
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2.2.2.1 Heating Fuels and Practices --
Most PA program elements try to educate the public first about which fuel
sources are acceptable and which provide the highest heat efficiency output.
For example, Vashoe County has a pamphlet that discusses fuel choice, fire
preparation and maintenance, and firewood characteristics of the area.
Most RVC emission control programs have a fuel source component that
stipulates which fuel sources are allowed to be burned in RWC devices (e.g.,
Washington's regulation even requires wood to be well seasoned [no more than
20% moisture content]). These ordinances rely on PA efforts to help the
public make informed choices about their fuel sources. Also, by pointing out
the harmful by-products released when nonapproved fuel sources (e.g., garbage,
treate'd wood) are burned in RWC devices, the PA program element reinforces the
health issues associated with wood smoke.
An effective PA program element links heating practices with selection of
heating fuel. It is a natural alliance since the quality and efficiency of
the wood being burned affect how it is burned. For example, hardwoods are
denser than softwoods and release more energy per pound of wood when burned.
Therefore, a RWC device needs fewer pieces of hardwood to heat an area than if
it were burning softwoods.
Education about heating practices focuses on optimum burning times and
how to burn properly. The first issue is straightforward: wood burners are
told not to burn overnight, while they are away, or anytime the fire is left
unattended. (Overnight burns are usually accomplished by very restricted air
supply settings which result in poor combustion and high emissions.)
Unfortunately, the two most common burn periods -- early morning and
early evening -- frequently coincide with the time of day when atmospheric
conditions are ideal for inversion and air stagnation. This coincidence is
almost unavoidable, since the two burn periods reflect the activity patterns
of most households; i.e., warming the house after a. cold night and again when
the household members arrive home in the evening.
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Knowing how to burn properly requires a basic understanding of how a wood
stove works. The NSPS requires explicit information in owner's manuals
regarding the operation of the specific appliance in order to achieve low
emissions. Brochures that address proper burning techniques emphasize the
importance of burning small, hot fires. PM-10 opacity limits usually accom-
modate this emphasis by allowing for a brief period when the opacity is higher
as wood burners build the initial hot fire.
Proper burning also involves careful monitoring of the air/fuel mix in a
stove. Turning the damper too far down or allowing fires to smolder from a
lack of air reduces heating efficiency and causes the worst wood smoke
pollution. An effective PA program element explains the simple "physics" of
how wood stove operators can ensure a proper air/fuel mix, and reminds them
that different stove types -- especially catalytic stoves -- are designed to
burn most effectively when dampered down. Many brochures go on to show how
poor burning is one of the easiest practices to monitor simply by observing
the amount of smoke exiting the chimney and adjusting the air/fuel mix accord-
ingly. Pointing out that smoldering fires greatly increase creosote build-up
in chimneys serves to reinforce the safety, health, and economic issues of
wood smoke.
2.2.2.2 Stove Types --
As reported earlier, the State of Washington equates the selection of an
RWC device with the broader issue of lifestyle. Although most of the
brochures collected as part of the description of PA program elements do not
address RWC device selection, the publication Wood Stoves, Wood Smoke and You
(53) discusses catalytic versus noncatalytic stoves and pellet stoves. Wood
Heat (45) treats wood stove material, types, and overall relative efficiencies
at some length. Most of the PA material allows prospective wood stove buyers
to draw their own conclusions about which stove is most appropriate for their
lifestyle, and how that stove choice may affect the degree of compliance with
the applicable PM-10 program.
2-5
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Overall, PA efforts could be more persuasive at helping buyers choose an
efficient RWC device by recommending that they consider only certified units
or pellet stoves. EPA's Buying an EPA-Certified Woodstove (52) is another
useful handout addressing woodstove selection to include in any PA program
element.
2.3 COMMUNICATING THE PA PROGRAM ELEMENT
There are three categories of media for conducting public information/PA
efforts: print (primarily newspapers and brochures), broadcast (TV and
radio), and public contact/public education (education classes and public
hearings). The most effective PA program element uses a combination of these
three media which, when coordinated, forms a comprehensive and potent means of
ensuring the best chance for meeting PA goals. Table 2-1 gives the relative
strengths and weaknesses of each medium.
One exception to the multimedia approach is found in Okanogan County,
Washington, which relied exclusively on town meetings and public hearings.
The decision to present elements of the PM-10 ordinance draft only through
public meetings was based on the controversy such legislation was anticipated
to generate. Because of the area's antiregulatory bias, county officials
decided this approach would help the legislative process appear to be less
arbitrary by presenting the ordinance as a democratic process. This approach
was not wholly successful at reducing tensions. B. Banner reported a volatile
and sometimes violent public hearing episode during one of the ordinance's
several revisions (1).
Like Okanogan County, Steamboat Springs (Routt County), Colorado, has not
developed any printed material, but has relied primarily on public contact to
publicize ordinance-related information. The rationale behind their approach
is the belief that most ski tourists, the predominant users of wood stoves and
fireplaces, are unlikely to read brochures.
2-6
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The three types of PA media differ in their degree of impact, from
"passive" (broadcast) to proactive (public contact/public education). Of the
areas surveyed, Washington State has one of the most comprehensive PA program
elements, especially in the Seattle/Puget Sound corridor. As described above
in the discussion of PM-10 health effects, Washington enlisted the help of the
news media to promote strong public acceptance of the state's PM-10 ordinance.
No known negative news stories, features, or editorials have been written
about the ordinance. The widespread media support is attributed to two
factors: (1) a strong initial effort to garner press support by holding one-
day workshops and press conferences that included articulate health experts to
discuss PM-10 health risks, and (2) an ongoing public information effort that
focuses on the air toxics aspects of wood smoke. Rather than attacking PM-10
problems initially as a purely environmental compliance problem, Washington
has successfully emphasized the health risks of wood smoke as an issue that
the news media could then present more objectively to a wider audience.
The following is a discussion of the three media -- direct public con-
tact, broadcast (or electronic), and print.
2.3.1 Direct Public Contact/Public Education Medium
2.3.1.1 Seminars and Workshops --
Washington's PA program element also is an example of an active public
education program. Coordinating classes with the Washington Energy Extension
office, the state employs wood smoke specialists to conduct seminars and
workshops on different aspects of wood heating. Through class curricula
developed by Washington's Department of Ecology (DOE), the major message of
the workshops is for each class participant to reconsider, after hearing the
facts about RWC, the practicality of buying or continuing to use an RWC
device. The degree of receptivity to the ideas presented in the seminars is
gauged by having class participants evaluate the course. These evaluations
provide the only solid data on the effectiveness of this particular type of PA
program element. M. Nelson reported that some of the class indicated they had
2-8
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decided not to buy an RWC device based on the information presented in the
seminars (20).
2.3.1.2 Community Group Programs --
The power of community group programs, as in Klamath County (see below),
should not be underestimated. In Washington State, residents formed a non-
profit organization, known as Citizens Against Woodstove Fumes (CAWF), that
played a major role in the state's 1987 RWC control legislation. CAWF
publishes a newsletter, and has an advisory board comprised of an environmen-
tally diverse background of professionals (33).
Officials with Washington's PA program element believe that getting the
public to decide against buying their first wood stove has the greatest
potential to contribute to reduced PM-10 emissions.
Public education similar to the seminar workshop format used in
Washington can be made to address specific issues (sizing a wood stove,
looking at new technology stoves) or address broad concerns (discussing a
proposed PM-10 ordinance, wood heat vs. other heating sources). Yet each
approach has the same limitations that make determining the ultimate effec-
tiveness and verifiable value of a PA program element extremely difficult.
Namely, there is no way of determining, over any meaningful period of time, to
what extent improved, long-term wood heating habits can be attributed to the
knowledge gained through public education.
2.3.1.3 Stove Fairs --
Another approach to public education has been community-sponsored stove
fairs that provide a forum for government and the private sector to educate
the public on new RWC technologies (e.g., catalytic, certified, and pellet
stoves). In Colorado, the towns of Crested Butte and Telluride organized a
trade show where retailers of RWC devices could present and discuss their
latest product lines. The advantage to this approach is that it allows
private businesses to be involved in the PA program element and promotes a
2-9
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better understanding between the local regulatory agency and the industry that
may perceive itself to be threatened by PM-10 legislation.
2.3.1.4 Speakers Bureaus -
Klamath County, Oregon, has an extensive PA program element that uses a
speaker's bureau approach. The Klamath County Health Board-has developed a
list of organizations that would be likely audiences for public speaking
forums on RWC issues. The Board has also established an industrial education
program that targets employers with printed material and lectures. The Board
then uses the roster of employees of the different industries as a base for
neighborhood meetings.
The neighborhood meeting approach involves informal, person-to-person
information sessions in private homes to discuss and present material on all
topics of wood heating. These meetings are held in the neighborhoods in areas
that experience the poorest air quality conditions, and are scheduled to avoid
conflicts with popular television programs.
2.3.1.5 Public School Programs --
Klamath County has two RWC PA program elements that will begin in the
public schools by August 1989. The first is the "compliance volunteers
program," which presents, through student-oriented projects, several wood-
heating issues (fire prevention, pollution, health, wood seasoning and burn-
ing, and the PM-10 compliance program). T-shirts displaying related messages
and newspapers that the children write and design themselves are also part of
that program element.
The second school-related program will be the "Breath of Life" fair that
combines the ideas of an RWC device trade show with public information about
wood heating. The health board plans to make the program a collaborative
effort of school administrators, health board staff, stove retailers, and
local civic groups. The key element to the "Breath of Life" fair is its
emphasis on community involvement. Klamath County's ambitious and comprehen-
sive slate of PA program elements is exemplary in its breadth of scope for
2-10
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long-range planning and diversified resources for achieving PA program element
goals.
2.3.2 Broadcast Medium
The broadcast medium (TV and radio) is the second most common vehicle for
disseminating public information about PM-10 issues. Every area surveyed
reported the use of TV and radio "spots" to various degrees of sophistication.
2.3.2.1 Radio-TV Soots --
As it demonstrated with its extensive public contact programs, Washington
has invested much of its PA program element in using radio and television. In
addition to the normal spots run as radio and TV public service announcements
(PSAs), the state produced a public access television program as an educa-
tional tool. Similarly, the Butte-Silver Bow, Montana Health Department
produced a radio talk show to address topics relating to wood heating and the
local PM-10 ordinance.
2.3.2.2 Telephone Hotlines --
Although not a broadcast medium in the technical sense, the telephone is
another type of electronic media used to inform the public of different
aspects of an area's PM-10 program. The telephone, through the use of "hot
lines," becomes a de facto PA medium by coordinating public information with
curtailment notices (see Section 5 for a detailed discussion of telephone hot
lines and their use during curtailment episodes). By including relevant
information about wood smoke/heating in the recorded messages along with
notices of curtailment, regulatory agencies have reinforced the connection
between poor wood-burning practices and their immediate consequences (i.e.,
poor air quality that leads to curtailment).
2.3.3 Print Medium
Of the three ways the different RWC emission control programs promote
public information, the print medium has been the most popular, with few
2-11
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exceptions. Largely because of the many possibilities for distribution, the
printed message is the linchpin of almost all PA program elements. Its two
great advantages -- diversity and specialization -- have been fully exploited
by many of the areas surveyed. Whether through the most common forms of
publications (newspapers and brochures) or through more novel approaches
(posters, restaurant placemats, utility bill inserts), the print medium has
the greatest potential to reach the broadest yet specific target audience.
Table 2-2 lists all the printed material received from the 30 different
agencies we interviewed.
When compared to the costs of public speaking efforts, printed informa-
tion is very economical, making the production and distribution of highly
focused messages a powerful tool. For example, in Pitkin County, cards
alerting tourists to Aspen's wood smoke problems have been printed and are
placed in special racks in the condominiums and restaurants most frequented by
tourists. Public awareness of how Aspen's odd/even burn day system works is
especially crucial in a transient wood-burning population, and information
cards posted in hotel rooms or distributed at the registration desk are an
ideal way of informing hotel clientele.
2.3.3.1 Newspapers --
Publicizing wood-heating information in the newspapers is effective
largely because newspapers usually enjoy a wide circulation and are highly
visible. The fluid nature of newspaper layout allows for strategically placed
items of information -- from front page forecasts of the day's air quality or
the notification of that day's curtailment episode, to detailed articles or
regular columns scattered throughout the paper that discuss selected wood-
heating topics. Daily (and even weekly) newspapers that carry some form of
PM-10-related information serve as a regular reminder of the existence of a
community's PA goals and efforts towards meeting those goals. Over time, this
awareness can become a conscious part of a newspaper's readership.
2-12
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TABLE 2-2 PRINT MEDIA USED IN PUBLIC AWARENESS PROGRAMS
Area
Title of Publication
Topics Discussed
California
(1) Residential Woodstoves
and Fireplaces
Health risks
Stove sizing
Better heating practices
Curtailment responsibilities
EPA Wood stove regulations
(2) Wood Heating and
Air Pollution
Fuel choice
Firewood preparation
Better heating practices
Colorado
Aspen
Idaho
(1) Tips on How to Burn
(2) A Burning Issue
(3) Welcome to Aspen
(4) Notice to Aspen Property Owners
Let's Clear the Air!
Better heating practices
Temperature inversion signs
Temperature inversion signs
Wood smoke pollution
Comparison of pollution levels
from wood heat vs. oil heat
Cost of heating with wood
Better heating practices
Tourists awareness of tempera-
ture inversions
Odd/even burn days system
responsibilities
PM10 regulations
Stove upgrade program
Curtailment responsibilties
Better heating practices
(Continued)
2-13
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TABLE 2-2 (CONTINUED)
Area
Title of Publication
Topics Discussed
Montana
Missoula
Lewis & Clark
(1) Heating With Wood
(2) Air Pollution in Helena
(3) Good Neighbors Under
One Roof
(4) How to Tell if You Are Burning
Hot, Smokeless Fires
Sizing a wood stove
Better heating practices
Health risks
Sizing a wood stove
Better heating practices
Proper wood cutting and
storing
How to use a stove thermometer to
monitor wood stove temperatures
(5) Please.. for a Healthy Helena
(Designed to slip over doorknobs)
(6) Air Pollution Affects Our
Health
(7) Everything Has Its Price. Even
Wood
(8) Turn Up the Gas!
(9) It's Time for the Change to
Natural Gas
Better heating practices
Health risks
Curtailment responsibilities
Provides a worksheet to estimate
total cost of wood heat vs. gas heat
Benefits of gas heating and the
Montana Power Co.'s rebate
program
Benefits of gas heating and the
Montana Power Co.'s rebate
program
Butte-Silver Bow
(10) Wood Heat
Health risks
State PM10 regulations
Advantages and disadvantages of
wood heat
Relative pollution emissions and
how to reduce them
Types of wood stoves
Better heating practices
(Continued)
2-14
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TABLE 2-2 (CONTINUED)
Area
Title of Publication
Topics Discussed
Oregon
(1) Certified Wood Staves
(2) Sizing Wood Stoves
(3) Catalytic Wood Stoves
(4) The Monitor
(5) Reduce Pollution
(6) Burn Wood Better
Consumer's guide to selecting
Oregon-certified wood stoves
How to select appropriate wood
stoves
Consumer's guide to selecting and
operating catalytic wood stoves
Curtailment responsibilities
Health risks
Better heating practices
Proper wood storage habits
Better heating practices
Sizing wood stoves
Comparison of heating values of
different types of wood
Washington
(Energy Extension
Service)
(1) Wood Heat, Wood Smoke and You
(2) Wood Heating and Air Pollution
(3) Focus on Washington's Wood Stove
Regulation
(4) Using Wood Heat: Advantages and
Disadvantages
(5) Adding a Catalytic Combustor to an
Existing Woodstove
Health risks
State PM10 regulations
Advantages and disadvantages of
wood heat
Relative pollution emissions and how
to reduce them
Stove types
Better heating practices
Fuel choice
Firewood preparation
Better heating practices
State PM10 regulations
Health risks
Costs of heating with wood vs. other
sources of heat
Advantages and disadvantages of
wood heat
Consumer's guide to buying and
using a catalyst
(Continued)
2-15
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TABLE 2-2 (CONTINUED)
Area
Title of Publication
Topics Discussed
Washington
(Energy Extension
Service)
Puget Sound Air
Pollution Control
Authority
(6) Guide to Sizing Wood Stoves
(7) Indoor Air PollutantsCombustion
Products
(8) The Town ofFirecrest: Washington's
Model Clean Air Community
(9) Life, Health and Woodsmoke
(10) Wood Smoke Facts
(11) Health effects of wood smoke: A
summary statement
(12) CAWF Newsletter
Selecting appropriate size wood
stove
Health risks
Health and safety risks
Curtailment responsibilities
Better heating practices
Better heating practices
Health, environmental, and safety
risks
Relative costs of heating with
wood
State's PM10 regulations
Health risks
Health risks
Health and environmental risks
State's PM10 regulations
Nevada
Washoe County
(1) Green, Yellow, Red
(2) Burning Issues
(3) Wood Stove Appliances
(4) A Woodburner's Guide
Curtailment responsibilities
Temperature inversions
Fuel selection and storage
Better heating practices
Comparison of heating values of
different types of wood
Answers common questions about
wood stoves and real estate trans-
actions
Selecting appropriate size wood
stove
Installation and maintenance
Better heating practices
Proper wood storage habits
(Continued)
2-16
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TABLE 2-2 (CONTINUED)
Area
Tide of Publication
Topics Discussed
Nevada
Washoe County
(5) New Rules for Buying and SellingWood
Stoves
Consumer's guide to buying wood
stoves
Curtailment responsibilities
U.S. Department of
Energy
(1) Buying a Wood-Burning Appliance
(2) Wood Fuel
(3) Operating a Wood Burning Appliance
Consumer's guide to selecting
different types of solid fuel devices
Firewood preparation, storage, and
relative heating values
Better heating practices
Proper chimney maintenance
Environmental and safety risks
U.S. Environmental Buying an EPA-CertifiedWoodstove
Protection Agency
EPA's wood stove regulations
Sizing and selecting the appropriate
wood stove
2-17
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2.3.3.2 Brochures --
Brochures are the most common type of printed medium community agencies
use to publicize RWC emission control information. Figure 2-1 shows examples
of the variety of brochures available to owners of RWC devices. Because of
mutually acceptable goals and methods for reducing PM-10 emissions from wood
smoke, the basic information found in one state's pamphlet or brochure is
often used by another community to educate its public. Some areas such as
Washington State have produced numerous brochures and fact sheets of relevant
information that are suitable for reprinting by smaller municipalities with
limited budgets. As an alternative to using PA material developed by an in-
house staff or relying on previously published material, Boise, Idaho, worked
with an ad agency to produce its brochures about air pollution in Boise.
Brochures are especially useful since they can treat any single topic in
as much detail as is necessary. Oregon's Department of Environmental Quality
has a series of brochures dealing with such issues as catalytic wood stoves,
certified wood stoves, and sizing wood stoves (46, 47, and 48). The U.S. EPA
has an excellent brochure, Buying an EPA-Certified Wood Stove, that lays out
specific guidelines on how to estimate the appropriate wood stove according to
particular geographical and household requirements (52). In contrast to the
specialized approach, Washington's Wood Heat, Wood Smoke and You (53) and
Montana's Wood Heat (45) are quite comprehensive, discussing different facets
of wood heating.
The value of any brochure, regardless of how well designed and written it
is, depends on getting it into the hands of the wood-burning public. Some
areas distribute their material through mass mailings (in addition to its own
mass mailing, the Washington Energy Extension office provides brochures to
organizations that prepare their own mailings). Also, every agency inter-
viewed that has some form of printed material makes the pamphlet/brochure
available on request. Several communities reported that they have a distribu-
tion system that includes brochures along with monthly utility bills. The
Montana Power Company also includes in its monthly gas bills a brochure about
the rebate program the gas company offers for switching from wood to gas heat.
2-18
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Figure 2-1. Some representative brochures discussing a variety of RWC devices.
2-19
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Perhaps the most potent way of distributing PA material is to mail it
with notices of ordinance violations. This approach has the advantage of
reaching a select segment of the public that could benefit by appropriate
educational material. Receiving wood smoke information along with an official
citation: (1) reinforces the connection between poor wood-heating practices/
inferior wood-burning appliances and diminished air quality, and (2) serves as
a verifiable record that a violator is aware of the ordinance and public
re spons ib i1i ty.
2.4 PROGRAM EFFECTIVENESS
Arriving at an evaluation of the actual effectiveness of PA program
elements is difficult given the basic mechanics of how PA program elements
operate. Short of taking exhaustive personal surveys that ask explicitly if
owners of RWC devices reduced their appliance use or altered wood-burning
habits directly because of what they had learned through community PA program
elements, there is no direct, quantifiable correlation between PA and improved
emission levels. However, despite these obstacles, there is a consensus that
PA program elements are pivotal to the success and acceptance of a community's
overall RUG emission control program. In summary, the PA program element is a
necessary -- but often insufficient -- ingredient in a community's comprehen-
sive approach to PM-10 attainment.
Following is an attempt to characterize three levels of effort for a
stand-alone (i.e., not combined with other program elements) PA program
element. Table 2-3 describes each of the three hypothetical levels of efforts
in terms of communication media and level of intensity (or frequency). It
must be emphasized that these are presented for illustrative purposes only.
The design of a specific PA program element must take into account attitudes,
resources, demographics, and other site-specific factors.
Unlike the other program elements described in this document, EPA has
decided not to award emission credits for public awareness program elements.
Instead, PA is viewed as a necessary component for the success of other
2-20
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program elements. The reasons for not awarding credits for PA are: its
effectiveness is virtually impossible to quantify; it is an unenforceable
measure; and no standard PA program element can be defined (i.e., it must
reflect site-specific circumstances). The PA program element is considered by
EPA to be a necessary component for any RWC emission control program seeking
SIP emission reduction credits.
2.4.1 Minimal Level of Effort -- Use of One Medium Only
Reliance on any one broadcast medium will be the weakest approach,
whereas a comprehensive mix of print, broadcast, and public contact media
would yield the best results. Of the three media discussed, TV and radio
(i.e., broadcast) alone would likely be the least effective at achieving PA
goals. A consensus seems to say that this medium's primary advantage lies in
alerting people to current air quality conditions for purposes of curtailment,
although there is probably a long-term cumulative effect on the wood-burning
public from repeated warnings and alerts.
2.4.2 Medium Level of Effort -- Broadcast Plus Public Contact
A medium level of effort of a PA program element would combine the
broadcast and public contact media. A community could initiate its PM-10
program process through a PA program element that focuses first on at least
three methods of public contact: (1) town or neighborhood meetings, (2) talks
with civic groups (e.g., Kiwanis or Rotary Clubs), and (3) trade shows.
Regulatory agency officials and health experts would discuss the ordinance as
a whole, then emphasize those health effects of wood smoke that have the
greatest psychological impact on the audience. Once all segments of the
community have had a chance to attend the public forums, the program element
would then rely on regularly scheduled, weekly TV and radio PSAs that act as
periodic reminders of the PM-10 program, as well as giving curtailment notifi-
cation.
2-22
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2.4.3 High Level of Effort Multimedia/Extensive Effort
A third, more powerful PA program element would establish a comprehensive
network of print, broadcast, and public contact/public education media, in
which each approach is coordinated with and reinforces the other two. Public
education through workshops, seminars; trade fairs, and community/publie
schools would be augmented by an extensive range of printed material dis-
tributed at each education event. Brochures (printed in volumes equal to one
brochure for every RWC device in the area) should cover a range of topics,
including:
Health effects of RWC emissions;
Selection, operation, and maintenance of RWC devices;
Fuel selection and use;
Nonhealth benefits of RWC emission control; and
Alternative fuel/heating options.
As Washington State and Klamath County have demonstrated, an aggressive public
education plan that pairs printed messages with hands-on involvement forms a
robust PA program element in which various agencies can continue to address
PM-10-related issues (health, quality of life, etc.). Furthermore, printed
material such as billboards, bumper stickers, and room signs in resorts that
offer RWC devices should also be a part of this program element.
As reported by Maykut, enlisting the support of the broadcast and news-
paper media early in the PA process helped ensure popular support for the PM-
10 program goals (16). Developing wood heating-related TV and radio programs
that go beyond simple PSAs, as well as regular newspaper articles with in-
depth coverage of relevant topics, is ideal for large metropolitan areas. And
because of the large number of potential and actual RWC appliances in the
cities, communities could adopt the system used by the State of Washington,
which assesses a $5 tax on all stove sales to subsidize the cost of educa-
tion. Wherever there is a large number or concentration of wood stove users,
2-23
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novel approaches to print communication (billboards, placemats, bumper
stickers, hotel room notices) can also be effective at educating the wood-
burning population.
The most effective approach to FA program elements emerges as a broad-
based, comprehensive use of public speakers, all types of printed material,
and well-timed, highly visible broadcast efforts. What is essential for each
regulatory agency is to understand what program elements are best suited to
the unique complexion of the community. Changing individual habits of wood
burning through an enlightened, aware public is the essence of successful and
long-term reductions in PM-10 levels. The key program element to achieving
high levels of reduction rests on establishing, then maintaining, a flexible
and varied PA program element that involves the community and its resources as
a whole.
2.5 TRACKING
As noted earlier, it is difficult to quantify the effectiveness of PA as
an RWC emission control measure. Consumer behavior may change as a result of
economic factors (e.g., perception that alternative heating is much less
expensive), lifestyle trends, or the influence of other program elements.
There are public relations firms that are skilled in developing surveys that
can isolate whether and to what extent various PA measures are influencing the
public.
2-24
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SECTION 3
IMPROVING WOOD BURNING PERFORMANCE
3.1 INTRODUCTION
Improvement in the combustion of wood in residential units can be
achieved in one or more of four ways. First, RWC devices can be designed to
employ features (e.g., smaller fireboxes) that can reduce the quantity of
particles created during the actual combustion process. Second, the PM-10
produced during combustion can be reduced by installing and operating control
devices on the flue gases of RWC devices (such as secondary combustion or
catalytic combustion) prior to emission to the atmosphere. Third, require-
ments concerning proper installation, maintenance, and operation of wood
combustion devices can be implemented through a program of education, audits,
inspections, and permits. Finally, the types of fuel combusted can be limited
to those that are inherently less polluting.
In addition to these four methods of improving wood burning performance,
a related approach to reducing emissions of PM-10 would be a program directed
at improving the weatherization of homes. This would reduce PM-10 emissions
by reducing the amount of wood combusted to heat a residence or building.
A permit program can be included as part of any strategy for improving
the emissions performance of RWC devices. A permit program can improve the
ability of the control program to reduce RWC emissions and track PM-10
emission reductions. Under a permit program, all owners of new or existing
RWC devices would be required to obtain a permit from the state or local air
quality agency. From this permit file, the agency could construct and
maintain a data base on any increase in the number of RWC devices in the
community, which residences have RWC devices installed, and what types of
devices are operating in the community. Consequently, a permit program would
provide an agency with a method for controlling emissions. A permit program
3-1
-------
can help ensure compliance with requirements that certain RWC technologies are
used, that specified installation procedures are followed, or that fuel
quality requirements are followed.
In considering the emission reductions achievable through improving the
performance of RWC devices, it should be recognized that these improvements
may prove inadequate to remedy a community's PM-10 attainment problems. In
these and other instances, program design should emphasize the benefits of
encouraging or requiring operators of RWC devices to switch to other, less
polluting fuels for residential heating. Program elements prohibiting the
operation of RWC devices are discussed in Section 4.3 below.
3.2 CERTIFICATION PROGRAM
3.2.1 Introduction
Certification programs improve the emissions performance of RWC devices
by establishing uniform procedures for determining the relative emissions
potential of various designs, and by allowing regulators and consumers to
distinguish between low-emitting and high-emitting RWC devices. A typical
certification program consists of two primary parts. First, a regulatory
authority develops laboratory procedures for testing RWC devices to determine
their PM-10 emissions characteristics under representative operating condi-
tions. Manufacturers are then required to submit their products, or indivi-
dual RWC devices representative of their products (i.e., prototypes), for
testing to determine their potential emission rates.
Second, the regulatory authority establishes a level of emissions that
cannot be exceeded for any device. This prohibition could extend to any RWC
device sold within the jurisdiction of the authority, to any device installed
in that community, and/or to any device operated in the community. Enforce-
ment of this certification requirement is accomplished through audits of
manufacturers or retailers, or through in-home inspections.
3-2
-------
The EPA currently administers a certification program applicable to new
wood heaters as part of the new source performance standards (NSPS) program
under the Clean Air Act (See Section 1.2.2.1 of this document). Under this
program, detailed procedures and requirements have been established for
testing, selling, labeling, and operating wood heaters.
The effectiveness of certification programs in reducing emissions of PM-
10 is generally a function of four factors:
Growth (or decline) projected in the number of operating
devices in a baseline year;
Rate of replacement of existing devices with certified devices;
The difference in average emissions between baseline and
certified devices, which is governed by the emission standards
selected; and
The difference between the performance of RWC devices in
laboratory settings versus their performance in actual residen-
tial applications.
A certification requirement reduces emissions to the extent that the per-
centage of certified RWC devices relative to uncertified devices increases in
the community. If certified RWC devices replace existing devices, whether
because the existing devices have completed their useful lives or because of
regulatory requirements to phase out existing devices, current PM-10 emissions
will be reduced. If the total number of RWC devices is expected to increase
and new devices are required to be certified, future PM-10 emission increases
will be reduced, although actual emissions may still increase.
The emission reduction achieved in a given year through a certification
program can be measured by the difference between emissions from certified RWC
devices compared to the emissions from uncertified devices. In a program
where only new devices are required to be certified, the emissions decreases
achieved by a certification program are realized incrementally over a 10- to
20-year period as existing devices are retired. If the implementation of the
program is accelerated by requiring the replacement of existing devices before
3-3
-------
their useful life expires, or through more rigorous enforcement of the cer-
tification requirement so that noncompliance is reduced, then the reduction in
emissions will be realized earlier and the reductions in the first years of
the program will be greater.
3.2.2. State Prr>81TiqtP-'ii
Certification programs can be incorporated into state wood combustion
emission control programs in a variety of ways. The first is through develop-
ment of an independent state-administered certification program. The states
of Oregon and Colorado conduct testing and certification programs for RWC
devices sold at retail in those states, in addition to the EPA program. The
Oregon program was the first certification program adopted, and served as the
model for many of the facets of the EPA program. The EPA is not encouraging
the development of certification programs by other states, however. Because
the EPA program is national in scope and incorporates the most recent informa-
tion on emission reduction technology, the implementation of additional
programs at the state level would be a duplication of effort.
State and local authorities could take steps to enhance the effectiveness
of the federal program. The first such step could be the adoption of the EPA
certification program as state law. After adoption, the certification
requirement could be implemented and enforced by the states without requiring
federal action. Currently, EPA plans to conduct a vigorous retail level
enforcement program, but, although empowered to do so, it is unlikely the
agency will enforce the program at the household level.1 A related step in
state or local enhancement of the EPA certification program is for state
authorities to undertake the responsibility for compliance and enforcement
activities required by the program. This entails using state personnel to
Although the focus of the NSPS is on certification of wood heater models by
manufacturers, there are provisions that affect retailers (e.g., ban on sale of
uncertified wood heaters) and wood heater owners and operators (e.g., operation
and maintenance according to owners manual).
3-4
-------
inspect retail outlets to ascertain whether units being offered for sale are
certified, and whether retailers are complying with the labeling requirements.
Washington is an example of a state that has adopted the EPA and Oregon
certification programs as part of the state's regulations. The Washington
regulations prohibit the advertisement, offer, sale, bargain, exchange, or
donation of any new wood stove in Washington unless it has been tested,
certified, and labelled in accordance with criteria and procedures specified
by the EPA regulations or the Oregon regulations. The regulation also
establishes exemptions from the certification requirement, prohibits local
authorities from establishing standards that are more stringent than the state
standards, establishes labeling requirements and prohibits alteration of
labels, and prohibits alteration of RWC devices that have been certified.
whether the state adopts the certification program or becomes involved in
enforcement of the program, the result is a more vigorous program and, conse-
quently, greater compliance with the certification requirements. This greater
compliance reduces RWC emissions and ambient PM-10 concentrations by causing
the certification program to be implemented more rapidly and more completely,
with a greater rate of compliance with the sales and operation requirements of
the program.
Other options are also open to state and local authorities that enhance
the effectiveness of the EPA certification program. These involve incorporat-
ing the certification requirements into other program elements, such as the
exemption of certified devices from curtailment requirements or the banning of
uncertified devices from new residences. Jackson County, Oregon prohibits
installation of an uncertified RWC devices in a residence, in addition to
prohibiting the retail sale of uncertified devices. These prohibitions make
the installation of uncertified devices from out of state illegal, which can
be especially important in border areas, such as Jackson County where resi-
dents have ready access to uncertified devices from adjacent states that do
not have certification requirements.
3-5
-------
The California Air Resources Board (CARS) is considering a State regula-
tion that would address particular problems faced by that State. It would
address the potential problem of "dumping" of RVC devices on the market in
California that cannot be sold because of RVC regulations in surrounding
States and localities (i.e., Oregon and Vashoe County, Nevada).
The adoption of a certification program by a state or local community
would not result in significantly greater reductions in emissions than will be
achieved by the existing EFA certification program. The existing program
reflects the level of reduction in emission rates achievable using current RWC
emission control technologies. No certification programs, for example,
address emissions from fireplaces,2 which may comprise 50 percent of RVC
emissions in areas such as Denver.
Further, certification programs address primarily long-term changes in
emissions, since they require a substantial turn-over in the mix of RVC
devices in a community before they accomplish significant reductions in
ambient PM-10 concentrations.
Although active state participation in implementing and enforcing the
federal certification could enhance the Federal Certification Program, it is
not anticipated that state or local agencies will adopt these measures.
Further, since the federal program will be national in scope, the additional
reductions in PM-10 emissions stemming from state participation are expected
to be minor. Therefore, no reductions are recognized in this guidance on
designing RVC emission control programs, as indicated in Table 3-1.
3.2.3 Ban on Resale or Installation of Used Uncertified Vood Heaters
Most certification programs, including those developed by the EPA and by
the states of Oregon and Colorado, apply only to new wood heaters. Used wood
heaters can still be sold by individuals without being certified. As a
Emissions from fireplaces, unlike "air tight" enclosed wood heaters, are not
readily controlled by catalytic or noncatalytic controls.
3-6
-------
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3-9
-------
consequence, uncertified wood heaters can stay in commerce and continue in
use. A ban on the sale or installation of used, uncertified wood heaters
would eliminate these wood heaters from the market. Any consumers desiring to
install an RWC device in a residence would be forced to purchase new, cer-
tified RWC devices. This would lead to a faster turnover in the mix of RWC
devices in the community, and replacement of existing uncertified devices with
new, certified wood heaters.
An example of a ban on the installation of used, uncertified RWC devices
is the local program in Jackson County, Oregon. Oregon has a state regulation
that makes it illegal to sell an uncertified stove at a retail outlet.
Jackson County has adopted a complementary ordinance that prohibits the
installation of an uncertified wood stove in a residence. This provision
restricts the sale of used RWC devices in the county, as well as the sale or
installation of used, uncertified RWC devices from out of state.
In this guidance, no credit is recognized for a ban on the resale of
existing uncertified RUC devices. Instead, it is assumed that each program
element calling for the replacement of an existing device with a device having
lower emissions will contain a prohibition against the resale of the uncer-
tified appliance and that this prohibition can and will be enforced. Conse-
quently, the emission reduction credit is recognized under the other program
elements discussed below. In addition, a prohibition against the resale of
used RWC devices in an informal market would be difficult to enforce, making
the quantification of reductions in PM-10 emissions speculative.
3.3 INSTALLATION QUALITY ASSURANCE
3.3.1 Introduction
Proper installation of RWC devices is necessary in order to achieve the
reduction in emissions possible through the application of low emitting
technologies, as well as to realize the most efficient operation of the device
as a means of space heating. Several aspects of the installation of an RWC
device can affect PM-10 emissions. The device selected for use in a residence
3-10
-------
should be properly sized to accomplish the heating needs of the residence,
without being over-sized. Smaller firebox sizes tend to result in hotter
fires, and, therefore, more complete combustion (32). The heating needs of
the residents and the structure should be examined so that the device is
adequate in size, but not inefficiently large.
Similarly, RWC devices that incorporate thermostatic control devices
should not allow severe air supply cycling such that sufficient oxygen for
complete combustion is unavailable. The flue gas ventilation system also
requires attention. Improperly vented RWC devices result in inadequate intake
of air into the unit, adversely affecting the combustion efficiency of the
device and increasing emissions. Therefore, the installation of a device
should be planned to provide for adequately-sized flue pipes that are designed
to provide the most efficient air flow through the device. In addition, the
design and installation of flue vents can also aid in reducing ambient con-
centrations of wood smoke by preventing the downwash of the particulate-laden
flue gases.
3-3-2 Installer Training and Certification
An installation training and certification program improves RWC device
installation and reduces emissions by improving the knowledge of the
retailers, chimney sweeps, and others who are involved in the business of
installing wood heaters or constructing fireplaces. This program can be
either voluntary or mandatory. A voluntary program offers a course in RWC
device installation and fireplace design. Individuals and businesses par-
ticipating in the program are then able to advertise their certification
status. Purchasers of RWC devices can choose certified installers on the
assumption that installation by a certified installer results in more effi-
cient, less polluting, and safer operation of the device. In a voluntary
program, effectiveness is a function of the degree to which installers and
purchasers can be convinced that certification provides benefits to the
individual homeowner and to the community.
3-11
-------
A mandatory program requires any individual installing an RWC device to
be certified. This program differs from the voluntary installer certification
program because it affects all new installations and installers, not just
those who choose to avail themselves of the program. Consequently, where the
voluntary program might reach only a certain percentage of the RWC devices in-
stalled, the mandatory program would affect all new installations.
No mandatory installer certification programs have been identified,
although voluntary education programs for installers are in operation.
Washington state promotes better operation and installation through classes
offered to homeowners under its public awareness program, as well as classes
that are available to manufacturers, retailers, and operators. The goals of
this program are to promote better installation of RWC devices and to increase
the retrofitting of catalysts to existing RWC devices.
The effectiveness of a voluntary installer certification program depends
on the ability of the air quality authority to convince installers to par-
ticipate in the program, the ability of certified installers to convince the
public of the advantages of certified installation, the degree of improvement
in actual installations accomplished through a certification program, and the
emissions reductions achieved for individual devices through improved instal-
lation. The effectiveness of mandatory installer certification programs
depends only on the degree of improvement in actual installations accomplished
through a certification program, and the emissions reductions achieved for
individual devices through improved installation. An additional factor is
whether homeowners installing devices in their own residences would be ex-
empted.
3.3.3 Inspections
Through an inspection program, an air quality agency ensures that RWC
devices are properly installed by inspecting residences where new devices or
fireplaces are installed. These inspections would ascertain that flue sys-
tems, thermostatic controls, and catalysts are properly installed to achieve
emission reductions, as well as efficient and safe operation. These inspec-
3-12
-------
tions could be carried out by the city or county building inspection staff as
part of an existing building permit and inspection system. Any such program
would be mandatory for new RWC device installations, and could be required for
existing RWC devices as well.
There are currently no inspection programs applicable to RWC devices that
inspect for factors related to emissions. There are locations, such as
Washington State, where inspections are made as part of a building inspection
program, particularly for fireplaces. These inspections focus on safety and
structural soundness, however, and apply primarily in instances where instal-
lation of a RWC device is part of new construction or the remodeling of a
residence.
3.3.4 Installation Credits
The effectiveness of installation quality assurance programs is generally
a function of two factors. The first is the degree to which such a program
accomplishes an actual change in the installation practices of RWC device
owners, retailers, chimney sweeps, and others who may install them. The
second is the incremental difference in emissions from a device that is pro-
perly installed from one that is improperly installed. Both of these factors
may exhibit a range in the difference they make in emissions, depending
largely on the degree of improvement possible in the installation of RWC
devices in a community.
There are little data on which to base credits for improved installation.
The technical review group determined that, since the emission factors are
based on average-or-better installations, the improvement in installations
would result in only a marginal improvement in emissions. Therefore, the
credit for measures to improve installation is generally expected to be <5
percent applied to new installations where either the installer is trained/
certified or the installation is inspected.
Since the emission factors in AP-42 (see Table A-4) are based on stoves
that were generally properly installed, any large credit for programs to
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improve installation quality could not be given unless the agency documents
that installation quality is poor at a high percentage of new installations.
In such cases, the emission factors should be adjusted to reflect the worse-
than-average installation.
3.4 TECHNOLOGY REQUIREMENTS
3.4.1 Introduction
Technology requirements reduce emissions of PM-10 from RWC devices by
requiring the incorporation of advanced design and technology that inhibit the
formation and emission of PM-10. These requirements may call for the adoption
of devices that alter the combustion process, that change fuel use patterns,
or that remove particles from flue gases.
Generally, a program element involving technology requirements includes a
direct requirement that any new RWC device installed in a community must
incorporate advanced technology to reduce emissions. In a more stringent
program, this requirement might also be applied to existing devices, requiring
homeowners to replace existing devices or to retrofit them with catalysts or
other control devices.
3.4.2 Pellet RWC Devices
A requirement that only certified pellet stoves be permitted for new
installations of RWC devices lowers emissions because pellet stoves have
inherently lower emissions than other RWC devices. In more stringent pro-
grams, RWC device owners can be required to substitute pellet stoves for
existing RWC devices to achieve immediate reductions in emissions.
Pellet stoves require specially manufactured wood pellets and are depen-
dent upon electricity to power the fuel feed system and combustion air. These
factors place limits on the applicability of pellet stoves. The special fuel
requirements mean that pellet stoves are only feasible where facilities for
manufacturing wood pellets are located in the vicinity to reduce transporta-
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tion costs. The forced combustion air design of pellet stoves has also
limited the effectiveness of this technology at high altitudes. In these
locations, the fan systems may not provide adequate oxygen for efficient
combustion. Finally, pellet stoves are more expensive than other RWC devices,
which limits their attractiveness relative to other types of RWC devices and
other heating fuels.
Although there are no existing programs that require installation of
pellet stoves in either new or existing installations, there are program
elements that indirectly promote pellet stove use. The Lewis and Clark
County, Montana, program exempts pellet stoves from the local curtailment
requirements. Lewis and Clark County also considered requiring pellet stoves
to be sold with maintenance contracts to provide for long-term performance,
but rejected this proposal because of expected public opposition.
The effectiveness of a pellet stove requirement can be estimated based on
the difference in emissions between certified pellet stoves and existing
stoves, and the rate of adoption of pellet stoves to replace existing RWC
devices. Table A-4 contains the emission factors for the categories of RWC
devices. As can be seen from this table, pellet stove PM-10 emissions range
from approximately one-fourth the emissions from a catalytic wood heater to
approximately one-tenth the emissions of a conventional wood stove.
As indicated in Table 3-1, a program element requiring the installation
of pellet stoves would result in significant reductions in PM-10 emissions
from wood combustion in a community. For each existing, uncertified RWC
device replaced by a pellet stove, the reduction in PM-10 emissions would be
90 percent, based on the difference in emission factors for these types of RWC
devices. Similarly, the reduction in PM-10 emissions would be 75 percent for
each non-pellet Phase II certified RWC device replaced by a pellet stove. The
overall restrictions would be calculated based on the mix of existing devices
and the projection of new devices in the community (as determined through the
household survey in Appendix A and estimated growth rates).
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3.4.3 Phase II Certified RWC Devices
A requirement that all RWC devices be EPA Phase II certified devices is
similar to a pellet stove requirement. Phase II devices are designed to
achieve more efficient combustion and lower particulate emissions than conven-
tional devices, although their emissions, as shown in Table A-4, are higher
than for pellet stoves. Generally, pellet stoves are considered to be a
subset of Phase II certified devices.
Requirements that all new RWC devices be Phase II devices have been
incorporated into a number of local RWC emission control programs. Telluride,
Colorado, and the surrounding San Miguel County incorporate a Phase II device
requirement into a permit program for installing and operating a wood stove.
To obtain a permit, a device must be among the cleanest on the Colorado
certification list. The Telluride program applies to existing devices as well
as new ones. Owners of existing RWC devices had 3 years to comply from the
adoption of the regulation. Owners of new devices are required to comply
immediately. Similarly, Juneau, Alaska, requires a permit for new RWC
devices, and qualifying ones must meet EPA Phase II standards for emissions.
The effectiveness of a requirement that Phase II certified devices be
installed is projected in Table 3-1. A "first cut" number reflecting the
reduction in PM-10 emissions for each existing, uncertified RWC device re-
placed by a Phase II certified device would be approximately 50 percent, based
on the difference in emissions between an NSPS certified device and a conven-
tional device. This assumes a mix of appliances, degradation of performance
of catalytic stoves, and that NSPS stoves burn wood more efficiently than do
conventional stoves. The overall reductions achievable through this require-
ment is a function of the number of existing devices replaced (if the require-
ment is made to apply to existing devices). Since the federal program re-
quires new devices to be certified, this program element would not affect
emissions growth from new devices.
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3.4.4 Retrofits
Proposals to require that emissions control devices be retrofitted onto
existing RWC devices usually specify catalysts or pellet hoppers as the
retrofit technologies to be applied to conventional RWC devices. This option
has been considered by some communities, but has not yet been adopted into any
mandatory residential wood combustion program. Some communities, such as
Missoula, have directed at least a part of their public education and aware-
ness activities into encouraging owners of RWC devices to install retrofit
catalysts where possible. Retrofit requirements would apply to existing RWC
devices and would be most effective if coupled with other requirements, such
as a catalyst requirement for new stoves or a ban on new woodburning fire-
places. Since catalysts are generally not designed for use in fireplaces and
are unnecessary on existing catalytic stoves or pellet stoves, the reduction
would be the extent to which the retrofit requirement reduced emissions from
existing conventional stoves.
The effectiveness of a retrofit requirement is a function of the dif-
ference between the emissions from the retrofitted devices and the emissions
from those devices prior to the application of the technology. It is dif-
ficult to derive a general conclusion concerning the effectiveness of a
retrofit requirement in reducing FM-10 emissions. Although there are some
exceptions, retrofit catalysts and pellet hoppers are not generally designed
for a specific model of RWC device. Consequently, the emission reductions
achieved by a retrofit technology may vary significantly from one retrofit
technology to another, and between applications of a retrofit device to
different RWC device designs and models. The Oregon Department of Environmen-
tal Quality has estimated, based on laboratory tests of RWC devices equipped
with retrofit catalysts, that average emission reductions from these devices
was between 42 and 71 percent. Retrofit devices installed in RWC devices in
actual residences could be expected to show an even wider range of emissions
-- particularly on the low side -- due to variations in installation and
operation.
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On a community-wide basis, the reduction in emissions achievable through
a retrofit requirement depends on the contribution of certified and conven-
tional stoves to the total wood PM-10 emissions, and on the relative number of
certified versus conventional stoves being retrofitted. The total reduction
in PM-10 emissions could be estimated based on data collected in the household
survey, as well as assumptions about emission factors and stove usage pat-
terns. The estimate of a reduction of 5 percent or less in PM-10 emissions
described in Table 3-1 is based on the assumption that catalyst retrofits will
be required for all uncertified RWC devices in the community, that the
requirement will be phased in over 3 years and that quality assurance of the
retrofit kit and its installation will be difficult to gauge. This credit
could be increased if a method is devised (and approved by EPA) to certify the
quality of the retrofit hardware and installation in a particular area.
3.4.5 Accelerated Changeover Requirements
Accelerated changeover requirements lead to faster replacement of exist-
ing RWC devices by certified devices. The mechanism for such an accelerated
changeover is a direct regulatory requirement, banning certain types of
devices or requiring their replacement with approved devices. Instead of
basing the replacement rate on the useful life of the device, this program
element requires existing devices to be replaced earlier, with the replacement
triggered by some change in the status of the device, such as a change in
ownership. For instance, in Uashoe County, Nevada, installation of an RWC
device requires a building permit that cannot be issued unless the permittee
has an affidavit of sale that shows that the RWC device meets emission limits
of 9 grams per hour for noncatalytic stoves or 4 grams per hour for catalytic
stoves. The county maintains a list of devices that meet these limits. The
building inspector will not issue a permit unless the device is either
exempted from the standard (such as fireplaces, cookstoves, furnaces, etc.) or
meets the emission limits (i.e., is on the County's approved list).
The State of Oregon is considering legislation that would require a
homeowner selling a residence to upgrade the RWC device in the home to a
certified unit (or to remove it entirely). The required upgrade program would
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foster more widespread use of certified devices and would reduce the number of
out-of-state RWC devices brought into the state. In another example, Routt
County, Colorado presently requires all existing coal stokers and wood stoves
to be changed over to certified Phase II devices or to be replaced with
alternative heating (e.g., gas).
An accelerated changeover requirement does not result in a reduction in
greater long-term emissions than that achieved by other program elements for
improving the emissions performance of wood combustion devices. This program
element will, however, result in the benefits of any such program being
achieved earlier than would be the case under a "normal" replacement program.
A requirement that only EPA Phase II certified RWC devices may be installed in
new residences would achieve the same level of effectiveness in reducing
emissions, but only over the passage of several years. A requirement that
existing devices be replaced by catalytic stoves, or that RWC devices be
upgraded on the sale of a home or other event, would quicken the pace of
emission reduction.
It should be noted that accelerated changeover requirements may also lead
some RWC device owners to switch from wood to other fuels for residential
heating. This will result in a greater increase in emissions. Efforts to
require or persuade homeowners to adopt a current RWC emission control tech-
nology may also "lock in" a technology that may be superseded or improved upon
in the near future. This would lead to higher long-term exposure to PM-10
than necessary, and to consumer resistance to any subsequent program element
requiring additional or different technologies to meet PM-10 attainment goals.
The effectiveness of an accelerated changeover program would depend on
the number and types of devices that would be replaced in each year of the
accelerated schedule compared to the number of replacements under a program
based on the useful life of existing devices. For each existing uncertified
conventional RWC device replaced by a Phase II certified device, the reduction
in emissions would be estimated by procedures in Appendix A. This estimate
would consider the device mix, adjustments in wood burning rate (i.e. Phase II
stoves are more efficient) and performance degradation. A "rough cut" value
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for use in preliminary estimates would be 35 percent. The estimates of the
reduction in PM-10 emissions resulting from the acceleration in the rate of
changeover from uncertified to certified RWC devices are contained in Table
3-1.
3.4.6 Accelerated Changeover Inducements
Inducements to accelerate changeovers would be similar to required
changeovers, except that the mechanism would be financial or some other form
of inducement, rather than the exercise of regulatory authority. For
instance, Jackson County, Oregon, has a program for funding the replacement of
old uncertified devices in low income housing units with newer, certified wood
heaters. A grant of $1.6 million was made available with which the county is
hoping to replace RWC devices as well as to provide insulation for 300 to 500
homes at a cost of $3000 to $5000 per dwelling. The program is funded through
county funds, rather than private funds.
The effectiveness of the Jackson County program will be measured (when it
is completed) by the number of residences that have been provided with cer-
tified devices to replace existing ones, and the number of homes weatherized.
Currently, the estimate is that 300-500 homes will participate in the program.
The important sources of variation in the effectiveness of this program
element are the condition of the residences being treated, the willingness of
the homeowners to cooperate, and the availability of funding.
Montana also has a program for encouraging the accelerated changeover
from older devices to newer, more efficient and less polluting wood combustion
devices. Through this program, stove purchasers get a tax credit for buying
clean stoves to replace existing stoves. Alaska has approached this same
issue by providing a low interest (5%) loan program enabling individuals to
purchase qualifying catalytic wood stoves.
The effectiveness of these inducements to accelerated adoption of less
polluting technologies is a function of the success of the program in motivat-
ing homeowners to invest in the newer technology. A program of grants, such
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as that in Jackson County, will be most effective, in that it entails vir-
tually no cost to the homeowner. A tax incentive or low interest loan program,
on the other hand, will result in fewer owners of existing devices switching
to other technologies. It would, however, encourage purchasers of new systems
to consider low emitting technologies.
In addition to the effectiveness of the inducements in increasing the
level of consideration of lower emitting technologies, the reductions achiev-
able are also dependent on the difference between the technologies being
encouraged and those currently in use. In this context, it should be noted
that programs providing incentives to change over to cleaner RWC devices may
have the unwanted effect of accelerating new RVC device sales (as opposed to
sales of heating devices using cleaner alternative fuels, such as natural
gas), resulting in a diminishment in the effectiveness of the incentives in
reducing pollution. Additionally, as with accelerated changeover require-
ments, the effect is to change the timing of the emission reductions, not to
change the magnitude of the reductions ultimately achieved.
The decrease in emissions of PM-10 resulting from the adoption of an
incentive program is described in Table 3-1. As with changeover requirements,
the reductions for replacement of an existing, uncertified RWC device by a
Phase II certified device would be estimated by procedures in Appendix A.
This estimate would consider the device mix, adjustments in wood burning rate
(i.e. Phase II stoves are more efficient) and performance degradation. A
"rough cut" value for use in preliminary estimates would be 35 percent.
3.5 FUEL QUALITY REQUIREMENTS
3.5.1 Introduction
Certain fuels inherently produce more PM-10 when burned in an RWC device
than other fuels. The major characteristics of fuels that contribute to the
formation of PM-10 are ash content and moisture content. Coal, for instance,
has a high ash content relative to wood. Therefore, some communities, such as
Lewis and Clark County, Montana, prohibit the burning of coal. (In that
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county, users of coal who can show that they burned coal prior to 1981 are
exempted from the ban.) For wood, the most important fuel characteristic
contributing to variations in PM-10 emissions is fuel moisture. It must be
recognized that enforcement of these programs may be difficult.
3.5.2 Wood Moisture Content Regulations
Regulations that restrict the fuel moisture content of wood require wood
burned in RWC devices to be dried and cured to reduce the moisture content.
These restrictions can be applied either to wood offered for sale, or to all
wood burned in the community.
The Jackson County, Oregon, RWC emission control program provides wood
moisture measurement services to RWC device owners. Jackson County's public
awareness campaign is directed at urging wood burners to use only well-sea-
soned wood. In conjunction with this effort, the county has installed instru-
ments for measuring wood moisture content in firehouses around the county,
where individuals can have the moisture content of their fuel wood measured
for free. The county recommends a 6 to 12 percent moisture range.
Telluride, Colorado, has an ordinance that requires firewood be covered
to promote drier wood and, therefore, more efficient and cleaner burning. It
also requires that wood be seasoned and that only wood, not trash or other
materials, be burned. Although uncovered stacks can be identified for
enforcement purposes, the requirement for seasoned wood be burned in RWC
devices is not readily enforceable.
Washington also Has a requirement that wood be well-seasoned (no more
than 20 percent moisture content), but the program is largely unenforceable
because of the difficulty of obtaining access to wood piles to inspect for
moisture content, particularly in a state where many RWC device owners cut
their own wood.
The effectiveness of a fuel moisture content requirement is measured by
the difference between the emissions from the combustion of poorly seasoned
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wood and properly seasoned wood. This theoretical difference must be tem-
pered, however, by recognition that the enforceability of any such requirement
will be limited. Under these conditions, a public awareness program, such as
that in Jackson County, may be as effective as a regulatory requirement. The
incentive to burn dry, well-seasoned wood can be heightened when the public
understands that burning moist wood results in reduced heating performance.
The estimate of emission reductions achievable through wood moisture
regulations is described in Table 3-1. Because of geographic and seasonal
variability in wood moisture and the difficulty in enforcing a wood moisture
regulation, only minimal reduction credits are recognized. Further, because
pellet fuels do not vary significantly in moisture content, a wood moisture
regulation would accomplish a lower percentage reduction in emissions if the
number of pellet stores increases.
A specific program to address wood moisture might justify higher credit
if it can be shown that the burning of unseasoned or wet wood is particularly
prevalent in that area and that the program is both effective and enforceable.
Several additional program features can be considered in addition to those
discussed above. These include the establishment of community-run wood banks,
where green wood is exchanged for seasoned wood, with or without a nominal
fee. Also, programs to license wood sellers or restrict the cutting of green
wood during or just prior to the heating season may be considered. Any wood
moisture program should address public awareness, as discussed above.
3.5.3 Trash Burning Prohibition
A number of communities prohibit trash burning as a measure to control
PM-10 emissions from residential heating. Because of the variable make up of
trash fuels, as well as the potential for emissions of potentially toxic
materials from the combustion of plastics and other substances, restrictions
on burning trash in heating devices typically address problems with odors,
noxious gases, and toxic pollutant emissions.
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Washington State prohibits the burning of waste products, liquid fuels
and/or treated or painted woods. Although the ban on what types of wood may
be burned is mandatory, this is the weakest element of the state's program
because it is difficult to inspect what homeowners are actually burning.
Lewis and Clark County, Montana, has a prohibition against the burning of
any solid fuel except newspapers, untreated kraft paper, untreated wood and
lumber, and products made specifically as wood for wood stoves. Telluride,
Colorado, and Vashoe County, Nevada, have similar requirements. All of these
prohibitions are difficult to enforce.
The PM-10 emissions reduction achievable through a ban on burning trash
is difficult to estimate. This difficulty is made greater by the fact that
particulate matter from trash burning has proportionately less PM-10 than
particulate matter emitted from wood burning, so that PM-10 emission levels
cannot be assumed from total particulate emissions. Further, any ban on
burning trash in residential combustion devices would be difficult to enforce.
Therefore, although elimination of trash burning may reduce PM-10 emissions,
it is not anticipated that any such requirement would accomplish significant
reductions. Consequently, no emission reduction credits are recognized for
this program element. Restrictions on trash burning might be achieved through
a public awareness campaign that would emphasize the potential toxic emissions
from burning trash.
3.6 Weatherization
In addition to employing technology to reduce PM-10 emissions by reducing
particulate formation during combustion or removing particles from flue gases,
emissions can also be reduced by reducing the amount of fuel combusted in a
wood combustion device. Weatherization reduces fuel use by reducing the
heating requirements for the residence. The addition of insulation, weather-
stripping, and other means of insulating the interior of the residence from
exterior cold reduces the amount of space heat required to maintain indoor
temperatures at a comfortable level.
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Jackson County, Oregon, has a program of grants to homes in low income
areas to subsidize weatherization. A similar program is also used in Klamath
County. The shortcoming of these programs is that they are only applicable in
low income areas, not middle class areas.
Another shortcoming of weatherization efforts is the potential to exacer-
bate indoor air quality problems in the residence. If a house is weatherized
to the point that ventilation is overly restricted, the residents may be
subject to chronic exposures to indoor pollutants (from dry cleaning fluids,
building and insulation materials, cigarette smoke, and other materials).
However, programs which address the R-value of insulation do not exacerbate
indoor air quality problems. In general, a low credit (<5 percent) is ex-
pected for weatherization programs because the percentage of homes in a
particular community that would benefit substantially from improved R-value is
likely to be small. A thorough engineering analysis of the decrease in wood
consumption attributable to improved home insulation in a particular community
could justify a higher credit.
3.7 Opacity Limits
Limitations on the opacity of emissions exiting a stack are a regular
feature of regulations limiting particulate matter emissions from industrial
sources. These opacity limits serve two purposes. First, they are measurable
indicators of particulate matter emissions that can be used by an air quality
agency to determine the occurrence of violations of an emission standard or
permit limit. Second, high opacity levels indicate when there may be a
malfunction or problem with the operation of a source that requires repair or
remedy.
In order to implement an opacity limit for RWC devices, it is necessary
that the enforcement personnel for the air quality agency be trained to make
visual opacity readings. When properly trained, an individual is able to
distinguish between various percentages of opacity with accuracy and
predictability. In addition to being trained in opacity reading, however,
these individuals must also be trained to make these readings at night. Night
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time emissions are important in controlling RWC emissions because RWC devices
are typically operated at the highest burn rate early in the evening, then
late at night are operated under very low air conditions to burn through the
night. Both of these operating practices can create worst-case PM-10 emis-
sions problems.
Several localities include opacity limits in their RWC emission control
programs. Juneau, Alaska, included an opacity limit in their early regula-
tions addressing RWC emissions. The opacity standard allowed agency staff to
identify those RWC device owners who were out of compliance with the opacity
limit and to discuss proper device operation and maintenance to reduce stack
emissions. This approach was labor-intensive in the initial two heating
seasons, but worked to reduce the enforcement effort required later in the
development of Juneau's RWC emission control program.
Enforcing opacity limits requires substantial commitment of personnel.
Although the use of air quality officers for this purpose may be the desired
approach, budgetary limits may require the use of other personnel. Juneau
initially assigned animal control officers to enforce opacity regulations, and
trained them in opacity (smoke) reading. Subsequently, this was delegated to
the police department. Although using the police force increased the capabil-
ity to observe violations or handle complaints, RWC emission enforcement was
given a lower priority than other police work.
An opacity program could be used to ensure that certified stoves are
properly installed and maintained. Thus, an opacity regulation could be
valuable in ensuring that stove installation is properly accomplished and that
the stove is continuing to operate as designed. However, there are sig-
nificant limitations to an opacity program: (1) the budget and personnel
problems cited above; (2) the lack of conclusive data on opacity limit effec-
tiveness; (3) the fact that many appliances would operate within reasonable
limits; and (4) a start-up or refueling exemption would make enforcement
cumbersome. Thus, a credit of <5 percent is given unless a strong case can be
made that these limitations do not apply or can be overcome in a particular
community.
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SECTION 4
REDUCING USE OF RWC DEVICES IN A COMMUNITY
Limiting the use of RWC devices in a community through the use of
alternative fuels reduces ambient levels of PM-10 by reducing the amount of
wood combusted for space heating. By focusing on reducing the use of RWC
devices, residents turn to alternative fuels, such as natural gas or electric-
ity. These alternative fuels produce lower PM-10 emissions for the amount of
heating value they provide. Therefore, to the extent that less wood is
combusted for residential heat and more reliance is placed on these other
fuels, local PM-10 problems could be avoided or alleviated.
There are three types of program elements that can be designed to achieve
a restriction or reduction in the number of RWC devices in a community. The
first focuses on making fuels other than wood more available and more attrac-
tive as alternatives to wood for residential heating. In some communities,
merely making alternative fuels, such as natural gas, more available for
residential heating could lead residents to switch from wood and reduce PM-10
emissions as a consequence. In other circumstances, the use of alternative
fuels for residential heating can be promoted by the local air quality agency
through various economic incentives, increasing the use of lower-emitting
fuels and reducing the amount of wood combusted.
The second group of program elements would be directed at restricting
growth in the use of wood as a residential heating fuel by restricting the use
of RWC devices in new or existing residences. This restriction could take one
or more of several forms. One approach would be a requirement that existing
RWC devices must be retired before new devices are allowed to be installed, so
that the emissions from new RWC devices are offset by reductions from retired
devices. Another approach would provide economic disincentives to the use of
wood as a residential heating fuel through the use of taxes on new RWC
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devices. The most stringent restriction on new RWC devices would either ban
new RWC devices altogether, or limit on the number of devices allowed to be
installed in a residence.
Under a program restricting new RVC devices, residents would have to
adopt other technologies and other fuels for space heating. Restrictions
applicable to new residences would slow the growth in PM-10 emissions from new
RWC devices. Current PM-10 emission levels would not be directly affected,
but would be reduced over the longer term as existing RWC devices are retired
and replaced by other heat sources.
The third group of program elements would be directed at the elimination
of both new and existing RWC devices from the community. The number of
existing RWC devices could be reduced through the use of economic incentives
and disincentives aimed at influencing residents to adopt other technologies
and fuels for providing residential heat, or through the use of regulatory
actions against the use of wood as a heating fuel. These measures would
either mandate conversion of existing residences from wood to other fuels, or
would provide incentives designed to lead to this conversion.
These three approaches to limiting or eliminating the use of RWC devices
for residential heating are discussed in greater detail below.
A permit program would be a valuable part of an RWC control program based
on limiting the population of RWC devices in a community. First, the permit
program would enable the air quality agency to determine the existing popula-
tion of devices at the beginning of the emission control program so that the
effectiveness of control measures could be evaluated. Second, withdrawing
permits for individual RWC devices can be a practical way of tracking which
residences have replaced wood as a residential heating fuel with heating
systems using fuels other than wood. Third, RWC permit requirements for new
and existing dwellings could facilitate the administration of emission
offsets, as well as taxes or restrictions on the installation of RWC devices
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in new dwellings. Finally, permits can be an effective way of implementing an
incentive program for the elimination of RWC devices from existing residences.
4.1 BACKUP HEAT OR ALTERNATIVE ENERGY SOURCES
4.1.1 General
Except, perhaps, for the most isolated residences, there are alternative
fuels available for residential heating. Electricity, propane, solar, and oil
are widely available for residential heating, and natural gas is available in
many areas. Although the particulate matter emissions from the use of these
fuels varies, they all emit much less particulate matter than wood combustion.
There are no emissions of particulate matter from solar heating or various
other alternatives to combustion, such as the use of geothermal sources of
heat. Particulate matter emissions from oil, propane, and natural gas
combustion are negligible. Even the particulate matter emissions from the
combustion of coal are less than one-fourth the emissions from wood combustion
on a gram PM-10 per kilogram fuel combusted basis.
4.1.2 Facilitating Availability of Alternative Fuels
Natural gas is the primary alternative to the combustion of wood as a
residential heating fuel in terms of emissions, convenience, and cost.
Electricity and oil are also preferable heating fuels compared to wood, but
are typically more expensive and less efficient than natural gas. There are
several types of heating appliances available on the market that could compete
with RWC devices for cost, convenience, and reliability. The most common
natural gas-burning appliance that replaces wood combustion for residential
heat is the gas fireplace or "gas logs." Newer models of these fireplaces
combine combustion efficiency with some of the aesthetic attractions of wood-
burning fireplaces. In addition to gas fireplaces, manufacturers are also
starting to produce gas-fired heaters that look like wood stoves, as well as
kits for converting an existing wood stove for natural gas combustion. When
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designed or converted for natural gas, these devices cannot be used to combust
wood.
The basic limitations to the use of natural gas as a residential fuel,
however, are availability and the cost of making natural gas available.
Natural gas is only available to homeowners where pipelines and service lines
have been constructed to bring this fuel to the community. Therefore, one of
the elements that could be adopted into an RWC emissions control program is
making natural gas services available in communities and in neighborhoods
where it cannot now be obtained.
As part of its overall program for controlling wood combustion emissions,
Telluride, Colorado, encouraged a natural gas supply and distribution company
to bring natural gas into the town. Partly as a result of this program
element, Telluride has experienced a significant shift from the use of RWC
devices to gas logs as a source of residential heat. The growing residential
community in Telluride, coupled with the town's other programs restricting
wood combustion as a source of residential heat, made this community attrac-
tive to the natural gas company. In other circumstances, other incentives to
the introduction of natural gas might have to be supplied, such as favorable
price and right of way considerations, or an agreement to purchase natural gas
for public buildings and services.
In addition to making natural gas more available as an alternative fuel
for heating residences, local authorities can also make other fuels or
alternatives to wood heat available. Favorable electric rates and oil prices
can be negotiated with suppliers so that these residential heat sources are
more available and more economical.
Making an alternative fuel more available will not result in greater
adoption of that fuel or reduced combustion of wood unless the alternative is
more attractive in terms of cost, convenience, or reliability. The effective-
ness of this program element in reducing particulate matter emissions from
wood combustion rests on changing the perception of wood as a heating fuel
4-4
-------
compared to natural gas, electricity, or other heat sources. Consequently,
local authorities considering the adoption of this program element should
ascertain whether wood is either more expensive, more difficult to get, or
less reliable than alternative fuels. A first step in formulating a program
to persuade RVC device owners and owners of new dwellings to choose alterna-
tive residential heating fuels would be to determine and publicize the "true"
cost of wood, including:
The cost of an RWC device,
The cost of the wood itself on a dollars per Btu basis,
The cost of cutting and transporting wood,
The time involved in splitting, storing, and using wood, and
The time and inconvenience involved in disposing of ashes.
If existing economic considerations do not make natural gas, electricity,
or other fuels attractive and lead to the adoption of those fuels in
preference to wood, the local authority can also alter the context of this
decision through the exercise of regulatory authority. Telluride has done
this by passing a prohibition on fireplaces and certain types of wood heaters.
In another approach, the local authority can also change the economic context
of the decision by offering incentives for homeowners to adopt alternative
fuels, as discussed in the following part of this section. In either case, it
is important to note that making alternative fuels more available should
generally be seen as part of a program that includes other elements that
influence the selection of fuels other than wood.
There has been little research conducted that would indicate the level of
reduction in PM-10 emissions that could be achieved through making alternative
heating fuels more readily available. Such effectiveness would, as discussed
above, depend on a variety of other factors in the decision making process.
In estimating the effectiveness of a program to make natural gas (or
other alternative fuels) more available, the air quality agency must project
4-5
-------
the number of RWC devices that would be replaced by heating devices using
other fuels, and the extent to which the continued use of RWC would be for
supplemental heat or aesthetic purposes, rather than as a primary heat source.
In projecting PM-10 emission reductions for the purpose of evaluating SIP
regulations, credit can only be recognized for those program elements that can
be assured of achieving permanent and enforceable reductions. Consequently,
no credit for emission reductions can be recognized in instances where an RWC
device is retained, even though an alternative fuel is incorporated into the
residential heating system.
The mix of RWC devices that would be replaced if alternative fuels are
made available - that is, the number of conventional, certified devices versus
the number of Phase II certified devices - would have to be projected by the
agency to determine the quantity of emissions reduced. In making this
projection, it should be noted that most existing RWC devices replaced could
be expected to be conventional, uncertified devices that have relatively high
PM-10 emissions. For new residences, however, the switch to alternative fuels
would reduce the growth in PM-10 emissions from the lower-emitting Phase II
certified RWC devices.
The projection of emission reductions from making alternative fuels more
available should reflect the expectation that most changes from wood to
natural gas or other fuels will take place in the first year after other fuels
are made available. After the first year,the effectiveness of this program
element would reduce each year. It should be assumed that no more than 10
percent of the residences in the community would switch entirely from wood if
alternative fuels were made available for the first time.
Where the RWC device is replaced by the alternative heating system and
the RWC device is removed and disabled, credit is recognized for 100 percent
of the emissions from all RWC devices removed, as indicated in Table 4-1.
This estimate is based on a program that makes alternative fuels more avail-
able, without providing additional incentives for switching fuels.
4-6
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-------
4.1.3 Economic Incentives
The use of economic incentives to encourage homeowners to change from
wood to other fuels is the next step after making those fuels available in the
community. In this program element, the relative economic attractiveness of
wood versus other fuels is changed by initially making the other fuels less
costly. Through tax incentives, direct payments, or preferential utility
rates (or a combination of all three types of incentives), the community can
subsidize lower-emitting fuels, such as natural gas or electricity, making
them attractive to more homeowners.
A tax incentive program to encourage fuel switching would give homeowners
and builders a reduction in local taxes to offset at least part of the cost of
installing a heating system using natural gas or other alternative fuels.
This tax reduction could be applied against local property taxes, sales taxes,
and/or income taxes. A tax credit would allow a homeowner to reduce taxes by
an amount intended to offset the cost of installing and using the alternative
fuel. A tax deduction against income tax would allow the homeowner to reduce
taxable income to offset the cost of the new heating system. Both approaches
to tax incentives would require some form of legislation, usually at the State
level.
Direct payments can take two forms. The first is a direct subsidy to the
homeowner to offset any increase in costs incurred in changing to an alterna-
tive fuel. The second is a payment for switching fuels that is only indirect-
ly tied to the cost of removing an RWC device from a home. Both forms of
direct payments require a significant source of funding be made available to
the air quality agency.
The town of Telluride, Colorado, provided direct payments as incentives
to homeowners to convert from wood combustion to alternative fuels. During
the first year of a 3-year grant program, grants of $200 were made available
to homeowners to finance the conversion of home heating systems from wood to
natural gas or electricity. In the second and third years, this amount was
4-9
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lowered to $150 per residence, and then to $100 per residence. The purpose of
this graduated incentive payment program was not only to encourage homeowners
to convert from wood heating, but also to encourage them to do so early in the
three-year period rather than waiting until just before the deadline. This
incentive program was coupled with Telluride's requirement that uncertified
wood heaters and fireplaces be removed or dismantled over a 3-year period.
Utility rates can be changed to reduce costs for alternative fuels as an
incentive to homeowners to switch to the alternative fuels. The change in the
rates would reduce the cost of alternative fuels relative to wood, making the
alternative fuels more attractive for home heating. This incentive would
require the cooperation of the utility company and would have to be consistent
with the utility's revenue requirements
The electric utility in Boise, Idaho, developed an incentive program to
encourage homeowners to switch from wood to electricity for residential heat.
The goal of this program element was to reduce or eliminate the cost advantage
that wood has over electricity in the perception of many homeowners. Under
this program element, the electric utility in Boise calculates the average
monthly use of electricity for the residence prior to the installation and
operation of an electric heating system. This baseline electricity require-
ment is then compared to the monthly electric power demand for the residence
following the installation of the electric heating system. The electric util-
ity then reduces by half the cost per kilowatt-hour of electricity for the
usage that exceeds the established monthly average.
The design of a program element incorporating economic incentives for
homeowners to switch from wood to other fuels for residential heating should
begin with an economic analysis of the relative costs of each fuel to the
homeowner. This analysis should consider not only the costs of the fuels, but
also their cost on a dollar per Btu basis and the cost of the equipment
necessary to use a different fuel. From this analysis, the agency should be
able to project the number of homeowners who will switch fuels at a given
incentive level. Those who are constructing new dwellings may be more
4-10
-------
amenable to these types of incentives, since they have not already made
investments in heating systems. Owners of existing RWC may be more difficult
to influence with incentives.
When the level of incentive required to achieve a given level of adoption
of alternative fuels is established, the means of making that incentive
available should be examined. Tax incentives and direct payments are under
the direct influence of the air quality agency and the governmental bodies
with which it is associated. Tax incentives are typically longer term
programs, where the payment may be spread over several years. Direct pay-
ments, on the other hand, would be one-time, lump payments.
Utility rate changes would have to be coordinated between the air quality
agency and the local utility company. The utility would have to be persuaded
that the loss of revenues involved in offering lower rates to homeowners for
switching to natural gas or electricity would be offset by the increased use
of those fuels. This would involve an economic analysis of the behavior of
homeowners in selecting fuels and of their fuel use patterns over a period
that may extend several years.
The effectiveness of these incentive programs is dependent on the level
of incentive and the degree to which the incentive alters the economic
attractiveness of wood relative to natural gas, electricity, or other fuel.
The air quality agency would have to be able to show through an economic
analysis the number of existing RWC devices that would be removed and disabled
under the incentive program. For new dwellings and new RWC devices, the
analysis would have to estimate the difference in the number of RWC devices
that would be installed in the community with and without the incentive
program. For each RWC device that the agency could show would be removed or
not installed, the credit, as shown in Table 4-1, would be 100 percent. No
credit is recognized if the installation of a heating system using an alterna-
tive fuel only results in a partial reduction in the use of a RWC device for
residential heating.
4-11
-------
4.2 LIMITING NEW RWC DEVICES
Program elements that limit the growth in the number of RWC devices in
the community reduce PM-10 emissions by discouraging or prohibiting the use of
wood for residential heating. These elements address the growth in PM-10
emissions from wood combustion that would be expected to take place in a
community in the absence of a control program. They would not serve to reduce
existing emission levels directly, but as existing RWC devices are retired and
replaced with heating systems using other fuels, existing emissions would be
reduced.
Three program elements have been identified that address the choice of
heating fuel and residential heating appliance for new residences. The first
program element addressing emissions from new dwellings is an offset program.
This program element would require any additional emissions from an RWC device
installed in a new dwelling to be offset by compensating reductions obtained
by retiring RWC devices elsewhere in the community. Through this measure,
total emission levels in the community can either be held constant, or reduced
if the offset ratio is greater than 1-to-l. This program element would also
make the use of RWC devices more expensive and make other fuels relatively
more attractive.
The second program element applicable to RWC devices on new dwellings is
an economic incentive in the form of a tax on new RWC devices. This tax would
make RWC devices less economically attractive relative to other technologies
and other fuels.
The third and most stringent is a ban on RWC devices in new residences.
By requiring builders of new homes to look to other fuels such as natural gas,
electricity or oil for space heating, PM-10 emissions from these sources can
be virtually eliminated. Further, as existing RWC units are retired, the
current PM-10 emission levels can be reduced over time.
Each of these program elements is discussed in more detail below.
4-12
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4.2.1 Emission Offset Requirement
Under an emission offset requirement, the builder or owner of a new
dwelling would have to eliminate an existing RWC device before the air quality
agency would permit the installation of a new RWC device. This may mean that
the homeowner or builder would eliminate an existing device that the owner or
builder already owns, but more frequently would require the purchase of an RWC
device from another individual. This may mean negotiating with other
homeowners for the purchase and disabling of their wood stoves, or for the
dismantling of their fireplaces.
Offset programs can be designed either for the maintenance of existing
air quality or for the gradual improvement in air quality. If the owner of a
new wood combustion device is only required to find offsetting emission
reductions equal to the emissions from the proposed new device, then emission
levels would be maintained but not improved. If, on the other hand, the owner
of the new device is required to eliminate emissions in an amount greater than
the emissions from the new device, then the result would be an overall
reduction in total emissions.
Okanogan County, Washington, has an offset program for the Methow Valley
area that requires a permit for installation of a wood stove or fireplace in a
residence. One requirement for obtaining a permit is that the permit can only
be issued if it replaces an existing device in the same residence.
Telluride and surrounding San Miguel County, Colorado, have perhaps the
most active offset program in the country. This offset program operates in
combination with a permit system. Every new solid fuel heating device being
installed in the town requires the elimination of two existing permits.
Someone who wants to install a new device in a new or existing structure is
required to (1) buy two existing permits, resulting in the elimination of two
existing devices, and (2) purchase a stove from Telluride's list of qualifying
stoves. The current market price in Telluride for a permit for an existing
4-13
-------
stove is approximately $1,000, so the offsets for a new stove would cost
$2,000.
The effectiveness of an offset program is dependent on the ratio required
between the new emissions and the emission reductions required for the offset,
and on the rate of installation of devices in new dwellings. The greater the
ratio of emission reductions to emission increases required in establishing
offsets, the more rapid the decrease in emissions. Similarly, if there is a
rapid rate of growth in new dwellings in an area and, as a part of that
growth, a large demand for offsets for new RWC devices, the rate of PM-10
emission reductions would be increased.
The effectiveness of the Telluride program can be gauged in part by the
reduction from 550 to 400 permitted solid fuel heating units over the past two
years. If this entire program were attributable to the offset provisions,
this would mean that 150 new units have been permitted in Telluride, but that
300 units were retired as part of the offset program, resulting in a net
reduction of 150 units in two years.
The emission credit recognized for an emission offset requirement will
vary with the trading ratio. If the trading ratio is 1:1, no credit for PM-10
reductions can be recognized, since there will be no net reduction in the
number of RWC devices in the community. If the trading ratio is 2:1, the
credit would be calculated as the difference between the emissions from the
new RWC device and the emissions from two average RVC devices in the
community. This multiplier would vary with the trading ratio.
4.2.2 Taxes on New RWC Devices
Imposing or increasing taxes on new RWC devices might slow the increase
in RWC emissions in an area by effectively increasing the cost of wood heat
relative to other sources of heat or types of fuel. The intent of the tax
should be to give other fuels such a competitive advantage over wood that the
owners and builders of new homes will elect to install and use heating systems
4-14
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using other fuels. Taxes on new devices, whether they are installed in new or
existing dwellings, would not serve to reduce existing emissions directly,
since they would not increase the rate of replacement of existing RWC devices
or the reduction in the use of wood as a fuel for space heat.
In addition to a program that taxes all RVC devices, it would also be
possible to design a program that would selectively tax certain types of
devices. For instance, a tax placed on fireplaces would result in fewer
fireplaces being installed in new dwellings if no tax, or a smaller tax, were
placed on certified wood stoves. In this case, the tax would result in a
change in the types of RWC devices going into new dwellings in the community.
In designing a tax policy to limit the installation of new RWC devices,
the air quality agency should consider the applicability of the tax to
certified devices that are intended to replace existing uncertified devices.
If the tax operates to restrict the purchase of replacement devices in this
instance, the retirement of existing devices may be restricted and higher
emitting units may be retained in service longer. This would result in a
slower decrease in PM-10 emissions than would otherwise be anticipated from
the certification program.
In Table 4-1, a PM-10 emission reduction credit is recognized for each
new RWC devices that would not be installed as a result of the imposition of a
tax on new devices. For each device avoided, the emission credit would be 100
percent. In order to determine the number of RWC devices that would not be
installed as a result of setting the tax at a certain level, the air quality
agency will have to perform an economic analysis projecting the effect of
different tax levels on RWC device purchases.
4.2.3 Ban on RWC Devices
A program incorporating a ban on the installation and operation of wood
stoves and/or fireplaces in new dwellings can take several forms. First, the
ban can prohibit the installation of all RWC devices, essentially ending the
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increase in the use of wood as a fuel for space heating in residences in the
community. Second, communities could also extend such a ban only to certain
types of RWC devices. There are a variety of such programs, ranging from a
total ban on the installation of uncertified RUG devices in new dwellings to
bans on fireplaces. A third variation on the prohibition of RWC devices from
new dwellings limits the number of devices allowed in a residence. Although
not a total ban, these provisions accomplish the same basic goal as a total
ban by limiting the number of new devices allowed in a community. These
restrictions on RWC devices in new dwellings will reduce growth in PM-10
emissions from wood combustion, but would not affect existing emissions in the
short term.
San Miguel County, Colorado, is an example of a community that bans a
certain type of RWC device. Their program prohibits the installation of wood-
burning fireplaces in new dwellings. Mammoth Lakes, California, has a zoning
ordinance limiting the number of solid fuel burners per residence to one per
residential unit or commercial building and one per single family residential
unit. The devices installed under this requirement must be certified.
Similarly, the Lake Tahoe Regional Planning Agency has an ordinance that
limits the number of stoves to one per house and bans fireplaces in new
construction because fireplaces cannot be effectively controlled and therefore
are not certified (although they are considering allowing one fireplace in
lieu of a stove).
Several ski resort communities in Colorado have also enacted limits on
the number of devices that are allowed in new dwellings. In Aspen and Pitkin
County, Colorado, new dwellings are limited to one fireplace (with gas logs
only) and one certified stove. The Steamboat Springs (Routt County), Colorado
ordinance also prohibits more than one device for each new structure, or one
solid fuel device per multifamily building.
Banning all or certain types of RWC devices in new dwellings will not, by
itself, result in reductions in emissions or ambient concentrations of PM-10
throughout an airshed. A ban that is limited to new dwellings would only
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lessen the rate of increase in emissions resulting from growth of the
community. This effect would be estimated by projecting the number of new RWC
devices that would be installed in the absence of the ban and the emissions
from those new devices. Emissions from the more limited number of devices
installed after implementation of the ban would also be projected. The
difference between these emission rates would be the measure of the
effectiveness of the ban.
Under a total ban, new PM-10 emissions from wood combustion would be
eliminated and there would be no increase in emissions. If the ban only
applies to certain types of RWC devices or to reduce the number of devices in
a dwelling, emissions would still increase as new dwellings are built. The
rate of increase would be lessened, however, because the average emissions per
device and/or the number of devices would be lower in dwellings built after
the ban.
An example of a ban on installation of certain types of devices is the
RWC control program in Washoe County, Nevada. This program includes a
specific provision calling for the elimination or replacement of existing
devices on resale of a residence. When a residence is sold, any uncertified
RWC device must be replaced with one that is certified as complying with
Federal standards. Planners have projected a 5 percent reduction in annual
emissions of particles from residential wood combustion. Because the turnover
rate in home ownership in Washoe County is about 8 percent per year, the
county expects that over a 5-year period, about 40 percent of the housing
stock will have either removed noncomplying heaters or upgraded to clean
burning ones. The assumption is that half of the residential structures will
comply with the provision of the ban by eliminating solid fuel burning
entirely, and that half will comply by using wood heaters that achieve a 75
percent reduction in particulate matter emissions, compared to conventional
uncertified heaters.
In Table 4-1, a PM-10 emission reduction credit of 100 percent is
recognized for each RWC device that is not installed in the community as a
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result of the ban. If the prohibition adopted is against all RWC units, the
credit is for all PM-10 emissions that would have taken place in the absence
of the control program. If only certain types of RVC devices are banned, the
credit extends only to those devices of that type that would have been
installed if the ban were not adopted. The credit recognized for a limit on
the number of devices permitted in each residence would be based on the number
of dwellings with multiple RWC devices avoided as a result of the ban.
4.3 ELIMINATE EXISTING RWC DEVICES
The elimination of wood burning addresses the reduction in particulate
matter emissions from RWC devices by providing incentives for homeowners to
remove or disable existing devices in residences. These program elements have
two advantages in controlling PM-10 emissions. First, the emission reductions
achieved through eliminating existing devices are permanent. They are not
intermittent controls that may continue to add to the PM-10 problem in a
community even if operating at reduced emission rates. Second, these
provisions are readily enforceable. If RWC devices are not removed from a
residence and continue to be operated, they can be readily detected.
There are two program elements that have been identified that can be used
to eliminate existing RWC devices. The first extends the previously discussed
economic incentives to discontinue the use of wood as fuel for space heating
to owners of existing RWC devices. The second would use the local authority's
regulatory power to require at least certain types of RWC devices be removed
from residences and disabled or, in the case of fireplaces, dismantled so they
are no longer operational.
4.3.1 Incentives to Remove and Disable Existing RWC Devices
The incentive program to reduce the number of existing RWC devices and
the incentive program to encourage homeowners to switch to alternative fuels
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(described above in Section 4.1.3) are basically the same program element.
The goals of the programs are stated differently, but the implementation and
results of both program elements are the same.
As with incentives to encourage homeowners and builders to use alterna-
tive fuels in new dwellings, incentives to remove or disable existing RWC
devices in residences can take a variety of forms. Tax credits or deductions
could be offered that would allow the homeowner who removes or disables an RWC
device to recover part of the cost of that change by deducting all or part of
the cost from the state or local tax bill. Alternatively, a grant from the
state or local authority can be provided to defray all or part of the cost to
the homeowner of switching the heating system in the residence to some system
other than wood heat.
Although tax credits and deductions are frequently used as incentives for
obtaining voluntary compliance with a governmental program, establishing these
tax incentives requires the cooperation of the legislative body (whether state
or local). Consequently, establishing the tax and setting the level of
taxation can be a complicated procedure. Similarly, getting funding to
undertake a direct payment program can also require legislative action to
establish the funding required to make the payments. Consequently, although
either measure can be effective in causing RWC devices to be eliminated, they
may have high internal costs to the air quality agency.
There are, at present, no existing programs that provide economic
incentives that are specifically intended to result in the retirement of a
substantial number of existing RWC devices. The effectiveness of any
incentive program that might be established would depend on the level of
incentive offered and the number of device owners who could be persuaded by
that incentive to relinquish their RWC devices. A low level incentive would
have only a marginal effect on the number of devices operating in the
community and, consequently, only a marginal effect on PM-10 emissions. A
higher incentive level (probably substantially higher than the cost of the
conversion to another heat source) could result in virtually all RWC devices
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being removed. Since the need of most localities to reduce PM-10 emissions
will probably fall between these two extremes, the incentive level would
probably need to be set at some intermediate level.
As with the incentive program elements for fuel switching described
above, an incentive program designed to eliminate existing RWC devices would
vary in effectiveness over time, with the greatest impact expected in the
first year and diminishing somewhat in following years. For each existing RWC
device retired and disabled as a result of the incentive program, a credit for
100 percent of the PM-10 emissions from that existing device is recognized in
Table 4-1.
4.3.2 Regulatory Prohibition Against Operation of RWC Devices
The most stringent program element designed to limit the population of
RWC devices is a regulatory requirement banning the use of RWC devices for
residential heating in the community. Such a program element could either be
a total ban on all RWC devices, or a partial ban that would extend to certain
types of devices. In either case, the effect on particulate matter emissions
is immediate and substantial.
A prohibition against RWC devices would eliminate both existing and
future PM-10 emissions from the combustion of wood as a heating fuel. Not
only would such a measure accomplish a complete reduction in emissions, but it
would also be a readily enforceable regulatory measure. The observation of
smoke coming from a chimney or flue pipe could be grounds for an inspection of
the premises to determine if an RWC device is in operation.
A regulation requiring the removal or disabling of existing RWC devices
would be based on the state's authority to regulate sources of air pollutant
emissions. Such a requirement would obviously be a politically sensitive act
by the local authority in any community, and no total bans are currently in
effect. Partial bans on certain RWC devices, most notably fireplaces, have
been implemented in communities such as Telluride and Aspen, Colorado.
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The effectiveness of a ban on RWC devices could be readily estimated.
This measure would reduce PM-10 emissions from the devices subject to the ban
by 100 percent. If the ban extended to all RWC devices, the inventory of PM-
10 emissions from wood combustion would be eliminated. If the ban extended
only to certain types of devices, the portion of the emission inventory
represented by emissions from that type of device would be eliminated. It
should be noted, however, that a partial ban extending only to certain types
of RWC devices may lead homeowners to purchase the remaining devices in
greater quantities. This may result in a reduction in PM-10 emissions,
assuming that the banned devices have higher emissions than the permitted
devices, but would not eliminate those emissions or prevent an increase in PM-
10 emissions over time. Consequently, a partial ban may only be a temporary
measure in communities where a more stringent control strategy is needed.
Table 4-1 describes effectiveness level for a ban on existing RWC
devices. The credit for this program would be 100 percent of the PM-10
emissions from all existing RWC devices removed from residences and disabled.
This credit would extend both to new and existing devices. If only certain
types of RWC devices are covered by the ban, the credit would extend to all
devices of that type that are removed or disabled.
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SECTION 5
CURTAILMENT
Episodic curtailment is the fourth category of control measures available
for reducing PM-10 emissions from residential wood combustion. Curtailment
programs have a very important role in PM-10 SIP's. In its simplest form, a
curtailment program element involves the elimination of wood burning during
periods (episodes) when ambient levels of PM-10 approach or are predicted to
exceed a given level, in this case the NAAQS for PM-10.
Many of the control measures discussed in the previous sections have the
potential for affecting long-term, gradual, and permanent reductions in
ambient PM-10. By contrast, episodic curtailment is best suited for making
short-term, immediate, but significant reductions in ambient levels of PM-
10.1 Episodic curtailment is particularly attractive for meeting the PM-10
ambient standard in those areas where woodstoves and fireplaces emit the most
when dispersion characteristics are the worst--resulting in sharp peaks (often
less than 10 percent of the heating season) of unacceptably high PM-10
concentrations. In areas where there is a persistent problem with wood smoke,
the other control measures will also be necessary. However, in most areas
where the wood smoke problem is characterized by both persistence and peak
periods, a combination of curtailment and one or more of the other methods
would be appropriate. Several programs involve such a linkage. Table 5-1
shows that all curtailment programs have a PA program element that goes beyond
simple notification, and most have program elements to attempt to reduce
overall PM-10 emissions rather than simply address peak ambient problems.
Virtually all PM-10 exceedances result from violations of the 24-hour
standard although in some cases both the annual standard and the 24-hour are
exceeded.
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TABLE 5-1. CURTAILMENT1 AND COMPLEMENTARY PROGRAM ELEMENTS FROM
SELECTED RWC EMISSION CONTROL PROGRAMS
Curtailment
Program
(Mandatory or Voluntary)2
Complementary3
Program Elements
Boise, Idaho (M*)
Butte, Montana (M)
Denver Area (B)
Jackson County, Oregon (V)
Juneau, Alaska (M*)
Lane County, Oregon (V)
Lewis & Clark County, Montana (M)
Missoula, Montana (M*)
Puget Sound APCA, Washington (M)
Washington State (M)
Washoe County, Nevada (B)
PA, SL, P, TS, OL
PA, OL, P
Cert
Cert, PA, grants for income for
replacement
PA, SL
PA
PA, OL
PA, TC, P
PA
PA, Cert, OL, fuel restrictions
PA, Cert, OL, Removal of noncerti-
fied stoves upon sale of residence
1Sources: Radian interview; Batson, 1987.
Mandatory only (M) Voluntary only (V) Both voluntary and mandatory (B)
(M*) Program now mandatory after unsuccessful voluntary program.
3"PA" is public awareness that goes beyond simply notifying public when a
curtailment is in effect.
"SL" is subsidized, low-interest loan for alternative heating devices and/or
clean burning stoves.
"TC" is tax credits.
"P" is permit system.
"Cert" is requiring only certified stoves in new installations.
"TS" is thermal standards or weatherization.
"OL" is opacity limits.
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There is a variety of curtailment program types. They can be either
voluntary, mandatory, or both--depending upon predicted ambient conditions.
Curtailment programs can range from an absolute ban on combustion of all solid
fuels (i.e., all coal and wood fired appliances) to the granting of exemptions
for certain types of appliances (such as certified stoves or sole-source
heaters). .Even the simplest curtailment program must have a means of deter-
mining when to trigger the "no burn" period and a means to notify the public
that a no burn condition is in effect. Finally, a variety of enforcement and
effectiveness monitoring approaches are available.
The following discussion explains how a. curtailment plan can be drawn up,
how the program can be communicated to the public, and how the no burn mandate
is monitored and enforced (for the nonvoluntary programs). This section
concludes with an estimate of the assumed effectiveness of various approaches
to episodic curtailment.
5.1 CURTAILMENT PLAN
In designing a curtailment plan, it is important to carefully consider
the issue of voluntary versus nonvoluntary compliance, the affected area, how
to gain public acceptance, the method of forecasting no burn periods, and the
issue of exemptions. Other aspects of a comprehensive curtailment plan are
discussed in Sections 5.2 - 5.4.
5.1.1 Voluntary Versus Mandatory Programs
Because wood burning has traditionally been regarded as a "right" rather
than a regulated activity, local elected officials are usually reluctant to
impose a mandatory ban on wood burning, preferring instead voluntary no burn
periods. As Table 5-1 shows, of the curtailment programs examined in this
study, two were voluntary only; eight were mandatory only; and one had
elements of both.
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The BPA study assessing wood smoke mitigation measures stated that
voluntary programs, which are unenforceable, do not achieve more than 15 to 20
percent cooperation. Of the seven communities (cited in the study) with
episodic curtailment, five had switched to a mandatory program because of the
apparent ineffectiveness of voluntary programs (38).
The most effective reported voluntary program is Washoe County, Nevada,
(Reno) where the voluntary phase of the curtailment program results in one-
third to one-half of the residents responding positively. One reason for this
high rate of participation may be because the action levels are set high. The
voluntary program is not triggered until the PM-10 level exceeds or is fore-
casted to exceed the NAAQS of 150 Mg/m3 (or 100 PSI2) . At this point, the
visibility is significantly impaired and the public literally se'es the value
of eliminating wood burning.
Overall, the experience suggests that despite its relative ineffective-
ness , a voluntary program could serve several useful purposes. As discussed
below, a voluntary program can be used as a first phase of what may eventually
become a mandatory program (depending upon public response). For example,
officials may introduce episodic curtailment during the first heating season
as a voluntary measure in order to increase public acceptance and as an
incentive to avoid mandatory curtailment in successive heating seasons. If
the public is persuaded through public education efforts to voluntarily
curtail wood combustion during air quality episodes, a voluntary program could
prove to be an end in itself. A voluntary no burn condition can also be used
as the first stage (e.g., a few hours or days) in a period of deteriorating
air quality, leading ultimately to the mandatory no burn phase.
In summary, voluntary programs have the advantages of greater public
acceptance (although there may be some resentment by those who give up wood
burning against those who ignore the no burn requests) and the avoidance of
Pollution standard index, where for any NAAQS 100 equals the NAAQS.
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surveillance and enforcement costs. However, as discussed later, mandatory
programs are more effective.
5.1.2 Affected Area
For the mandatory programs, the affected area should take into account
the concentration of emissions and ambient "hot spots," the ability for
program personnel to monitor and enforce compliance, and the means of com-
munication to individual households.
The curtailment program can be limited to a geographic subset of a larger
program area involving several control measures. For example, although the
Juneau, Alaska, wood smoke control program includes a variety of control
measures, the curtailment program is confined to the Mendenhall Valley where
approximately half the Juneau area population resides and where topographic
and microclimatological features create the highest levels of PM-10 concentra-
tions. Similarly, in Missoula, a mandatory no burn condition is voluntary for
rural residences.
Where a state agency is charged with administering the curtailment
program--as is the case in Washington--the affected area may include several
counties or theoretically the entire state. The Washington statute and
regulations allow for the State Department of Ecology to issue a statewide or
regional "episode" in which all solid fuel burning must cease. However, local
areas, such as the Puget Sound Air Pollution Control Agency, can issue
"impaired air quality" alerts which require all but certified woodstoves to
stop burning.
On the other hand, problems can arise where the jurisdictional area is
smaller than the problem area, as is the case in the Denver Metro Air Quality
Council (DMAQC). The DMAQC is a coordinating agency created by the Governor
to develop the SIP for the Denver area. It includes the areas covered by six
counties and 23 municipalities but has no regulatory authority in and of
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itself. Communication of no burn days, compliance determination, and enforce-
ment becomes complicated when several jurisdictions are involved. The
effectiveness of the Denver area curtailment programs is limited, in part,
because of the variety of jurisdictional approaches within an essentially
common air shed. Some of the communities have no burn days, some do not; some
are voluntary, some are mandatory; and there are varying means of communica-
tion and enforcement techniques. For this reason, there is a proposal to con-
solidate much of the program under the State Department of Health.
5.1.3 Public Acceptance
Officials with programs that have been in effect several years report
that resources and attention to public awareness are vital at the inception of
a curtailment program, but that after the second or third year the need for
public awareness is sharply reduced. These officials also report that it is
essential to focus first on informing and persuading local elected officials
and the local media of the curtailment program's importance and necessity
before broadening the effort to the public.
The success of voluntary curtailment programs is solely dependent upon
public acceptance. In these programs the public must be convinced of the need
to make an individual sacrifice for a public good (healthier air for the
community at large). Therefore, an effective public education program is
essential.
For the mandatory programs, public acceptance is also important for at
least two reasons: first, curtailment involves the giving up of what has been
commonly regarded as a right -- burning wood for space heating. The sacri-
fice, although temporary, may last several days and often comes at a time when
the demand of wood heating may be the greatest. Even if the public is forced
to grudgingly go along with the program under threat of fines and penalties,
the community's elected leaders may eventually be pressured to eliminate the
program. Second, a popular program can create a form of peer pressure against
noncompliance that is more thorough and less costly than organized patrolling
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and surveillance. It is common for neighbors to resent being forced to comply
with a no burn requirement while a careless or uncaring neighbor pollutes the
air. A form of peer pressure develops to reinforce the exhortations from
program officials. This may also result in the reporting of these violations
-- often anonymously --by neighbors.
Public acceptance can be achieved by a PA and education program element,
a phase-in of curtailment program elements, and the provisions of wood-burning
alternatives for areas where episodes are frequent and/or lengthy. The
latter, alternative wood-burning provisions, are discussed in the "Exemptions"
f
section.
'5.1.3.1 Public Awareness--
Whether the program is voluntary or mandatory, it is important to inform
the public why it is being asked to sacrifice their previously unrestricted
right to burn wood. (See Section 2 of this document for a more detailed
discussion on PA program elements.) The messages may include the following
themes and content:
1. There are health threats of particulates, including the carcinogenic
properties of polycyclic organic material and carbon monoxide and
the link between these pollutants and wood burning. The Washington
State program has developed a very effective approach based on the
toxics concern and the issue of indoor air quality.
2. The true economic costs of wood burning may be much higher than most
people realize. It is important to provide consumers with a means
(1) to calculate the actual costs of wood burning (including the
value of homeowner's time for cutting and hauling wood, ash dis-
posal, etc.) and (2) to compare this with alternative heating costs.
3. Citizens need to comply with the PM-10 standard and the legal
sanctions that could be imposed on the community if effective
measures are not implemented and enforced.
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4. It is essential to provide details on how the program will work.
The first message should help generate voluntary acceptance by establish-
ing the need to control wood smoke emissions. The emphasis of the public
education program element should be on the health and welfare benefits of
reduced wood smoke levels during episodes. The second message may help
residents be more tolerant of curtailment and can provide them with data that
will allow them to make an informed decision as to whether they should convert
to an alternative heating source.
The third message informs the public that episodic curtailment is not a
unique nor experimental program confined to their community, but rather it is
a response to a national ambient standard that has been selected because of
technical review and reasoned analysis. Finally, the fourth message--informa-
tion about how the program will work--will promote acceptance because it will
counteract the inevitable rumors that will occur in the absence of good
communication. A description of how the program will work is particularly
important if there are exemptions for sole-source heaters and/or certified
stoves or if there is a phase-in period.
5.1.3.2 Phase-in of Program Elements--
Program officials in several localities believe that a phased-in approach
(rather than a sudden imposition of a curtailment program) has long-term
benefits in public acceptance despite the temporary delays in program effec-
tiveness.
The most common phase-in is the voluntary-to-mandatory transition. The
phasing-in of a mandatory program has several advantages. First, it allows
program officials to establish the forecasting, communication, and effective-
ness monitoring elements without having to worry about the logistics and
political controversy surrounding surveillance and enforcement. Second, if
the voluntary program is sufficiently effective to reduce ambient levels
adequately, it may not be necessary to move to a mandatory phase. The public
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education program element should communicate to the public that if voluntary
compliance is successful, there will be no mandatory phase. Therefore, if it
is necessary to go mandatory, there should be greater acceptance because it
will be apparent that the voluntary approach did not work due to an insuffi-
cient response from the public.
In addition to or instead of a voluntary-to-mandatory phasing, the
curtailment "action point" can be set such that only during the first heating
season relatively few curtailments result. The next season the action point
can be set lower (e.g., from a predicted 150 Mg/m3 to 100 Mg/m3)
Finally, as discussed below, penalties can be phased-in. This is usually
accomplished by establishing a graduated set of penalties based upon frequency
of violation. For example, a first offense merits a warning ticket; a second,
a $50 fine, and the third and subsequent offenses, $150 fines. The warning
ticket approach can also be an occasion for public education by having the
enforcement personnel distribute pamphlets on the need for the program and the
importance of compliance. This has been effective in Juneau.
5.1.4 Forecasting Episodes
An effective program requires that forecasted meteorological conditions,
existing ambient levels, and ambient trends be taken into account in order for
local officials to accurately call an air pollution alert. The pollution
alert triggers the no burn mandate or, for voluntary programs, request.
Forecasting should provide enough lead time to communicate to the public and
thus avoid the high ambient levels but should not be so premature as to result
in "false alarms," which could adversely affect the credibility and accep-
tability of the program.
Local officials with successful programs report that episode forecasting
skills improve with time. Also, the public becomes sensitized to conditions
that accompany air pollution emergencies and therefore is often able to
presume when the episode is occurring. At a minimum, the forecasting of
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potential episodes of unacceptably high ambient levels requires access to
weather forecasts and the real-time monitoring and reporting of PM-10 ambient
levels in the affected areas.
5.1.4.1 Weather Forecasting--
Local program officials should maintain frequent contact with the
National Weather Service or other appropriate weather forecasting entities
that can determine whether a temperature inversion and conditions favorable to
poor dispersion will occur. The Washington State program does not impose a
mandatory curtailment until the State meteorologist declares that an air
stagnation is in effect, although local programs can use other criteria and
methods.
5.1.4.2 Ambient Monitoring --
A system of ambient monitoring of PM-10 levels is also necessary. Many
programs use nephelometers or beta gauges as a basis for declaring a curtail-
ment. These have the advantage of providing real-time data. Others use PM-10
reference monitors, which although more accurate, may create delays in calling
for a curtailment. Nephelometers, which measure the light scattered by
particles in a sample volume of air, have been shown to be accurate in the
range of very fine particles (0.1 to 1.0 urn's) which includes much of the
range for RWC particles. Colorado measures CO as a surrogate indicator (and
because CO nonattainment is more of a problem).
Some areas, such as Washoe County, use reference PM-10 samples for
official determinations together with beta gauges for hourly readings as an
aid in forecasting or to trigger an "action point."
5.1.5 Action Points
All of the curtailment programs have to be triggered by some level of
deterioration in air quality called an action point. In some programs,
curtailments are triggered by the deterioration of air quality to a certain
level plus a prediction by a meteorologist that an air stagnation condition
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will persist for at least 24 hours. Some programs have several action points:
one for implementation of voluntary curtailment, another for when an official
may (i.e., at his or her discretion) call for mandatory curtailment, another
when mandatory curtailment must go into effect, and perhaps another phase of
mandatory curtailment when no exemptions are allowed and all solid fuel
burning must cease.
The stringency and the effectiveness of a curtailment program is based,
in part, upon the action point. A high action point -- one at or near the PM-
10 standard -- will have the advantage of requiring fewer curtailments and may
have more public support because the necessity of curtailing burning will be
more obvious. However, a high action point is less likely to avoid an
exceedance of the standard because the margin between the action point and the
standard is narrow. A lower action point, for example at 50 to 70 percent of
the standard, will create more curtailments. However, it will, if adequately
enforced, provide greater assurance of avoiding an exceedance of the standard,
and (because moderately high ambient levels are avoided) will result in
generally cleaner air. Table 5-2 lists some of the action points used by some
of the programs. Note that four of the programs listed have two action
points. The first number is for the first stage (a less stringent, perhaps
voluntary stage) and the second action point is for the second stage (a more
stringent stage that may not allow exemptions).
5.1.6 Exemptions
Exemptions from mandatory curtailment serve two purposes: (1) humani-
tarian and (2) as an incentive to replace a relatively high-emitting appliance
with a cleaner burning one. Table 5-3 presents the exemptions and criteria
for various curtailment programs.
5.1.6.1 Exemptions for Sole Source Heaters and Economic Hardship - -
Many of the homes in this country are heated exclusively by wood burning
and many use wood as a primary source of heat. Many of these households are
low income and thus, unable to easily convert to an alternative fuel.
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Therefore, it may be appropriate to include either a permanent or temporary
exemption for sole source wood heaters for humanitarian reasons. Washoe
County provides for a sole-source exemption that is scheduled to phase-out two
years after the initiation of the program. Other programs provide for
demonstration of hardship exemptions such as low income.
To avoid circumvention (i.e., someone getting rid of their backup or
alternative heating source in order to qualify for this exemption), the
exemption should apply only to those dwellings that are sole source as of a
given date, such as the date that the program is established. It may also be
necessary to require that if the house with the exempted device is sold, the
house must be equipped with a backup heating system. If a wood-heating survey
is conducted in the community as a means of estimating wood smoke emissions
(see Appendix A), it may be worthwhile to include questions relating to backup
heating devices in order to estimate the number of sole source wood heaters in
the community. Finally, the program officials should consider distinguishing
between sole source heaters at dwellings that are a principal residence and
those that are used for recreation purposes such as hunting cabins.
The use of sole-source exemptions not only serve a humanitarian purpose
but they promote public acceptance by the community at large. There is a
widespread concern that by banning residential wood combustion, families may
go without heat. The use of a sole-source exemption can defuse this argument
against episodic curtailment.
5.1.6.2 Exemptions for Clean-Burning Appliances--
An exemption from the no burn mandate is often made for wood-burning
appliances that have demonstrated that they are low emitting. Most programs
that use this approach grant an exemption to wood heaters that have been
certified by either a state program (Oregon or Colorado) or are certified
under the U.S. EPA's NSPS wood heater certification program. Some programs
link the exemption with an EPA Phase II certification; some require that the
emissions be below a certain level based upon certification test results.
Others, concerned about the apparent discrepancy between certification
5-14
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laboratory results and in-field performance, are considering limiting the
granting of exemptions to a subset of certified stoves believed to have
superior in-use emissions control performance. Finally, certain types of
wood-burning appliances such as pellet stoves or open fireplaces may be
exempted.
There are two advantages to the clean burning appliance exemptions and
two potential disadvantages. The advantages of creating these exemptions are
(1) it enhances public acceptability by making it possible for some households
to continue burning wood without creating the impacts if they were using a
conventional wood heater, and (2) it creates an incentive to replace relative-
ly high-emitting conventional stoves with lower emitting catalytic or high-
technology noncatalytic stoves. Thus, the curtailment program, which has as
its goal the elimination of peak ambient loadings of woodsmoke, can also be
used to create an incentive to reduce overall average emissions by speeding up
the normal replacement rate of older stoves with newer cleaner burning stoves.
One disadvantage to the practice of granting clean-burning exemptions is
that this creates the need for a permit or other tracking system in order to
ensure that (1) the dirty stoves are removed, (2) the new stoves meet NSPS
requirements, (3) the stoves have been properly installed, and (4) the stoves
continue to perform as clean-burning appliances in order to continue to
qualify for the exemption. Areas with extreme air quality problems may not be
able to grant clean-burning exemptions if they are to attain air quality
standards and protect public health.
In order to ensure that the exempted stoves continue to perform as clean-
burning appliances, exemptions should be contingent upon a periodic main-
tenance inspection of a licensed or certified inspector. This would consist
of an inspection of the stove's general condition, including the gaskets,
doors and bypass dampers, and the periodic replacement of the stove's
catalyst, if applicable.
5-15
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Under a permit approach, permitted stoves are allowed to continue to burn
during the curtailment episodes. If a homeowner is challenged by a neighbor
or an enforcement officer for having smoke emitting from the chimney, he could
produce a permit to show that he had been exempted. In practice, this is
rarely a problem because police dispatchers or other central recordkeeping
offices can maintain a list of permitted appliances. If the permit is
renewable, the expiration of the old permit can serve as an opportunity for
building inspectors or chimney sweeps to certify that the unit is still in
apparent good working operation (e.g., catalysts continue to light off, no
warping, rope insulation in place, etc). This use of police dispatchers
becomes impractical in large communities.
The second problem with exemptions for clean burning appliances is that
over time, the effectiveness of curtailments for reducing peak ambient condi-
tions will diminish as more and more households are exempted from the no burn
mandate. This, however, can be addressed by establishing a staged program:
Stage l--no burn except for permitted stoves; and Stage 2--no burn except for
designated sole-source heaters.
There appears to be a general consensus that the types of exemptions
should be kept to a minimum. In particular, if the objective is to avoid
violating the standard, exemptions for certain solid fuel burning devices such
as those exempted under the NSPS (i.e., coal stoves, wood burning cookstoves,
furnaces, and fireplaces) should be avoided (31). In summary, if exemptions
are to be permitted, they should be confined to either a small subset of clean
burning devices or based on economic hardship. Otherwise, it is important
that the curtailment apply to all solid fuel-burning appliances (particularly
if coal burning is also a problem).
5.1.7 Adopting the Plan
When the state or local community has evaluated the factors described
above and has developed a program plan for episodic curtailment, the plan--
particularly those that involve mandatory actions--is adopted by an elected
5-16
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body (legislature, county commissioners, or city council). Appendix C
includes the ordinances and statutes from most of the programs cited in this
section.
5.2 COMMUNICATION STRATEGY
Once the design of a curtailment plan is accomplished and the issues of
program scope are resolved, details -- such as how to notify the public of no
burn conditions -- must be addressed. This section addresses the external and
internal communications. External communication is notifying the public that
a curtailment is in effect. Internal communication is the notification of
program officials and enforcement personnel that curtailment conditions exist.
5.2.1 No Burn Notification Procedures
Once the decision is made to declare a voluntary or mandatory no burn
period, there must be an effective means of communicating this to the affected
public. Approaches used include radio and television announcements, newspaper
announcements, the use of road signs, and a continuously running tape on a
special telephone hotline. Table 5-4 presents the various notification
procedures in use.
5.2.1.1 Radio and Television Announcements--
Use of the electronic media to announce a curtailment provides the
advantage of immediacy. Some programs provide local radio and television
stations with taped announcements that can be used depending upon the stage of
curtailment. The text of a prerecorded message from the Juneau program is
provided in Figure 5-1. The use of prerecorded tapes ensures that the
messages will be accurate and consistent.
5.2.1.2 Newspaper Notices--
If the local community is served by a daily newspaper and if the decision
to invoke a curtailment can be communicated to the newspaper before the
newspaper's deadline for the evening edition or next morning's edition, the
5-17
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TABLE 5-4. METHODS OF NOTIFYING RESIDENTS OF NO BURN CONDITIONS
Program Location
Notification Method
Boise, Idaho
Butte, Montana
Juneau, Alaska
Lewis & Clark Co.,
Montana
Washoe Co., Nevada
Hotline
Newspaper
TV and radio
Hotline
TV and radio
Newspaper
Hotline
Newspapers
10 folddown road signs
Radio and TV PSAs
Hotline
Radio & TV PSAs
Newspaper
Uses red/yellow/green symbols in newspaper
Radio and TV
Hotline
5-18
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AIR ALERT 10/22/86
This is the Juneau Police Department. Due to the temperature inversion which
* v
continues to exist in the 'Mendenhall Valley/ the City and Borough of Juneau
has issued an Air Alert effective immediately. The Air Alert means that the
burning of all solid fuel fired heating devices is prohibited except for those
persons with Class I certified wcodstove permits. Additional information may
be obtained by calling 586-5225 Monday through Friday between 8 a.m. and 4:30
p.m. Thank you.
AIR EMERGENCY
This is the Juneau Police Department. Due to the temperature inversion which
continues to exist in the Mendenhall Valley, the City and Borough of Juneau
has issued an Air Emergency effective immediately. The Air Emergency means
that the burning of all solid fuel fired heating devices is prohibited in-
cluding those with Class I certified wcodstove permits. Additional information
may be obtained by calling 586-5225 Monday through Friday between 8 a.m. and
4:30 p.m. Thank you.
STANDARD AIR ALERT/AIR EMERGENCY CANCELLATION
This is the Juneau Police Department. Effective immediately, the air alert
for the Mendenhall Valley has been cancelled. Woodstoves may be used but may
not produce an exhaust plume which exceeds 50% opacity. Please use your driest
wood and open the damper on your wcodstove to reduce smoke emissions as much
as possible. Open burning continues to be prohibited. Thank you for your
cooperation.
Figure 5-1. Text of pre-recorded message from the Juneau Program.
5-19
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use of a canned notice, which could accompany the weather forecast, can be
effective. Although lacking the immediacy of electronic media, newspapers can
reach some people who do not listen to radio or watch television and can
provide a more official record of an announcement. The Washoe County program
has worked out an approach with the local newspaper to indicate each day on
the front page ambient air quality and curtailment status.
5.2.1.3 Road Signs--
Some communities have established permanent signs that are hinged and
locked shut during periods when there is no episodic curtailment. When the
curtailment is invoked, a city crew is dispatched to open up the signs that
announce that a curtailment is in effect.
5.2.1.4 Telephone Hotline--
The most essential notification element is a telephone hotline where
residents can call to get a constantly updated recording that will inform the
caller whether curtailment is in effect. The message may be combined with a
weather forecast and/or a forecast of air quality conditions. To accommodate
several callers at once, most telephone companies provide a service whereby
simultaneous messages can be communicated through multiple lines.
As noted earlier, residents in areas that have experienced severe air
quality problems associated with woodsmoke pollution know, or at least
strongly suspect, when conditions exist that will create these problems. If
they do not see the signs or hear the radio messages and if they suspect that
a curtailment may be in effect because of reduced visibility or cold, still
conditions, they can call the hotline to confirm their suspicions. An example
of a taped message is provided in Figure 5-1.
A simple and graphic way of communicating to the public when a two-staged
curtailment program is in effect is to use a system of color notices: green
(okay to burn), yellow (either voluntary or partial mandatory curtailment),
and red (mandatory or most stringent curtailment in effect). The three
periods can be easily communicated because of the familiar analogy to a
5-20
-------
traffic light. A copy of the Reno daily newspaper with its graphic presenta-
tion of pollution and curtailment levels (which appears each day throughout
the heating season) is shown in Figure 5-2.
5.2.2 Internal Communications
Internal notification that an episode exists should be based on an
emergency episode plan. Unlike the program planning, which is the process of
deciding what kind of curtailment program to implement (Sec. 5.1), the
emergency episode plan is a brief action-oriented document that designates
responsibilities, actions, and associated time frames. The plan may include
the following components: a brief description of the overall curtailment
program, a description of each stage and the action points associated with
each stage, and the means of public notification. These plans may also
include surveillance and enforcement procedures. (Some guidance and an
illustrative ordinance for dealing with emergency episodes can be found in 40
CFR 51, Subpart H and Appendix L.)
The key to the development of a good planning document is that it clearly
sets out who should do what, when, and under what conditions. At the beginn-
ing of each heating season, those concerned in implementing the plan--air
quality staff, police, building inspectors, news media representatives, etc.,
should meet to review their respective roles.
Both internal and external communications should be simple, direct, and
routine.
5.3 SURVEILLANCE
This section presents two kinds of surveillance, discusses the issues of
nighttime surveillance, and the timing of surveillance relative to the
initiation of the curtailment.
5-21
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RenoGazel
Tuesday
January 17, 1989
35 cents
Sunny, high 44, low 21
CMnpMt OTMhvraport. pag* 10A
CM9 150-99 100-149 150-199 200-299
Story: Miners' Walsh
(flits after Super Bowl
MIAMI - Bill Walsh has decided to
retire from coaching the San
Francisco 49ers and will announce his
decision within 48 hours after next
Sunday's Super Bowl, a published
interview with team owner Eddie
DeBartolo said today.
"He just wants to wait till after the
season's over," DeBartolo said in an
interview published in the San
Francesco Chronicle.
"He's told me that. Basically, he's
told (the media), too. I really believe
that Monday, probably, or maybe
Tuesday, at the latest, he'll (make an
announcement)."
DeBartolo put at no better than 20
percent the odds that Walsh would
coach the 49ers again in 1989, the
Chronicle said.
"If I had to guess again, I'd think
that Bill would want to take some
time off (from coaching), win or lose.
The outcome of this game Sunday has
nothing whatsoever, in my opinion, to
do with his decision," DeBartolo said.
Related story, page 2B.
Unhealthy skies 1
Conditions expected
to persist until Friday
By Sutwi Skonipa/o*
A strong, high-pressure system over the
Reno-Sputa area has pushed today's
erpurted air quality into the unhealthful
range, and no relief is in sight until Fri-
day.
"It looks doubtful there'll by any (sig-
nificant) wind before then," said Tom
Cylke of the National Weather Service in
Reno. "We could have something move in
Friday into Saturday
out"
Forecasts for the
today call for sunny si
clouds, light winds
degrees. Wednesday's
sunny sties with big
Washoe Distn
meat's air quality ran
low. Area residents ar
or stop wood burning
ride Citifare if possit
door activity, such s
advised.
Residents in home
Bush eyes
Educators flex muscle
Figure 5-2. Newspaper notification in Washoe Co.
5-22
-------
Surveillance is the act of observing individual households to determine
whether or not the public has responded to the notice that a curtailment is in
effect. Two types of surveillance are windshield surveys and citizen com-
plaints. Depending on whether the program is voluntary or not, the surveil-
lance may be followed by enforcement actions. For voluntary programs,
occasional surveillance is important to determine the effectiveness of the
voluntary effort.
Surveillance may be accomplished by "windshield inspections" conducted by
police or other personnel during the day or by specially trained observers or
special devices and training for detecting nighttime emissions. Windshield
inspections may be accomplished by requiring police on routine neighborhood
patrols to watch for smoke plumes from chimneys during no burn periods. If a
plume is detected the police may decide to radio the dispatcher to inquire
whether the house is entitled to burn by virtue of a sole source or clean
burning appliance exemption before instituting enforcement actions. If the
city is large enough to have a full-time zoning enforcement or building
inspection staff, these personnel may be used in lieu of or in addition to the
police for surveillance purposes.
Advantages of using police rather than other city or county staff are
that (1) police can combine surveillance and enforcement, since they are
trained and legally empowered to issue citations and make arrests, if neces-
sary; and (2) police have access to a 24-hour dispatcher who can receive
complaints from residents about violations of the curtailment. However, the
disadvantage of using police is that police consider wood smoke complaints and
violations to be of lower priority than their other responsibilities. Also,
police may lack the technical ability of health department staff or building
inspectors to counsel residents on the health effects of woodburning, safety
considerations associated with improper installations, and how to improve
wood-burning efficiency.
As noted earlier, leads on probable noncompliance often originate by
citizens who complain, usually anonymously. Table 5-5 shows various means by
5-23
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TABLE 5-5. METHODS OF SURVELLIANCE FOR IDENTIFYING CURTAILMENT NONCOMPLIANCE1
Program Who Conducts
Location Surveillance2 Comments
Boise C.C.
Butte Staff
Jackson Co. None
Juneau C.C., police and Used dog catchers at one
staff time.
Missoula C.C., staff
Puget Sound C.C., off-duty
firemen, staff
Washoe Co. C.C., staff Health dept. staff deployed
in 15 two-man teams.
Lewis & Clark Co. C.C., police staff
1Sources: Radian interviews; Batson, 1987.
2C.C. - citizen complaints.
Staff - staff of local air pollution or health agency.
5-24
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which curtailment violations are observed and reported. Citizen complaints
are the most common form of surveillance.
Most woodburning occurs at night when temperatures are coldest and
residents are home to enjoy the esthetics of a wood fire. This creates a two-
fold problem for surveillance. First, the availability of potential staff to
conduct surveillance is less because most government employees work during the
day. Second, nighttime woodburning is also more difficult to detect and
therefore may require special training or the use of special equipment such as
spotlights. However, some program officials, such as in Washington State,
report that in most urban and suburban areas nighttime emissions are not
difficult to detect even without special training or equipment. Some surveil-
lance has been attempted through the use of infrared cameras (22).
Finally, most programs have taken into account the fact that once a
curtailment is declared, it is not possible to immediately extinguish fires
and thereby immediately eliminate smoke emissions. Therefore, a one to three
hour grace period is allowed in order for the fires to burn down. For this
reason, surveillance and enforcement should not commence until the grace
period is over.
5.4 ENFORCEMENT
Although related to surveillance, enforcement is the act of officially
charging violators with noncompliance. Most enforcement schemes rely on a
graduated series of penalties increasing with repeat offenses. In some
programs the slate is wiped clean at the end of the heating season. In
others, the accumulation of penalties occurs over a period of years.
As Table 5-6 indicates, fines often are generally set at a level (i.e.,
more than $10) that overcomes whatever marginal economic benefits there may be
for burning wood versus alternative fuels. This is important, otherwise it
would be cheaper to pay the fines.
5-25
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TABLE 5-6. PENALTIES AND DISINCENTIVES FOR NONCOMPLIANCE
Program
Location
Butte
Juneau
Lewis & Clark Co.
i
Missoula
Puget Sound
Washoe Co.
Yakima, Washington
1
2
3
1
2
1
2
3
1
2
3
1
2
3
1
2
1
2
3
4
Fine
Schedule
- $25
-*$50
- $100 - 500
- $50
- $500
- $25
- $50
- $75
- $20
- $50
- $100
- $50
- $100
- up to $1000
- $100 - 250
- $200 - 500
- None
- $25
- $50
- $100
Other
Disincentives/Comments
Have to appear in police
court.
Violators names listed in
newspaper.
All are criminal violations.
Court appearance required.
Uses highly publicized
enforcement teams in marked
vehicles .
5-26
-------
On the other hand, most of the programs do not immediately begin issuing
fines. Instead, there seems to be a progression from a voluntary program to a
mandatory program with an emphasis on warning tickets during the first several
months of mandatory curtailment.
Program officials have increased the effectiveness of their program by
securing the cooperation of news media to publicize the enforcement efforts.
Program officials report that where publicity accompanies an enforcement
effort--such as the publication of the names of persons issued notices of
violation--the deterrent effect is significantly increased at little extra
cost to the program. The most extreme form of this is in Washoe County, where
television crews follow staff vehicles with their flashing yellow lights to
the homes of curtailment violators.
This penalty-by-publicity approach requires that program officials
secure the support of the local news media and the general public. This can
be accomplished by briefings and one-on-one sessions with newspaper editors
before program implementation.
Most jurisdictions issue Notices of Violations (NOVs) similar to traffic
tickets. Some can be paid by mail; others require court appearances. An
example of the form used in Lewis and Clark Co., Montana, is provided in
Figure 5-3. In the Puget Sound program, the NOVs are sent by mail rather than
given to the violator on the spot. The reason is twofold: (1) it avoids the
possibility of a violent confrontation between the violator and the staff
person or police officer, and (2) it allows the persons performing the
surveillance to cover more ground and write more tickets.
In general, there seems to be a consensus that: (1) a program that is
mandatory, with sufficient staff to conduct surveillance and enforce, and with
penalties high enough to overcome the benefits of woodburning is effective;
and that (2) it only requires a relatively small amount of enforcement effort
to yield a good response.
5-27
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IN THE JUSTICE COURT OF THE STATE OF MONTANA
IN AND FOR THE COUNTY OF LEWIS AND CLARK
Before the Justice of the Peace
LEWIS AND CLARK COUNTY,
Plaintiff,
-vs-
No.
OMPLAINT
Respondent.
The above Respondent is charged with violating Lewis and Clark
County Clean Air Ordinance by operating a wood, paper or coal burning
device during a "Poor" air quality state; or
(explain)
Filed this
day of
19
(SignaFure of inspector!
On this day of __ , 19 , this
complaint was presented to me a~n3~tTfe c o~m pTa inant under oath swear s
that the charges are true.
(Signature of Judge or Notary)
NOTICE TO APPEAR
TO:
(Violator's name^acTdTe'ss;phone numETer & firm name & address, FTany)
Notice is hereby given that the Respondent named in the foregoing
Complaint is to appear before the Justice of the Peace, at the Lewis
and Clark County Courthouse in Helena, Montana, on or before the
dav °f ____ , ' I9, » at tne hour of 8:30 a.m.
or 3T8TB p.m., to answer" th~e foregoing violation complaint.
Failure to respond may result in a warrant being issued against
the Respondent and a penalty being imposed pursuant to 75-2-412 MCA.
Dated at Helena, Montana, this
_ day of
19
Received this
day of
(Inspector)
, 19
(Signature ot Respondent)
Figure 5-3. Example of violation notice form used in Lewis and Clark County.
5-28
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5.5 PROGRAM EFFECTIVENESS/CREDITS
A few programs have developed data indicating the effectiveness of their
voluntary and mandatory programs. The most convincing data are those that are
derived from several seasons of ambient air quality data (such as excursions
over a heating season, peak values before and after program) from areas where
wood smoke is known to be the only or predominate factor in high PM-10 values.
Table 5-7 presents effectiveness data from several programs including those
from Juneau and Missoula which appear to meet the criteria stated above.
Tables 5-8 and 5-9 present the recommended features for acceptable
voluntary and mandatory curtailment program elements. Effective voluntary and
mandatory curtailment programs should provide for regulatory authority,
planning, and resources to implement the program features listed in Tables 5-8
and 5-9, respectively. Because each community is unique in some aspects of
its air quality problem and level of public support, it is neither possible
nor prudent to prescribe a curtailment program in detail. The circumstances
in each particular community may dictate emphasis or de-emphasis of specific
features.
Table 5-7 contains reported curtailment program effectiveness levels.
The data are limited and there is variability in the reported effectiveness
among programs. Nonetheless, the table provides useful information. Based on
knowledge of these specific programs and their strengths and weaknesses, the
technical review committee determined that a credit of 10 percent would be
given voluntary curtailment programs and 50 percent credit would be given to
mandatory curtailment programs. In particular, it was noted that the Washoe
County Health Department's highly effective program had a trigger level well
above the PM-10 NAAQS when these effectiveness data were taken. This is
likely to foster unusually high public cooperation because the concentrations
are high enough to be of aesthetic, as well as health concern. The Juneau
effectiveness is based only on improvements in monitored concentrations and
factors other than wood stove curtailment could contribute to that improve-
ment. The credit for mandatory fireplace curtailment was set at 60 percent.
The technical review committee based this credit in part on the fact that, in
5-29
-------
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5-30
-------
TABLE 5-8. RECOMMENDED FEATURES FOR A VOLUNTARY CURTAILMENT PROGRAM ELEMENT
Program Feature
Discussion
Public Awareness
S taging/Phas ing
Prediction of when to call
the curtailment
Where to set action point
Notification to public that
a curtailment is in effect
Exemptions
Surveillance/Enforcement
Tracking
Vital for success of program. Should be at a
level similar to the Level II example in Section
2 of this document. Should be strong on
persuasion.
Not necessary or appropriate.
Use of both air quality data and meteorological
data. Air quality data should include at least
one real time (i.e., hourly) monitor --
preferably a beta attenuation monitor.
Level should avoid an exceedance of the
standard by setting action point at below
150 /ig/m3.
Should use hourly trend data to make
preemptive call.
Should avoid high (>15) number of calls
during a season in order to avoid a
disgruntled, and therefore less responsive,
public.
Local media (all TV/radio stations and
daily paper).
Telephone hotlines.
If no local media, conspicuous signs.
Sole source.
Low income.
EPA Phase II certified stoves (only in
certain situations).
No enforcement but there should be some effort
to identify and, at least occasionally, notify
those who appear to be disregarding the
voluntary curtailment.
Before and after windshield surveys (counts of
smoking chimneys) in order to determine actual
effectiveness.
Effectiveness
Assumed to be 10 percent of all RWC devices
affected (i.e., after application of other
control measures and elimination of
exempted devices).
If tracking shows higher effectiveness
data, these data may be used in subsequent
years.
5-31
-------
TABLE 5-9. RECOMMENDED FEATURES FOR A MANDATORY CURTAILMENT PROGRAM ELEMENT
Program Feature
Discussion
Public Awareness
Staging/Phasing
Prediction of when to
call the curtailment
Where to set action
point
Notification to public
that a curtailment is in
effect
Exemptions
Needed for success of program. Should be at a
level similar to the Level II example in Section
2 of this document.
Staging. Could make program progressively
more stringent (e.g., lower action points,
stiffer fines, more aggressive enforcement,
etc.) with each season in order to get
public accustomed to program. Or could
make voluntary program a first stage.
Phasing. Should include two phases tied to
exemptions (if exemptions are allowed).
First phase allows exempted units to
continue burning; second phase requires all
but economic hardship units to stop
burning.
Use of both air quality data and meteorological
data. Air quality data should include at least
one real-time (i.e., hourly) monitor --
preferably a beta attenuation monitor.
Level should avoid an exceedance of the
standard by setting action point at below
150 /ig/m3.
Should use hourly trend data to make
preemptive call.
Should avoid high (>15) number of calls
during a season in order to avoid a
disgruntled, and therefore less responsive,
public.
Local media (all TV/radio stations and
daily paper).
Telephone hotlines (with multiple lines if
necessary to accommodate calls).
Sole source.
Low income.
EPA Phase II certified stoves (only in
certain situations).
(Continued)
5-32
-------
TABLE 5-9. (Continued)
Program Feature
Discussion
Surveillance/
Enforcement
Tracking
Effectiveness
Provide for nighttime enforcement by having
equipment and personnel necessary to spot
nighttime burning.
Encourage citizen complaints.
Publicize enforcement efforts to ensure
that public is aware that enforcement is
occurring and to "shame" violators.
Levy fines that are high enough to
discourage woodburning. For most
communities $50 first time offense, $75 and
$100 for subsequent violations is
sufficient.
Before and after windshield surveys (counts
of smoking chimneys) in order to determine
actual effectiveness.
Compare level of ticketing with program
effectiveness to ensure that enforcement
effort has "teeth" in it.
Assumed to be 60 percent of all fireplaces
and 50 percent for all stoves affected
(i.e., after application of other control
measures and elimination of exempted
devices).
If tracking shows higher actual
effectiveness data, these may be
substituted for future years.
5-33
-------
their experience, fireplace users were potentially more cooperative with
curtailment programs than are wood stove users.
These credits are presumed appropriate if the program features in Tables
5-8 and 5-9 are reasonably well addressed. If a program is particularly
strong in regard to these features, it may justify a higher credit, converse-
ly, inadequate consideration of these program features may warrant a credit
lower than those listed.
5-34
-------
SECTION 6
REFERENCES AND SOURCE MATERIAL
6.1 LIST OF PERSONAL CONTACTS
Much of the information presented in this document is based primarily on
informal telephone interviews with state/county/city officials who administer
their PM-10 programs. Table 6-1 provides the names of the officials inter-
viewed, the names and geographic locations of their agencies, and the date of
the interviews. The reference number for each interview corresponds to the
reference number cited elsewhere in this document.
6.2 WRITTEN REFERENCES
Table 6-2 is a list of source material - exclusive of personal
interviews - that is cited elsewhere in this document. The reference number
for each source material corresponds to the reference number that appears in
the text.
6.3 BIBLIOGRAPHY
Table 6-3 lists printed material related to PM-10 and RWC topics but was
not used as reference material in this document.
6-1
-------
TABLE 6-1. LIST OF PERSONAL CONTACTS
Reference
Number Contact
1 Banner, B. Okanogan County Health District, Okanogan,
Washington, 13 January 1989.
2 Bashian, B. Fresno County Air Control District, Fresno,
California, 11 January 1989.
3 Bateman, B. Bay Area Air Quality Management District, San
Francisco, California, 10 January 1989.
4 Bonderson, N. Auburn County Air Pollution Control District,
Cloverdale, California, 6 January 1989.
5 Church, S. Missoula City/County Health Department,
Missoula,Montana, 16 December 1988.
6 Crank, B. and J. King. Town of Crested Butte, Crested
Butte, Colorado, 1 January 1989.
7 Drabeck, J. Department of Ecology Air Programs, Redmond,
Washington, 21 December 1988.
8 Fackrell, J. City Housing Department, Boise Idaho, 20
December 1988.
9 Gilbertson, S. and T. Chappie. City Borough of Alaska,
Juneau, Alaska, 10 January 1989.
10 Golden, K. Washoe County Health Department, Reno, Nevada,
19 January 1989.
11 Hardeback, E. Great Basin Unified Air Pollution Control
District, Mammoth Lakes, California, 10 January 1989.
12 Johnson, R. Lane County Air Pollution Control Agency,
Springfield Oregon, 29 December 1988.
13 Jordan, C. Tahoe Regional Planning Agency, Lake Tahoe,
California, 13 January 1989.
14 Kuyper, B. Denver Metro Air Quality Council, Denver,
Colorado, 4 January 1989.
(Continued)
6-2
-------
TABLE 6-1. (Continued)
Reference
Number Contact
15 Larson, R. Butte-Silver Bow Health Department, Butte,
Montana, 21 December 1988.
16 Maykutt, N. Puget Sound Air Pollution Control Authority,
Seattle, Washington, 17 January 1989.
17 Mileham, M. Oregon Department of Environmental Quality,
Portland, Oregon.
18 Morgan, W. Northern Sierra Air Quality District, 10 January
1989.
19 Nelson, B. and L. Cassin. Aspen/Pitkin County Environmental
Health Department, Aspen, Colorado, 19 December 1988.
20 Nelson, M. Washington Energy Extension Service, Seattle,
Washington, 22 December 1988.
21 Pryor, B. Jackson County Planning Department, Medford,
Oregon, 21 December 1988.
22 Rickard, P. and Lou Ellen Kelly. Klamath Falls County
Health Department, Klamath, Washington, December 1988 and
May 1989.
23 Selser, W. Lewis and Clark City/County Health Department,
Helena, Montana, 21 December 1988.
24 Sherlock, L. and R. Grise. Town of Telluride, Telluride,
Colorado, 17 January 1989.
25 Tommelson, M. North Sonoma County Air Pollution Control
District, Cloverdale, California, 6 January 1989.
26 Young, B. California Air Resources Board. Sacramento,
California, 21 December 1988.
27 Zopf, M. Routt County Department of Environmental Health,
Steamboat Springs, Colorado, 9 January 1989.
28 Harley, Bob. City of Albuquerque, New Mexico. February,
1989.
6-3
-------
TABLE 6-2. WRITTEN REFERENCES
Reference
Number Reference
31 Batson, A. "Summary of the Proceedings of the PNWIS-APCA
Woodheating Curtailment Workshop." The Pacific Northwest
International Section of the Air Pollution Control Association,
Portland, Oregon, December 1987.
32 Paul Tiegs, OMNI Environmental Services, 1984.
33 "Citizens Against Wood Fumes Newsletter." Seattle, Washington,
1988.
34 Comis, S.K. Draft State Implementation Plan for Particulate
Matter - Yakima Area. Washington Department of Ecology,
Redmond, Washington, 1988.
35 Gay, R.L., W.T. Greene, and J.J. Shah. A National Assessment
of Residential Wood Combustion Air Pollution Impacts. Nero and
Associates, Inc., Portland, Oregon, unknown published date.
36 Gilbertson, S.B., T.W. Chappel, and G.A. Guay. A Selective
Shotgun Approach to Effective Wood Smoke Control. City and
Borough of Juneau, Alaska, 1988.
37 Grotheer, W.E. Overview of Control Strategies for Residential
Wood Combustion. EPA-84-70.1, U.S. Environmental Protection
Agency, Seattle, Washington, 1984.
38 Houck, J.E., C.A. Simons, and L.C. Pritchett. "Mitigation
Measures for Minimizing Environmental Impacts from Residential
Wood Combustion - Task E." U.S. Department of Energy, Pacific
Northwest and Alaska Regional Biomass Energy Program,
Bonneville Power Administration, June 1988.
39 Idaho Department of Health and Welfare, Air Quality Bureau.
Operations Manual for the Air Quality Index Program for the
Boise Metropolitan Area. Boise, Idaho, September 1988.
40 Kamens, R.M., G.D. Rives, J.M. Perry, D.A. Bell, R.F. Paylor,
Jr., R.G. Goodman, and L.D. Clayton. "Mutagenic Changes in
Dilute Wood Smoke as it Ages and Reacts with Ozone and Nitrogen
Dioxide: An Outdoor Chamber Study." Environmental Science and
Technology. 18:523-530, American Chemical Society, 1984.
(Continued)
6-4
-------
TABLE 6-2. (Continued)
Reference
Number Reference
41 Klamath County Voluntary Compliance Plan. Klamath County,
Oregon, 1989.
42 Koenig, J.Q., D.S. Covert, T.V. Larson, N. Maycutt, P. Jenkins,
and W.E. Pierson. "Wood Smoke: Health Effects and
Legislation." The Northwest Environmental Journal. 4, pp. 41-
54, 1988, University of Washington, Seattle, Washington.
43 Little, A.D., Inc. "Survey of Wood Heating Devices." Consumer
Product Safety Commission, 1983.
44 Malo, J.E., R.E. Imhoff, J.W. Phillips, J.A. Manning, and C.E.
Bohac. Air Quality Impact of Residential Wood Combustion:
Problem and Control Options Assessment. Tennessee Valley
Authority, Division of Air and Water Resources, Muscle Shoals,
Alabama, February 1985.
45 Montana Department of Resources and Conservation. Wood Heat.
Department of Natural Resources and Conservation, Helena,
Montana, June 1988.
46 Oregon Department of Environmental Quality. Catalytic Wood
Stoves. Portland, Oregon, 1986.
47 Oregon Department of Environmental Quality. Certified Wood
Stoves. Portland, Oregon, 1986.
48 Oregon Department of Environmental Quality. Sizing Wood
Stoves. Portland, Oregon, 1986.
49 Radian Corporation, "Woodstove NSPS Issue Paper: Scope of the
Standard and Definition of Affected Facility." Prepared under
contract to U.S. EPA, revised 1986.
50 U.S. Environmental Protection Agency. "Advanced Notice of
Proposed Rulemaking (ANPR), RWC NSPS." Federal Register. 2
August 1985.
51 U.S. Environmental Protection Agency. Regulatory Impact
Analysis (RIA) Residential Wood Heater New Source Performance
Standard. 1 December 1986.
(Continued)
6-5
-------
TABLE 6-2. (Continued)
Reference
Number Reference
52 .U.S. Environmental Protection Agency. Buying an EPA-Certified
Woodstove. 1986.
53 Washington Department of Ecology, Wood Heat. Wood Smoke and
You. Seattle, Washington, 1987.
6-6
-------
TABLE 6-3. BIBLIOGRAPHY
Dresser, A. L. "A Dispersion and Receptor Model Analysis of a Western
Community's PM-10 Program." JAPCA, 38,11, November 1988, pp. 1419-1421.
Easley, E. "1988: A Milestone Year." Alternative Energy Retailer, December
1988, pp. 15-17.
Energy Information Administration, Estimates of U.S. Wood Energy Consumption
1980-1983. U.S. Department of Energy, DOE/EIA-0341(83), Washington, D.C.,
November 1984.
Lipfert, F. W., L. R. Dupuis, M. Daum, and A. Srackangast. Empirical Analysis
of Residential Woodburning Impacts. U.S. Environmental Protection Agency,
Contract No. DE-AC02-76CH00016, Upton, Long Island, New York, October 1984.
U.S. Environmental Protection Agency. Residential Wood Heaters -- Background
Information for Promulgated Standards, U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle Park, North
Carolina, November 1987.
6-7
-------
APPENDIX A
TECHNIQUES FOR ESTIMATING RWC EMISSIONS
-------
APPENDIX A
TECHNIQUES FOR ESTIMATING RWC EMISSIONS
The estimation of emissions from residential wood combustion is necessary
in order to determine the initial level of emissions that must be reduced in
order to achieve ambient air quality goals. These emissions must be estimated
in two ways. First, an estimate of seasonal emissions of PM-10 from wood
combustion is necessary to determine the quantity of emissions that must be
reduced throughout the heating season. These reductions address chronic
particulate matter problems and potential violations of the annual PM-10 NAAQS
of 50 Mg/ro3 A seasonal emission estimate is also necessary to assess the
ability of long-term program elements, such as certification, to achieve
emission reductions over the course of a heating season.
In addition to seasonal emissions, it is necessary to determine emissions
of PM-10 on a "design day" basis. The design day is the theoretical or actual
worst case, day on which PM-10 emissions from RWC devices (and other sources)
are expected to be the greatest. The design day emissions are important
because these are the days on which the 24-hour PM-10 NAAQS is most likely to
be exceeded. Control of emissions on the design day is necessary to prevent
episodic exceedances of the NAAQS. Although almost all PM-10 NAAQS violations
occur because of exceedances of the 24-hour standard of 150 jig/m3, SIPs must
evaluate both the annual and the 24-hour standards.
HOUSEHOLD SURVEY DESIGN
An essential part of the emissions estimation process is the household
survey. The household survey is intended to obtain information on patterns of
combustion for residential heat, the types of wood burned for residential
heating, the types RWC devices in use, and the numbers of each type of RWC
device installed in the community. It is imperative that planners do not
A-2
-------
"make do" with a survey from another area. Due to changes in wood use over
the past several years, the importance of a contemporaneous survey is em-
phasized. This section describes the major factors to consider in the design
and implementation of an RWC survey. Additional information on this topic can
be found in reference 16 of this appendix.
The design and planning of the survey should begin with a clear statement
of the objectives of the survey and the uses for the data to be obtained. For
instance, surveys may be designed to obtain information on the numbers and
types of RWC devices in use. They may also be designed to gather information
on the perceptions and attitudes of the public on RWC emissions and control
strategies. Further, initial surveys may be used to provide a basis for
future surveys, enabling the air quality agency to track the effectiveness of
the control strategy adopted. In designing the survey, the goals to be
addressed should be stated clearly so that the best sample can be selected and
the most appropriate questions included in the questionnaire. The survey
design, including the questionnaire, should be reviewed by the individuals at
the agency who will be using the data, as well as by an outside expert in
survey techniques. Pretesting the questionnaire by administering it to a
small group (possibly agency staff members) could help eliminate problems with
the wording or format of the questions.
The sample chosen for administration of the survey should be representa-
tive the relevant population of the community as a whole. Generally, this
means that the size of the sample must be statistically adequate to represent
that population. Guidelines for estimating an adequate sample size for a
survey can be found in reference 16.
In addition to the size of the sample, it is also necessary to consider
the makeup of the sample chosen. Depending on the goals of the survey,
specific categories of individuals who own RWC devices may be considered
separately from the population as a whole. In this case, the sample needs to
be selected to assure that those individuals are included in adequate numbers.
Similarly, if permanent residents of a resort community (e.g., Aspen,
A-3
-------
Colorado) are to be distinguished in their RWC operation practices from
transient residents, the size and composition of the sample, as well as the
method for distributing the survey questionnaire, should be designed to
include this group.
The total costs of a household survey consists of several inputs.
Mailing lists may be purchased from companies that supply this service, or may
be constructed from existing public records. If the latter source is chosen,
the cost of labor by agency personnel to construct this list should be
considered. Review of the survey questionnaire by a consultant and presenta-
tion of the results of the review should also be included in the budget.
Materials for the survey include paper and envelopes. Both outgoing and
return envelopes should be included. Postage costs should also include both
the original distribution of the survey, as well as the return of the respon-
ses.
The survey questionnaire should be accompanied by a cover letter from the
agency discussing the purpose of the survey, the importance of the recipient's
input, and the confidentiality of the responses. The cover letter should also
explain the mechanics of returning the questionnaire, and provide the tele-
phone number and address of a contact person who can answer questions about
the survey. An example cover letter and questionnaire can be found in an
attachment at the end of this appendix.
The questions in the survey should be designed and worded to elicit
specific information. This will not only help ensure that the data collected
will address the goals of the survey, but will also avoid ambiguity in
responses and interpretation. Where possible, respondents should be given
alternative responses (e.g., multiple choice questions), or else the form or
mode of response should be specified (e.g., by specifying how to indicate the
response chosen or what information to use to fill in a blank). Some in-
dividual information should also be requested to give an indication of the
representativeness of the sample (e.g., age, income, zip code, number in
household).
A-4
-------
When information has been gathered through the use of the survey on
residential wood heating, the six steps outlined below should be followed to
estimate both seasonal and design day emissions of PM-10.
In some locations and circumstances, some information necessary to
estimate RWC emissions may be available without conducting a household survey.
For instance, in regions where most firewood is cut from public lands, land
management agencies such as the U. S. Forest Service may be a source of data
on the amount and types of wood used as fuel in a community. Similarly, in
areas where most wood fuel is purchased rather than being cut or gathered by
consumers, wood suppliers may be a valuable source of information on the
quantity of wood combusted. Retailers of wood stoves are also a good source
of information on the types of new devices being purchased and installed in a
community. The use of these sources of information may reduce the cost and
burden of a household survey. However, the information available through
these means may not provide some of the data necessary for a reasonably
complete and accurate estimation of RWC emissions.
CALCULATING RWC EMISSIONS
This subsection describes a recommended methodology for using the survey
results to derive emission estimates. The overall approach for estimating PM-
10 loading from RWC devices includes estimation of wood consumption by
appliance type, application of adjustment factors to account for site specific
fuel characteristics and the multiplication by emission factors for each
appliance type. Determination of winter design day emissions rates is made by
apportioning seasonal wood consumption by heating degree days, and estimating
RWC emission for a typical day during the heating season or the month with the
highest number of heating degree days. Alternatively, design day emissions
can be estimated based on conservative assumptions about the number of RWC
devices being used and the number of hours they are operated.
A-5
-------
The efficiency and emissions performance of certified noncatalytic and
catalytic stoves may degrade over time. In addition to deterioration of the
catalyst, seals (e.g., dampers and gaskets) can become damaged or blocked and
change the flow of combustion air. Although scant data are available,
assumptions can be made which consider the possible effects of performance
degradation.
For example, one might assume that as efficiency degrades, the stove
moves closer to taking on the heating efficiency and emissions characteristics
of a conventional stove, and that its performance can never be worse than a
conventional stove. It can also be assumed that the degradation of both
efficiency and emissions are in equal proportional steps. For example, if a
certified stove's heating efficiency degrades by 10 percent of the difference
in heating efficiency between certified stoves and conventional stoves, the
emissions will also degrade by 10 percent of the difference in emissions
between certified stoves and conventional stoves. Assumptions can also be
made about the frequency of catalyst replacement. This is based on informa-
tion obtained since the regulatory impact analysis for the NSPS wood stoves
which assumed that the emissions from catalytic wood stoves increases 1
percent per year, and that catalysts were replaced every 5 years. However,
the July 1989 revision to AP-42 section 1.10 (Residential Wood Stoves) notes
that Phase II units are subject to a 10-30 percent degradation within the
first 3 years of use.
The following step wise approach illustrates how the compiled survey data
should be used to calculate RWC device emissions. This calculation procedures
assumes that the following information is available from the household survey
or other sources:
Species of trees used for wood fuel;
Quantity of each species combusted in RWC devices (in cords);
Total amount of wood combusted in the community (in cords); and
Number of RWC devices in the community, by device type (e.g.,
fireplaces, pellet stoves, certified catalytic stoves).
A-6
-------
This calculation also assumes that information is available on emission
factors for different RWC devices (see reference 17) and average heating
degree days for specific locations (see references 14 and 15).
Step 1: Identify typical wood characteristics for'vour area
The first step in estimating emissions of particulate matter from RWC
devices is to determine the types of fuel wood used for heating in your
locality and the characteristics of the various wood species that affect
particulate matter formation. Table A-l lists several species of trees that
are frequently used in the western and northwestern regions of the nation for
fuel wood. Similar information on other species can be obtained from the
USDA's publication "Wood Handbook." The density of the fuel wood species is
the most important characteristic that should be identified. The densities of
several species of trees are listed on Table A-l, and are used in Step 2 of
the emissions estimation procedure to derive the quantity of each species
combusted on a dry basis.
The energy content of the various wood species listed on Table A-l is not
used in the procedure described here, but could be used to derive the amount
of wood it would be necessary to burn to achieve a certain heating level. If,
for instance, an agency decided to base its estimates on the amount of heat
necessary to heat a typical residence for a season (rather than on the amount
of wood burned as indicated by the survey), the energy content of the wood
could be used to determine the quantity of each species combusted if the
percentage of each species fired could be determined.
Step 2: Determine the quantity of wood combusted on a dry basis
Once the density of the tree species used for fuel wood in the area is
identified, the total quantity of wood combusted can be determined, as
illustrated in Table A-2. For each of the major wood species used for fuel
wood, an estimate of the number of cords consumed during the heating season is
A-7
-------
TABLE A-l. CHARACTERISTICS OF VARIOUS WOOD SPECIES
Density
Energy Content Ibs/cubic foot
Species (106 Btu/cord) (dry basis)
Aspen
White Oak
Cedar
Alaska
Western Red
Douglas Fir
Coast
Interior West
Interior North
Interior South
Larch, Western
Pine, Ponderosa
Spruce
16
29
18
13
20
21
20
19
22
17
17
.5
.1
.9
.7
.6
.4
.6
.7
.3
.1
.1
21
37
24
17
26
27
26
25
28
22
22
.4
.8
.5
.8
.7
.8
.7
.6
.9
.3
.3
(Black, White and
Sitka)
Source: Wood Handbook, Agricultural Handbook No. 72, U.S. Department of
Agriculture, 1974. Washington, D.C.
A-8
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determined from the survey data. Based on the density figures in Table A-l
and an assumption that each cord of wood contains roughly 80 cubic feet of
solid wood, the quantity of solid wood of each species fired in a year can be
determined. From this result, an estimate can be made of the dry mass of wood
contained in a cord of each species. An example of this calculation for white
oak, based on Table A-2, would be as follows:
37.8 Ib drv white oak X 80 ft3 - 3.024 drv Ib X 0.4535 kg - 1.371 dry kg
ft3 cord cord Ib cord
Based on the dry mass of wood of per cord of each species combusted and on
the total amount of each species combusted (as determined from the survey
data, a typical mass value for each cord of wood combusted in the locality can
be determined by weighing the individual mass per cord values by the relative
amount of each wood type combusted, using the following general equation:
n
Z (MFC,, x Ct)
i-1
MPCw -
n
where :
MPCW - weighted average mass per cord, dry kg/cord
HPCi - mass per cord for fuel species "i", dry kg/cord
Ct - annual consumption of species "i", cords /year
n - number of different wood types .
As applied to the information in Table A-2, this calculation would take
the following form:
( 1.371 kg oak X 400,000 cords )+( 1.009 kg fir X 150,000 cords)
cord cord
MPCW - _
400,000 cords oak + 150,000 cords fir
MPCW - 1,272 kg/cord
A-10
-------
Step 3: Identify the mass of wood burned by appliance type
The mass of dry wood combusted by each type of wood combustion appliance
in the locality can be estimated based on the survey data on the number of
cords of fuel wood combusted in the community in each type of appliance. This
estimation is based on the average mass of dry wood calculated in Step 2, as
in the example in Table A-3.
In some instances, the information supplied by the household survey may
not adequately delineate wood consumption by stove type (e.g., conventional,
noncatalytic certified, and catalytic certified), or the reliability of this
data may-questioned because of a small sample size or data quality problems.
Under these circumstances, this information may be estimated using the
approach outlined below.
This alternative approach involves apportioning wood consumption based on
the relative thermal efficiencies of the different appliance types. The
overall thermal efficiency of conventional, noncatalytic certified, and
catalytic stoves, is estimated to be 52%, 63% and 72%, respectively. For a
given heat demand, efficient stoves consume less wood than inefficient ones.
Therefore, if total wood consumption and the mix of appliance types are the
only variables known, the amount of wood consumed by each appliance type can
be calculated by solving for D, using the following equations:
TWC - (A * D) + (B * D * 0.84) + ( C * D * .72)
Rearranging this formula gives:
D - TWC / [A + (B * 0.84) + ( C * 0.72)]
where:
TWC - Total wood combusted in stoves, dry kg (from survey)
A - Number of conventional stoves, (from survey)
B - Number of certified noncatalytic stoves (from survey)
A-ll
-------
TABLE A-3. ESTIMATION OF WOOD BURNED BY APPLIANCE TYPE
Appliance
Type
Fireplace
Conventional
Wood
Combusted
by Appliance
(cords/year)
165,000
247,500
Mass of
Dry Wood
(kg/cord)
1,272
1,272
Wood Burned by
Appliance Type
(kg)
2.1 x 108
3.1 x 108
Stove
PHASE II CERTIFIED STOVE
Non-Catalytic, 27,500
Catalytic 27,500
Furnace 82,500
1,272
1,272
1,272
3.5 x 107
3.5 x 107
1.0 x 108
A-12
-------
C - Number of certified catalytic stoves (from survey)
D - Wood consumption in a conventional stove, dry kg
0.84 - Relative heating efficiency for certified noncatalytic stove
(i.e., kg of wood required for certified noncatalytic stove to
produce the same quantity of heat as 1 kg burned in conven-
tional stove)
0.72 - Relative heating efficiency for certified catalytic stove
(i.e., kg of wood required for certified catalytic stove to
produce the same quantity of heat as 1 kg burned in conven-
tional stove
Finally, the amount of wood consumed by each appliance category is
calculated using the following equations:
E - D * A
F-D*0.84*B
G - D * 0.72 * C
where:
E - wood consumed by conventional RWC devices, kg
F - wood consumed by certified non catalytic RWC devices, kg
G - wood consumed by certified catalytic RWC devices, kg
The following is an example of this approach. It assumes the following
data on total wood combustion (TWC) and on the mix of RWC devices was gathered
through the use of a survey.
TWC - 380,000,000 kg
A 107,500 conventional stoves
B - 5000 certified non catalytic stoves
C - 6000 certified catalytic stoves
D - Wood consumption in an individual conventional stove
To solve for D, the following equation is constructed from this data:
A-13
-------
380,000,000 - (107,500*0) + (5000*D) + (6000*D)
Rearranging this equation to solve for D yields the following:
D - 380,000,000/[107,500 + (5000*0.84) + (6000*.72)]
D - 380,000,000/[116,020]
D - 3275 kg of wood consumed in each conventional stove
The quantity of wood consumed in the population of conventional stoves, then,
would be calculated as:
E -3275 kg/stove * 107,500 stoves - 352,062,500 kg
The quantity of wood consumed in the population of certified noncatalytic
stoves would be calculated as:
F -3275 kg/stove* 0.84 efficiency factor * 5000 stoves - 13,755,000 kg
The quantity of wood consumed in the population of certified catalytic stoves
would be calculated as:
G -3275 kg/stove * 0.72 efficiency factor * 6000 stoves - 14,148,000 kg
Step 4: Apply emission factors to calculate total annual PM-10 emissions
To calculate total PM-10 emissions from the RWC devices in a locality, the
mass of wood burned by each appliance type (as calculated in Step 3) is
multiplied by an emissions factor. These emission factors represent the
average emissions of PM-10 from each type of appliance based on combustion of
a certain amount of wood. Typical emission factors for different appliance
types are listed in Table A-4. As noted in AP-42, they represent the field-
operation emissions expected from wood heaters meeting the July 1, 1990 (Phase
II) certification standards. These emission factors were developed for
A-14
-------
TABLE A-4. EXCERPT FROM AP-42 SECTION 1.10 ON RESIDENTIAL WOOD COMBUSTION"
PM-10
Appliance Type (g/dry Kg) Efficiency1
Fireplace 14.0 c
Conventional Stove of 15.Od 52
Fireplace Insert
PHASE II CERTIFIED STOVE
Noncatalytic
Catalytic
Furnace
Pellet Stove
9.6d
6.6d
15. Oe
1.6d
63
72
C
78
*See AP-42 for current version of section 1.10. Also, see discussion in text
and in AP-42 on efficiency and performance degradation before using these
factors.
bOverall efficiency represents sum of combustion and transfer efficiencies,
and values represent averages of laboratory test resuts.
°No data provided in AP-42.
Reference 18.
'Assume same emissions factors as conventional stoves.
A-15
-------
inclusion in the AP-42, except as noted. The data for the noncatalytic and
catalytic stoves are based on a limited data base of in-situ tests of stoves
that were of average-or-better installation. It is anticipated that the
quality of these stoves will improve, resulting in an improvement in their in-
situ performance. As more in-situ data become available, the AP-42 values
will be reviewed and revised, if appropriate. Refer to AP-42 to obtain any
revisions to the factors in Table A-4 and for additional information on their
derivation and use. The AP-42 emission factors should be used unless local
conditions clearly show other emission factors would be more appropriate. For
example, higher emissions might be anticipated if installation methods are
particularly poor in a community or if a large number of stoves in the
community do not meet the Phase II NSPS.
When these emission factors are multiplied by the quantity of wood
consumed during the heating season by each RWC device type in the locality,
the product is the quantity of PM-10 emitted from each appliance type per
year. An example of the calculation of emissions from one appliance type
(fireplace) would be as follows:
2.1 x 108 kg wood X 14 g PM X Mg - 2.9 x 103 Me PM-10
year kg 106g year
These products may then be aggregated for all appliance types to determine
the total quantity of PM-10 emitted from all RWC devices in the locality.
Table A-5 depicts an example of the calculation of emissions for a typical mix
of RWC devices in a locality.
Step 5: Calculate average PM-10 emissions per heating degree day
To calculate the PM-10 emissions from residential wood combustion in a
locality on the worst case "design day," the first step is to determine the
average emissions per heating degree day. A heating degree day (HDD) is a
measure of the number of degrees that the temperature in a residence must be
raised over the outside temperature to maintain a temperature that is
A-16
-------
TABLE A-5. EXAMPLE OF AGGREGATION OF EMISSIONS FOR APPLIANCE TYPE
Appliance
Type
Fireplace
Conventional
Annual
Consumption
(Kg/year)
2.1 x 108
3.1 x 108
PM-10 Emission
Factor
(gAg)
14.0
15.0
PM-10
Emissions
(Mg/year)
2.9 x 103
4.6 x 103
Stove or
Fireplace
Insert
PHASE II
CERTIFIED STOVE
Noncatalytic
3.5 x 107
9.6
3.4 x 102
Catalytic
Pellet Stove
3.5 x 107
1.0 x 108
6.6
1.6
2.3 x 102
1.6 x 102
A-17
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comfortable to the residents (assumed to be 65°). The greater the number of
heating degree days, the greater the quantity of wood combusted for heat and,
consequently, the greater the quantity of emissions.
Average heating degree day requirements have been calculated for most
areas of the country and are available through references (12,13). To
calculate the average emissions per heating degree day, the average annual
emissions are divided by the number of heating degree days in the heating
season. In the example for fireplaces below, using heating degree day
figures for Denver, Colorado drawn from Table A-6, it is assumed that the
heating season includes all months when the number of heating degree days
exceeds 100. Although in some cases there may be cold weather in other
months, it is expected that these cold spells will be infrequent and
relatively mild, so that burning wood for residential heat will not be
significant.
2.0 x 103 Mg PM-10
year -0.33 Mg PM-10 per HDD during heating season
6.014 HDD
heating season
Step 6: Calculate design day PM-10 emissions from wood combustion
To calculate design day PM-10 emissions from wood combustion, the average
number of heating degree days per day during the months of the heating season
associated with exceedances of the PM-10 NAAQS is calculated. This calcula-
tion is based on information such as that contained in Table A-6 and in
references 14 and 15. This average number of HDD per month(s) when exceed-
ances occur is then multiplied by the annual average PM-10 emissions per HDD,
as calculated in Step 5.
RWC emissions in _ Emissions (Mg Pm-10) x HDD in exceedance months
exceedance months Year HDD for entire year
A-19
-------
When the emissions of PM-10 from RWC devices is calculated, the design day
emissions is calculated as the average daily emissions during the exceedance
months .
RWC emissions in exceedance months
D.,ign d.y «.i..ion> - Totfll number of 4^ in exceedance months
An example of this calculation for Denver would begin with an identifica-
tion from agency records of the months in which exceedances of the PM-10 NAAQS
generally occur (assumed for purposes of this example to be November, Decem-
ber, and January. If total PM-10 emissions from RWC devices for the year are
estimated to be 2.0 X 103 Mg PM-10 and the heating degree days for these three
months are 2894 (from Table A-6), emissions during this three-month period
would be :
2.0 X 103 Mg PM-10 x 2894 HDD - 962 Mg PM-10
Year 6014 HDD
Based on there being 92 days during the three month period, the design day
emissions of PM-10 for Denver in this example would be
962 Mg PM-10 - 10.4 Mg/day
92 days
Other methods for estimating the design day emissions may be considered.
For example, the HDD for the actual exceedance days can be used (instead of
the HDD in the exceedance months) , provided monitoring occurred frequently
enough to ensure that a representative estimate of the HDD on exceedance days
can be obtained.
DATA EVALUATIONS AND QUALITY CHECKS
Survey data should be reviewed and evaluated for reasonableness and
accuracy prior to calculating emissions. To accomplish this, local agencies
should develop a quality assurance plan that outlines in detail specific steps
planned to ensure high quality data. Such a plan and its execution serve to
A-20
-------
produce a more complete and accurate inventory while simultaneously promoting
user and agency confidence in the data. The data/results generated under such
a plan will allow a better assessment of control strategies and better
resolution on the impact of RWC emissions on air quality.
As a general rule, the single piece of information most subject to error
during an RWC survey is fuelwood consumption. Furthermore, fuelwood consump-
tion is the single parameter that has the largest impact on calculated RWC
emissions. For these reasons, data evaluations and quality checks should
focus heavily on ensuring the accuracy of these values.
Errors associated with fuelwood consumption values described in the survey
are due to judgment error by respondents. This generally results because
respondents are unfamiliar with precise definitions for measuring fuelwood
(i.e., standard cord, face cord, etc.). These judgment errors include both
underestimates and overestimates of the quantity of fuel wood consumed.
Several generalizations determined during a nationwide fuelwood survey
performed by the U.S. Department of Agriculture may be useful in evaluating
the responses. (Reference A-l) As a rule of thumb, respondents overestimated
fuelwood consumption in fireplaces by approximately 20 percent. Similarly,
those respondents claiming to burn over 10 cords of wood per year (in any wood
burning device) were determined through follow-up surveys to have over-
estimated consumption by an average of about 45 percent.
Quality assurance checks should evaluate fuel consumption estimates in
view of appliance type and use category (primary, secondary heat, occasional
use, etc.). The data should be evaluated to identify apparent outliers. For
perspective, Table A-7 presents 1980-1987 national estimates of total wood
consumption by appliance type and average per unit consumption by appliance
type. Table A-8 presents fuelwood consumption characteristics by timber
region.
Apparent data outliers should be identified and follow-up contacts made.
During subsequent interviews, respondents should be allowed and encouraged to
A-21
-------
TABLE A-7. ANNUAL FUELWOOD CONSUMPTION IN THE USA BY APPLIANCE TYPE
(1980 - 1987 Averages)
Consumption of Wood
Average Amount of Wood
Burned by Appliance Type
Appliance
Type
Ordinary Fireplace
Non-Airtight Stove
Fireplace Insert
Airtight Stove
Furnace
By Appliance Type
(106 Cords/Yr)
9.8
2.7
9.5
15.5
2.9
Per Unit Bases
(Cords/Appliance/Yr)
0.8
1.8
2.3
2.8
3.7
Source: Skog & Watterson, U.S. Department of Agriculture, p. 20.
A-22
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-------
describe fuelwood consumption in terms that are familiar to them. Surveyors
should use the information in the responses to estimate revised consumption if
necessary. Table A-9 lists guidelines for assisting surveyors in evaluating
these follow-up responses.
A-24
-------
TABLE A-9. GUIDELINES FOR ASSISTING SURVEYORS IN EVALUATING FUELWOOD
CONSUMPTION RESPONSES (REF A-l)
Commonly Used
Fuelwood Measurements
Estimated Relationship
to a Standard Cord
Half-ton pickup truck full
Three-quarter ton pickup truck full
Small pickup truck full (Datsun,
Toyota, LUV, etc.)
Full-size car trunk full
Small-size car trunk full
Full-size station wagon full
Small-size station wagon full
Suburban (carry all) full
Small lift-back (Citation, Corolla,
etc.)
Tons: dry
Tons: wet
12-inch face cord
16-inch face cord
18-inch face cord
24-inch face cord
Standard Cord
0.500
0.500
0.333
0.167
0.100
0.250
0.167
0.500
0.125
0.667
0.500
0.250
0.333
0.375
0.500
1.000
Source: Skog and Watterson.
A-25
-------
SUGGESTED REFERENCES FOR ADDITIONAL INFORMATION
Fuel Use Surveys
1. Elrick and Lavidge, Inc. The Pacific Northwest Residential Energy Survey.
Volumes 1-12. Prepared for the Bonneville Power Administration and the
Pacific Northwest Utilities Conference Committee under Contract No. DE-
AC79-79BP13061. Portland, Oregon: Bonneville Power Administration. July
1980.
2. Michigan Department of Natural Resources. Fuelwood Consumption Survey in
1980. 1980.
3. Minnesota Department of Natural Resources. Firewood Use in Minnesota.
Unpublished. 1980.
4. Puget Sound Power and Light Company, Rate Department. Residential Wood
Heating Survey. Bellevue, Washington: Puget Sound Power and Light
Company. July 1980.
5. U.S. Department of Agriculture, Pacific Northwest Forest and Range
Experiment Station. Wood for Energy in the Pacific Northwest: An
Overview. Portland, Oregon: U.S. Department of Agriculture. 1979.
6. U.S. Department of Agriculture Forest Service, Forest Products Laboratory.
Survey Completion Report. Residential Fuelwood use in the United States:
1980-1981. Kenneth Skog and Irene Watterson July 1983.
7. U.S. Department of Energy, Energy Information Administration, Office of
Coal, Nuclear, Electricity and Alternate Fuels. Estimates of U.S. Wood
Energy Consumption From 19A9 to 1981. Washington, DC 20585, August 1982.
A-26
-------
General
8. Gay, Larry. The Complete Book of Heating With Wood. Charlotte, Vermont:
Garden Way Publishing. 1974.
9. Monsanto Research Corporation. Source Assessment: Residential Combustion
of Wood. Prepared for the U.S. Environmental Protection Agency under
Contract No. 68-02-1874. Research Triangle Park, North Carolina: U.S.
Environmental Protection Agency. March 1980. EPA-600/2-80-042b.
10. Shelton, Jay W. Jay Shelton's Solid Fuels Encyclopedia. Charlotte,
Vermont. Garden Way Publishing. 1983.
11. U.S. Environmental Protection Agency (OAQPS). "Source Sampling
Residential Fireplaces for Emission Factor Development"
EPA-450/3-76-010, Contract no. 68-02-1992, November 1975.
12. U.S. Environmental Protection Agency. "Preliminary Characteristics of
Emissions from Wood-Fired Residential Combustion Equipment,"
EPA-600/7-80-040, March 1980.
Fuel Wood Properties
13. U.S. Department of Agriculture, Forest Products Laboratory, Wood Handbook.
Agricultural Handbook No. 72, Washington, DC. 1974.
Heating Degree Data
14. National Oceanic and Atmospheric Administration. Historical Climatology.
Series No. S-l, July 1931 - June 1980. Asheville, North Carolina:
National Climatic Center. 1981.
15. U.S. National Oceanic and Atmospheric Administration, "Climatography of
the United States, No. 81," September 1982.
A-27
-------
Survey Methods
16. Dillman, Don. Mail and Telephone Surveys: The Total Design Method. New
York, New York: John Wiley. 1978.
Emission Factors
17. U.S. EPA (OAQPS). Compilation of Air Pollutant Emission Factors (AP-42).
Third Edition. Supplement 14. RTF, NC, 1983.
18. U.S. EPA (OAQPS). "Residential Wood Stoves" Draft Supplement to
Compilation of Air Pollutant Emission Factors (AP-42) Third Edition. RTF,
NC, 1988.
A-28
-------
ATTACHMENT TO APPENDIX A
Example of Cover Letter and Survey of Local
Wood Heating Patterns
-------
Department of Environmental Quality
532 S.W. FIFTH AVENUE. BOX 1760, PORTLAND. OREGON 97207 PHONE (503)229-5696
May 3, 1985
Dear Resident:
The Departaent of Environmental Quality (DEQ) is conducting a survey to
gather more information about home heating patterns and use of wood burning
equipment of residents in the Medford area. The results of this survey
will be used by the DEQ Air Quality Division for educational and planning
purposes.
Your household is one of a small nunber in which people are being asked
about home heating and wood burning. It was selected in a random sample of
the entire area. So the results will be representative of the Medford
area, it is important that each questionnaire be completed and returned.
Information from individual households will be kept strictly confidential.
Ve ask that you fill out the enclosed questionnaire and return it to us on
or before May 31, 1985. A self-addressed, prepaid envelope is enclosed
for your convenience.
Tour cooperation is appreciated. If you have any questions, please contact
Marianne Fitzgerald at 229-5353, or call toll free, 1-800-452-4011. Thank
you for your assistance.
Sincerely,
Fred Hansen
Director
MEF:n
AA3240
-------
1Q85 MEDFORD AREA WOOD HEATING SURVEY
Please read the following questions carefully and circle, or write in the
answer as indicated. Your cooperation is appreciated.
1. Your zipcode? (Please indicate in space below.)
2. Do you own or rent your home? (Please circle number of answer.)
1. OWN
2. RENT
3. What type of residence do you live in? (Circle number.)
1. SINGLE FAMILY HOME
2. APARTMENT OR DUPLEX
3. CONDOMINIUM
4. MOBILE HOME
4. How long have you lived at your present address? (Circle number.)
1. LESS THAN 1 YEAR
2. 1 TO 2 YEARS
3. 2 TO 3 YEARS
4. 3 TO 4 YEARS
5. 5 YEARS OR MORE
5. Which of the following areas are insulated in your home?
(Circle numbers of all answers that apply.)
1. CEILINGS
2. WALLS
3. FLOORS
4. STORM/THERMAL WINDOWS
5. STORM DOORS
6. WEATHER STRIPPING/CAULKING
7 DON'T KNCW
8. NONE
6. How many people live in your home? (Indicate in space below.)
PEOPLE
7. What was your total household income in 1964, before taxes?
(Circle number.)
1. LESS THAN $10,000
2. $10,000 TO $19,999
3. $20,000 TO $29,999
4. $30,000 TO $39,999
5. $40,000 TO $49,999
6. $50,000 OR MORE
-------
MEPFOHP AREA WOOD HEATING SURVEY
8. Your present age Is? (Circle number of answer.)
1. LESS THAN 25 YEARS OLD
2. 25-34 YEARS
3. 35-44 YEARS
4. 45-54 YEARS
5. 55-64 YEARS
6. 65 AND OLDER
9. Which of the following fuel types do you use to heat your home?
(Please put the corresponding number in the appropriate space.)
MAIN SOURCE OF HEAT 1. NATURAL GAS
2. WOOD
SECONDARY SOURCE OF 3. ELECTRICITY
BEAT (IF ANY) 4. OIL
5. PROPANE
ADDITIONAL SOURCE 6. KEROSENE
OF HEAT (IF ANY) 7. SOLAR
8. TRASH/ PAPER
9. OTHER
10. Do you burn wood in your residence? (Circle number.)
1. YES
2. NO
11. Have you installed a new or replacement woodstove or stove-like
fireplace Insert during the past year? (Circle number.)
NEW APPLIANCE REPLACEMENT APPLIANCE
1. YES 1. YES
2. NO 2. NO
12. Have you installed a new woodstove or stove-like fireplace insert
during the past two to five years? (Circle number.)
1. YES
2. NO
13* Do you plan to install any new or replacement woodburning equipment
in the next two years? (Circle number.)
NEW EQUIPMENT REPLACEMENT EQUIPMENT
1. DEFINITELY 1. DEFINITELY
2. MAYBE 2. MAYBE
3. NO 3. NO
If you plan to purchase a new or replacement woodstove, please refer
to the list of informational brochures and publications available from
DEQ on page 6.
-------
1985 MEDFORD AREA WOOD HEATING SURVEY
IF YOU BURN WOOD, PLEASE ANSWER THE FOLLOWING QUESTIONS. IF NOT, PLEASE
RETURN THE QUESTIONNAIRE IN THE RETURN ENVELOPE. THANK YOU FOR YOUR
COOPERATION.
14. Do you burn wood primarily for: (Circle one number.)
1. MAIN SOURCE OF HEAT?
2. SUPPLEMENTAL SOURCE OF HEAT?
3. ENJOYMENT?
15. How many cords of wood did you burn this heating season (October 1984
April 1985)? A cord is a stacked pile 4 feet high, 4 feet deep, and 8
feet long. (Please indicate amount burned below.)
... CORDS
16. How ouch wood did you burn last heating season (1983-84) as
compared to this heating season (1984-85)? (Circle number.)
1. MORE
2. SAME
3. LESS
4. NONE
17. How much wood do you expect to burn next heating season (1985-86)
as compared to this heating season (1984-85)? (Circle number.)
1. MORE
2. SAME
3. LESS
4. NONE
18. Please mark the appropriate responses to the following questions.
Which of the following
wood heating devices
do you have?
(Circle yes or no.)
How many devices
do you have?
(Write in
number below.)
Age of each
device?
(Write in
age below.)
Total number
of cords
burned per
year in each
device?
(Indicate
bel ow.)
FIREPLACE (WITHOUT
STOVELIKE INSERT)
FIREPLACE (WITH
STOVELIKE INSERT)
WOODSTOVE
WOOD BURNING FURNACE
WOOD COOKSTOVE
YES
NO
YES
NO
YES
NO
YES
NO
YES
NO
YEARS
YEARS
YEARS
YEARS
YEARS
CORDS
CORDS
CORDS
CORDS
CORDS
OTHER (PLEASE SPECIFY)
-------
MEDFQRD AREA WOOD HEATING SURVEY
19. If you use a woodstove or fireplace Insert, in which position is the intake
air control set most of the time? (Circle number.)
1. LOW (0 TO 1/3 OPEN)
2. MEDIUM (1/3 TO 2/3 OPEN)
3. HIGH (2/3 TO FULLY OPEN)
20. If you have a woodstove or fireplace insert, what kind of air Intake control
do you have? (Circle number.)
1. AUTOMATIC
2. MANUAL
21. What percent of the following type(s) of firewood do you burn most often?
(Circle the numbers of all answers that apply and indicate approximate
percent.)
1
1. FIR
2. MADRONE
3. OAK
4. PINE
5. MAPLE
6. CEDAR
7. LUMBER OR MILL SCRAPS _
8. OTHERS (PLEASE SPECIFY)
22. What are the four most frequent tines you burn wood? (Please put
corresponding number in the appropriate space below.)
1. MIDNIGHT TO 6:00 A.M...WEEKDAYS 6. MIDNIGHT TO 6:00 A.M...WEEKENDS
2. 6:00 A.M. TO NOON WEEKDAYS 7. 6:00 A.M. TO NOON WEEKENDS
3. NOON TO 6:00 P.M WEEKDAYS 8. NOON TO 6:00 P.M WEEKENDS
4. 6:00 P.M. TO MIDNIGHT..WEEKDAYS 9. 6:00 P.M. TO MIDNIGHT..WEEKENDS
5. ALL DAY WEEKDAYS 10. ALL DAY WEEKENDS
MOST FREQUENT TIME
SECOND MOST FREQUENT TIME
THIRD MOST FREQUENT TIME
FOURTH MOST FREQUENT TIME
23* If you have a woodstove or fireplace insert, approximately how many days did
you burn this heating season (October 198M - April 1985)? (Circle number.)
1. UNDER 60 DAYS
2. 60-99 DAYS
3. 100-200 DAYS
4. MORE THAN 200 DAYS
-------
MEDFQBD AREA_tfQOD HEATING SPRVEY
24. What was the average time (In hours) you burned during those days? Include
any time there was a fire or burning coals in your stove. (Please indicate
in space below.) -
HOURS PER DAY
25. Where do you obtain aost of your firewood? (Circle the numbers of the
answer that apply.)
1. PURCHASED FROM A DEALER
2. CUT ON PERSONAL PROPERTY
3. CUT ON PRIVATE LAND (OTHER THAN OWN)
4. CUT ON STATE FOREST LAND
5. CUT ON FEDERAL FOREST LAND
6. LUMBER OR MILL SCRAPS
7. RECEIVED FROM FRIENDS, NEIGHBORS,
RELATIVES
8. OTHER (PLEASE SPECIFY)
26. If you purchased your firewood, what was the price you paid per cord?
DOLLARS PER CORD
27. If you cut your own firewood, what was the average round trip mileage to
gather wood?
MILES
28. If you cut your own firewood, during which of the following seasons do you
cut it? (Circle the numbers of the answers that apply.)
1. WINTER (DECEMBER, JANUARY, FEBRUARY)
2. SPRING (MARCH, APRIL, MAY)
3. SUMMER (JUNE, JULY, AUGUST)
4. FALL (SEPTEMBER, OCTOBER, NOVEMBER)
29. From the time of cutting to the tine of burning, how long do you store your
firewood before burning? (Circle the number that is most typical for you.)
1. 3 MONTHS OR LESS
2. 4-6 MONTHS
3. 7-12 MONTHS
4. 1-2 YEARS
5. MORE THAN 2 YEARS
6. DON'T KNOW
30. Where do you store most of your firewood? (Circle number.)
1. INSIDE HOME
2. GARAGE OR SHED
3. COVERED OUTSIDE
4. UNCOVERED OUTSIDE
-------
MEPFORD AREA WOOD HEATING SURVEY
31. Did you hear about the 20 day air stagnation advisory in Medford in
January, 1985 (January 10 to January 29)? (Circle number.)
1. YES
2. NO
3. DON'T REMEMBER
32. Did you discontinue woodburning as requested during this period?
(Circle number.)
1. IES
2. NO
3. DON'T REMEMBER
33* la there anything else you would like to tell us about home heating and use
of wood burning equipment? If so, please use this space for that purpose.
IODR CONTRIBUTION TO THIS EFFORT IS GREATLY APPRECIATED. IF YOU WOULD LIKE A
SUMMARY OF THE RESULIS, PLEASE CONTACT THE DEQ REGIONAL OFFICE IN MEDFORD AT
776-6010.
The following publications are available free from the Department of
Environmental Quality, Public Affairs Section, P.O. Box 1760, Portland, Oregon
97207, or from any DEQ Regional office. Call Public Affairs at 229-5317 in the
Portland area, or toll-free from other parts of the state at 1-800-452-4011.
. 1. Slginq Wood Staves - How to match heating capacity to heating
needs (1985 brochure).
. 2. Certified Woodatovea - Describes Oregon's woodstove
certification program (1985 brochure).
_3. Llat nf DEQ Certified Woodatovea (Current).
_4. Catalytic Woodatovea - Describes this new type of woodstove (1985
brochure). «
_5. Burn Wood Better - Shows heat values and drying times for various
types of wood; shows how to operate a stove to reduce emissions.
-------
APPENDIX B
REPORT SPONSOR, AUTHORS, AND REVIEWERS
This report was produced under the direction of Thompson G. Pace, P.E.,
Senior Environmental Engineer, assisted by Martha Smith. Mr. Pace and Ms. Smith
are with the USEPA's Office of Air Quality Planning and Standards, Research
Triangle Park, North Carolina.
The report was prepared by Radian Corporation (Austin, Texas, and Research
Triangle Park, North Carolina) under contract to USEPA. Authors were Bob Davis
(project director) and Gary Harrison (in the Austin office), and Barry Read in
Radian's RTP office. Radian technical reviewers were Glenn Rives and Mike
Hartman. A Technical Review Committee developed the recommended credits and made
substantial improvements in early drafts of this document.
The names and affiliations of those who served on the Technical Review
Committee appear below.
Kevin Golden, Washoe Co. (Nevada) Dept. of Health
Andy Goodrich, Washoe Co. (Nevada) Dept. of Health
Jim King, Colorado Department of Health
George Lauderdale, State of Washington, Department of Ecology
Bob Lebens, EPA, Stationary Source Compliance Division, Washington, D.C.
Bob McCrillis, EPA, Office of Research and Development, RTP, NC
Dallas Safriet, EPA, Office of Air Quality Planning and Standards, RTP, NC
Martha Smith, EPA, Office of Air Quality Planning and Standards, RTP, NC
Jeff Telander, EPA, Office of Air Quality Planning and Standards, RTP, NC
John Watson, Desert Research Institute (Reno, NV)
Dale Wells, EPA, Region 8 (Denver)
Ann Williamson, EPA, Region 10 (Seattle)
Barry Young, California Air Resources Board, Sacramento, CA
B-l
-------
APPENDIX C
EXAMPLE ORDINANCES
Jurisdiction
Aspen, Colorado
(Item 1)
Washoe County
Nevada (Item 2)
Butte, Montana
(Item 3)
Telluride,
Colorado
(Item 4)
Illustrates
Good use of rationale/justification for program
(p. 1, only included)
Definitions of appliances (pp. 1-2)
Inspection of retail outlets (p. 5)
Accelerated changeover (pp. 5-7)
Mandatory elimination of noncertified RWC
devices (p. 7)
Curtailment in general, and specifically:
action points, monitoring, notification (pp. 5-
6)
Exemptions to curtailment via permit system (pp.
7-9)
Expiration and renewal of permits (pp. 7-9)
Local standards more stringent than prevailing
state or federal standards (pp. 2-3)
Registration and permitting system for new and
existing RWC devices (pp. 3-4)
Limits one RWC device per dwelling (p. 4)
Ban on coal use (p. 4)
Emission fee in $/gram for certified levels (p.
5)
Fireplaces restricted to certain public areas
(P. 5)
Mandatory retrofit of fireplaces (p. 5)
Fuel quality specifications (p. 5)
C-l
-------
Jurisdiction . Illustrates
Telluride, Rebates for conversion to alternative heating
Colorado (p. 6)
(continued)
Two for one offsets -- two permits for existing
units must be retired for each new device
installed (pp. 6-7)
Inspection and enforcement (p. 7)
Appeals procedures (p. 8)
Crested Butte, Installation requirements
Colorado
(Item 5)
C-2
-------
Appendix C
Item 1
ASPEN, COLORADO
Note: Only first page of ordinance is provided. This illus-
trates a good justification section for a RWC emission
control ordinance.
-------
ORDINANCE NO.
(Series of 1988)
AN ORDINANCE AMENDING PORTIONS OF SECTION 11 ARTICLE II OF THE
MUNICIPAL CODE OF THE CITY OF ASPEN, COLORADO, TO REGULATE AND
REGISTER FIREPLACES AND SOLID FUEL BURNING DEVICES, REQUIRING
FIREPLACES INSTALLED IN THE FUTURE TO CONTAIN AND BE USED ONLY
WITH TECHNOLOGY WHICH MAKES THEM APPROVED CLEAN-BURNING DEVICES,
PERMITTING FIREPLACES CONTAINING AND OPERATED WITH GAS LOGS TO BE
CONSIDERED "CERTIFIED DEVICES", AND PRESCRIBING THE PENALTY FOR A
VIOLATION OF SAID AMENDMENT
WHEREAS, the Aspen area has exceeded healthful levels of
total participates for most of the years from 1975 through 1987;
and
WHEREAS, PM^o levels in Aspen have also been found to exceed
healthful levels; and
WHEREAS, these levels of PM10 pollution also cause visibil-
ity degradation which is harmful to the quality of life of
residents and visitors; and
WHEREAS, the Colorado Health Department has determined
through numerous studies that woodburning is one of the two
significant sources of PM^Q pollution in Aspen, and is the main
source of the toxic portion of PM]_0 pollution, and
WHEREAS, the Aspen area has measured three exceedances of
the health standards for PM10 pollution, after less than one
winter of monitoring; and
WHEREAS, the intent of this ordinance is to promote clean
air and to encourage alternative technologies and approaches to
improving air quality, and
WHEREAS, the City Council of the City of Aspen desires to
provide financial assistance if possible to citizens unable to
upgrade existing solid fuel burning devices to cleaner devices,
and to do so needs to determine the number of such devices; and
WHEREAS, the city Council, for the purpose of protecting the
health, safety and welfare of the residents and visitors of the
City of Aspen, desires to amend portions of Section 11, Article
II of the Municipal Code of the City of Aspen to regulate
construction and use of fireplaces and other solid fuel burning
devices.
-------
Appendix C
Item 2
WASHOE COUNTY, NEVADA
Note: Nine pages of excerpts from Washoe County illustrate:
Definition of appliances (pp. 1-2)
Inspection of retail outlets (p. 5)
Accelerated changeover (p. 7)
Episodic controls (pp. 8-9)
-------
DISTRICT HEALTH DEPARTMENT
AIR POLLUTION CONTROL REGULATIONS
PERTAINING TO WOOD STOVES
010.0255 "CERTIFIED" means a wood stove/fireplace insert has
been certified in accordance with current standards
adopted by the U.S. EPA, the State of Oregon, the
State :f Colorado an/or appears on the washoe County
District Health Department Official List of
Cerrified Wood Stoves; Ref. 40 CFR, Part 60; Oregon
Administrative Rules, Chapter 240, Division Cl;
Colorado Revised Statute, Regulation No. 4.
010.045 "COOK STOVE" means a wood stove installed in the
kitchen which is primarily designed for cooking and
has a stove top and an oven. It may also be
equipped with gas burners. This wood stove is
exempt from the emission standards and requirements
of Sections 040.051 and 040.0512.
010.063 "FIREPLACE" means an open hearth or fire chamber or
similar prepared place in which a fire may be made
and which is built in conjunction with a chimney.
It may have doors, provided they are not designed
with gasxets, air intake controls or other
modifications which create an air starved operating
condition. Fireplaces without such modifications
are exempt from the emission standards and
requirements of Sections 040.051 and 040.0512.
010.117 "PELLET BURNER" means a solid fuel burning device
designed to heat the interior of a building. It is
a forced draft heater with an automatic feed which
supplies appropriately sized feed material or
compressed pellets of wood, coal or other biomass
material to the firebox.
010.143 "STOVE KIT" means a kit that may include a door,
legs, flue pipe and collars, brackets, bolts and
other hardware and instructions for assembling the
wood heater with ordinary tools. Wood heaters built
from such kits must meet all emission standards and
requirements of Sections 040.051 and 040.0512.
:001 EAST MNTH STnEET ° 0 30X 11130. RENO. NEVADA 69520 (702) 328-2-iOO
-------
010.145 "UNCERTIFIED" means a wood Jtove/fireplace insert
that cannot be verified as meeting the certified
standards and/or does not appear on the Wasnoe
County District Health Department Official List of
Certified/Exempt Wood Stoves.
010.200 "WOOD HEATER" means an enclosed wood burning
appliance capable of, and intended for space
heating, domestic water heating or indoor cooking
and has an air-to-fuel ratio of less than 35 to 1 in
the low burn cycle. It also must have a usable
firebox volume less than twenty (20) cubic feet,
weigh less than 800 kilograms and have a minimum
burn rate less than five (5) kilograms per hour.
Appliances that are described as prefabricated
fireplaces and are designed to accommodate doors or
other accessories that would create the air starved
operating conditions of a wood heater, must meet the
emission standards if they meet the criteria in the
above definition with those accessories in place.
010.205 "WOODSTOVE/FIREPLACE INSERT" means for purposes of
compliance with Sections 040.051 and 040.0512, a
wood stove may be a wood heater, pellet stove,
prefabricated zero clearance - fireplace or a
fireplace heat form with doors or other accessories
which cause the fireplace to function as a wood
heater. Wood stoves do not include open masonry
fireplaces, barbeque devices, gas-fired fireplaces
or cook stoves.
020.040 PENALTIES
A. Except as provided in Subsections B, C, and
D, a violation of any section of these
regulations constitutes a major violation.
B. Any person who violates any section of these
regulations, other than Sections 020.050 and
020.055, is guilty of a civil offense and
shall pay an administrative fine of not more
than $5000.00. Each day of violation
constitutes a separate offense.
C. Any violation of Sections 040.005(8),
040.030, 040.035, 040.040 (A), 040.045,
040.050, 040.051, 040.055, 040.080, and
050.015 of these regulations constitutes a
minor violation unless the violation occurs on
more than two (2) occasions during a period of
twelve (12) consecutive months. In that
event, the third (3rd) and any subsequent
violations constitute major violations.
-------
Any person who violates Sections 040.051 or
040.0512 shall pay sn administrative fine up
to 31000.00. Eacn day of violation
constitutes a separate offense.
The following fines shall be levied for minor
violations of these regulations:
Section 040.005 (B)
(Wood Stove Opacity)
Section 040.030
(Dust Control)
Section 040.035
(Open Fires)
Subsection A of
Section 040.040
(Fire Training)
Section 040.045
(Refuse Burning)
Section 040.050
(Incinerator
Emission)
Section 040.051
(Certified
Woodstoves)
Section 040.055
(Odors)
Section 040.080
(Gasoline
Storage)
Section 050.015
(Emer. Episode)
First
Violation
not less than 50
not more than 250
not less than 100
not more than 250
not less than 25
not more than 250
not less than 50
not more than 250
not less than 25
not more than 250
not less than 50
not more than 250
not less than 100
not more than 250
not less than 50
not more than 250
not less than 50
not more than 250
not less than 100
not more than 250
Second
Violation
not less than .
not more than !
not less than '.
not more than !
not less than :
not more than f
not less than )
not more than £
not less than ]
not more than f
not less than \
not more than S
not less than 3
not more than 5
not less than 2
not more than 5
not less than 2
not more than 5
not less than 2
not more than 5
-------
040.005 VISIBLE AIR CONTAMINANTS
B. No person :nay permit emissions from a
residential woodstove, fireplace insert or
fireplace to exceed an opacity greater than
that shade designated as Mo. 2 on the
Ringelmann Chare for a period or periods
aggregating more than three (3) minutes in any
one hour period. Emissions created during a
fifteen (15) minute start-up period are
exempt.
1. A person who violates Subsection B shall
be issued a warning for the first
violation and shall be provided
information on proper woodburning
tecnniques.
040.051 WOODSTOVE/FIRE PLACE INSERT EMISSIONS
A. Emission Standard
Commencing November 1, 1987, it is unlawful
for any person to advertise, except when
restrictions are noted, sell, offer to sell,
or install any woodstove/fireplace insert to
any person for installation in any residence
within the Health District if it emits more
than fifteen (15) grains of particulate matter
per hour for a non-catalytic appliance or six
(6) grams of particulate matter per hour for a
catalytic appliance. Commencing June 30,
1988, the standard shall be nine (9) grams of
particulate matter per hour for a
non-catalytic appliance and four (4) grams of
particulate matter per hour for a catalytic
appliance. If the U.S. Environmental
Protection Agency adopts a woodstove/fireplace
emission standard which is more stringent,
that emission standard supercedes the standard
in this Section and becomes effective on the
date that the U.S. Environmental Protection
Agency standard becomes effective.
B. Certification
A wood stove/fireplace insert shall be
considered certified for purposes of these
regulations as defined in Section 010.0255.
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C. Enforcement
1. Mo local government authority within the
Health District may issue a building
permit to any person to install an
uncertified woodstove/fire place insert on
or after November 1, 1987.
2. The Control Officer shall on November 1,
1987, and periodically thereafter, inspect
wholesale and retail outlets for
woodstoves/fire place inserts to ascertain
their compliance with this Section and
shall make available to the public a list
of all certified appliances by brand name
and model being offered for sale within
the Health District.
D. Dealers Report of Sale
1. Commencing November 1, 1987, every
person who sells a woodstove/fireplace
insert within the Health District must
report the sale to the Control Officer
within thirty (30) days from the end of
each month on the form provided by the
Control Officer.
2. The form shall be provided by the Control
Officer after the person pays the fee
established by the District Board of
Health for that form.
3. Any person who fails to notify the Control
Officer of the sale is subject to the
penalties set forth in Section 020.040.
040.0512 EXISTING WOODSTOVE/FIREPLACE INSERT - REPLACEMENT
A. Commencing July 1, 1988, it is unlawful for
any person to complete, or allow the
completion of, any escrow transaction for the
transfer or conveyance of any previously
occupied residential real property unless the
residential real property has been certified
by the Control Officer as being in compliance
with the woodstove/fireplace insert
certification requirements of these
regulations.
B. A person may be licensed by the Control
Officer to inspect and certify that
woodburning stoves/fireplace inserts in
residential real properties are certified.
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C. To obtain a license, an application must be
made to the Control officer, on a form
approved by the Control Officer, for that
purpose. A license will be issued upon
satisfactory completion of all requirements
set forth by the Control Officer and payment
of the fee established by the District Board
of Health for the licensing process. A
license remains in effect for one year from
the date of issuance and may be renewed upon
meeting all the requirements of the Control
Officer and payment of the renewal fee.
0. A licensee shall report the result of each
inspection of a residential real property on a
form provided by the Control Officer after the
licensee pays the fee established by the
District Board of Health for that form. The
licensee must indicate that:
1. Mo woodstove/fireplace insert exists
within the residential real property; or
2. Each woodstove/fireplace insert within the
residential real property is certified; or
3. Any of the woodstoves/fireplace inserts
within the residential real property are
uncertified.
E. Not later than seven (7) working days after
receipt of a report from the licensee, the
Control Officer will issue a Certificate of
Compliance if each woodstove/fireplace insert
is certified. If the Control Officer fails to
act within the seven (7) day period, all
woodstoves/fireplace inserts within the
residential real property will be deemed
certified.
F. If the report indicates that a
woodstove/fireplace insert is uncertified, the
woodstove/fireplace insert must be removed
from the property/ retrofitted to meet
certification standards or replaced with a
certified device. Reinspection from a
licensee is required.
G. The Control Officer may issue a Certificate
of Compliance for a residential real property
if a person provides a copy of the Dealer's
Report of Sale issued under Section 040.051
(E) and provides evidence that the certified
woodstove/fireplace insert has been installed
in compliance with all applicable building,
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fire and other codes adopted oy the
jurisdiction in which the residential real
property is located.
H. If a residential real property is to be sold
and does not contain a wood stove/fireplace
insert, a form approved by the Control
Officer, containing the notarized signatures
of both the buyer and seller attesting to that
fact, may be accepted in lieu of an
inspection, and a Notice of Exemption may be
issued. On any subsequent sale, a new Notice
of Exemption or Certificate of Compliance
is required.
I. A Certificate of Compliance issued pursuant
to this Section:
1. Remains valid until such time as the
residential real property is transferred
or conveyed to a new owner.
2. Does not constitute a warranty or
guarantee by the licensee or the Control
Officer that the woodstove/fireplace
insert within the residential real
property meets any other standards of
operation, efficiency or safety, except
the emission standards contained in these
regulations.
J. Commencing January 1, 1993, it is unlawful
for any person to have a woodstove/fireplace
insert in any residential real property
unless:
1. The woodstove/fireplace insert is
certified; or
2. The residential real property has received
a Certificate of Compliance.
K. Any person who violates any of the
requirements of this Section, or who falsely
attests as to information as part of
compliance with this Section, is subject to
the penalties as set forth in Section
020.040 and may be subjected to the
applicable penalties prescribed by law for
perjury and may have any license issued by the
Control Officer pursuant to this Section
revoked.
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050.005 EPISODE CRITERIA LEVELS
TABLE 1
EPISODE CRITERIA LEVELS
POLLUTANT
Carbon
Monoxide
Ozone
AVERAGING
TIME
8 Hour
1 Hour
STAGE 1
(ALERT)
PSI 150
12 ppm
0.16 ppm
STAGE 2
(VARNING)
PSI 300
30 ppm
0.40 ppm
STAGE 3
(EMERGENCY)
PSI 400
40 ppm
0.50 ppm
Particulates
PM-10
24 Hour
250 ug/m3 420 ug/m3 500 ug/m3
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050.015 EPISODE CONTROL ACTIONS
The Control Officer and the appropriate law enforcenu
and public health officials shall take the follow:
control actions upon declaration of the follow.
stages:
A. Stage 1
1. A health warning for sensitive persons sh<
be included in all notifications
pursuant to Section 050.010.
2. All open burning must be terminated.
3. The use of permitted incinerators shall
terminated. Crematoriums or pathologic
incinerators may continue to operate if t
Control Officer determines that cessation
operation will cause a greater health hazard,
4. A request shall be made to the public
curtail any unnecessary motor vehic
operations.
5. Whenever the measurements of particulat
(PM-10) or carbon monoxide reach, or «
predicted to reach Stage 1 levels and advei
meteorological conditions are predicted
persist, the burning of any solid fuel
commercial or residential stoves and/
fireplaces shall be suspended unless it can
demonstrated, in accordance with t
procedures established by the Control Office
that such fuels supply the only heat availab
to the person burning it. The suspensi
shall remain in effect until all episc
stages have been terminated.
6. Sources covered under Section 050.030 mu
commence curtailment of operations as p
their submitted and approved plans.
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Appendix C
Item 3
BUTTE, MONTANA
Note: Illustrates:
Curtailment provisions (pp. 5-6)
Exemptions to curtailment via permit system (pp. 7-9)
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COUNCIL BILL NO. 330
ORDINANCE NO. 330
AN ORDINANCE REDUCING THE LEVEL OF AIR POLLUTANTS AT OR DELC
THOSE STANDARDS FOUND IN ADMINISTRATIVE RULES OF MONTANA, TIT1-
16, CHAPTER 8 SUB-CHAPTER 8 AND 9, AND IN EFFECT AS OF OCTOBE
15, 1985; PROVIDING FOR AUTHORITY; PROVIDING FOR INTENT; PRO
VIDING FOR SCOPE; PROVIDING FOR DEFINITION AND TERMS; ESTAB
LISHING REGULATIONS; PROVIDING FOR PERMITS; PROVIDING FOR EN'
FORCEMENT; PROVIDING FOR PENALTIES; PROVIDING FOR SEVERABILITY
PROVIDING FOR THE REPEAL OF ANY ORDINANCE OR RESOLUTION II
CONFLICT HEREWITH; AND PROVIDING FOR AN EFFECTIVE DATE HEREIN.
BE IT ORDAINED BY THE COUNCIL OF COMMISSIONERS OF THE CITY AN!
COUNTY OF BUTTE-SILVER BOW, STATE OF MONTANA:
SECTION 1: AUTHORITY; The authprity to promulgate this
Ordinance is provided for in Ordinance 68 of the
City and County of Butte-Silver Bow.
SECTION 2: INTENT; This Ordinance is necessary to preserve,
protect, improve, achieve and maintain such levels
of air quality as will protect the health and
welfare of citizens of the City and County of
Butte-Silver Bow.
SECTION 3: SCOPE; This Ordinance applies to all persons/ '
agencies, institutions, businesses/ industries or
government entities living in or located within
the area defined in the attached District Map and
legal description. Stationary sources with the
potential to emit more than 25 tons per year of
any pollutant, with the exception of five (5) tons
par y«*r of l««d, r«gulat«d und«r th« Montana
Clean Air Act, are not subject to this Ordinance.
SECTION 4: DEFINITIONS; For the purpose of this Ordinance
the following definitions shall apply:
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(A) "Air Contaminant" means dust, ash, fumes/
gas, mist, smoke, vappr, odor, or any particulate
matter or a combination thereof present in the
outdoor atmosphere.
(B) "Air Pollution Control District" means the
geographical area designated as such' by the map
and legal description attached hereto and by this
reference made a part hereof.
(C) "Board" means the Butte-Silver Bow Board of ,
Health defined by Ordinance 68.
(D) "Class I Permit" means an emission permit
issued by the Government to operate a residential
solid fuel burning device during an Air Pollution
Alert.
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(E) "EPA Method" means 40 CFR Part 60, Subpart*
i **
AAA, Sections 60.531, 0^534, and 60.53,5. . *
(F) "Emission* means a release into the outdoor
t
atmosphere of an air contaminant.
(G) "Government" means the local government of
Butte-Silver Bow.
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(H) "Opacity" means a measurement of visible
emissions defined as the degree expressed in
percent to which emissions reduce the transmission
of light and obscure the view of an object in the
background. Opacity shall be determined only by
Government personnel who have . successfully com-
pleted the Montana Department of Health and
Environmental Sciences Visual Emissions Evaluation
Course and hold a current qualification.
(I) "Oregon Method" means Oregon Department of
Environmental Quality "Standard Method for Mea-
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oo
suring the Emissions and Efficiencies of Wood-
stoves"/ Sections I. through 8 and O.A.R. Chapter
340. Division 21 Sections 100, 130, 140, 145, 160,
161, 163, 164, 165.
(J) "Residential Solid Fuel Burning Device" means
any fireplace, fireplace insert, wood stove, wood
burning heater, wood fired boiler, coal-fired
furnace, coal stove, or similar device burning any
solid fuel used for aesthetic, cooking, or heating
purposes, which burns less than 1,000,000 B.T.U.'s
per hour.
(K) "Sole Source of Heat" means one or more
residential solid fuel burning devices which
constitute the only source of heat in a private
residence for purpose of space heating. No
residential solid fuel burner or burners shall be
considered to be the sole source of heat if the
private residence is equipped with a permanently
installed furnace or heating system, designed to
heat the residence connected or disconnected from
its energy source, utilizing oil, natural gas,
electricity, or propane. A sole source permit may
be issued by the government when the heating
system is only minimally sufficient to keep the
plumbing from freezing. Only residences equipped
with a residential solid fuel burning device which
qualifies for a Class I Permit may obtain a new
Sole Source of Heat Permit after July 1, 1988.
(L) "Special Need" means a person who demon-
strates an economic need to burn solid fuel for
. residential space heating purposes by qualifying
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for energy assistance according to economic
guidelines established by the U.S. Office of
Management and Budget under the Low Income Energy
Assistance Program "L.I.E.A.P." as administered in
the City and County of Butte-Silver Bow by the
District 12 Human Resource Development Council.
i , »
(M) "Particulate Matter". Ten '(PM-10) means
particulate matter up to a nominal size of 10
micrometers.
SECTION 5: REGULATIONS;
i
(A) Solid Fuel Burning Devices
1. Within the air pollution control dis-
trict, no person owning or operating a
residential solid fuel burning device shall
cause, allow, or discharge emissions from
such device which are of an opacity greater
than twenty five (25) percent.
2. The provisions of this subsection shall
not apply to emissions during the building of
a new fire, for a period or periods aggre-
gating no more than thirty (30) minutes in
any four (4) hour period.
3. Within the Air Pollution .Control Dis-
trict, no person in control of a residential
solid fuel burning device shall emit any
visible emission from such device during an
Air Pollution Alert declared by the Govern-
-,ant unlaaa a Sola Scurca of Heat, Special
Need Permit, Class I Permit or a Temporary
Sole Source of Heat Permit has been issued
for such device.
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4. Within the Air Pollution Control D
trict, no person*in control of a resident:
solid fuel burning device for which a S<
Source of Heat, special need or Class
Permit has been issued shall cause, allow
discharge any emissions from such devi
which are of an opacity greater than ten (1
percent during an Air Pollution Alert d
clared by the Government. The provisions
this paragraph shall not apply to emissio
during the building of a new five or f
refueling for a period or periods aggregati
no more than thirty (30) minutes in any fo
(4) hour period.
5. For the purpose of this section, t]
Government may declare an Air Pollution Ale:
to be in effect whenever the ambient concei
tration of (PM-10) within the Air Pollutie
Control District equals or exceeds 10
micrograms per cubic meter (ug/m ) average
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over any four (4) hour period and whe
scientific and meterological data indicati
the average (PM-10) concentrations wilJ
remain at 100 ug/m if an Air Pollution Alert
is not called. . The Government may call an
Air Pollution Alert whenever available
scientific and meterological data indicate
that the ambient concentration of (PM-10)
within the Air Pollution Control District can
reasonably be expected to equal or exceed 100
»
, ug/m averaged over a four (4) hour period
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1 ... . within the next twenty four (24) hours. As a
2 surrogate method for (PM-10) measurement, the
3 Government may use nepheloroeter readings
4 correlated to ambient (PM-10)-concentrations.
5 6. The Government has a duty/ when declaring
6 an Air Pollution Alert to be in effect, to
7 take reasonable steps to publicize that
g information and to make it reasonably avail-
g able to the public at least three (3) hours
10 before initiating any enforcement action for
11 a violation of this subsection. *
12 7. Every person operating or in control of a
13 residential solid fuel burning device within
14 the Air Pollution Control District has a duty
15 to know when an air pollution alert has been
16 declared by the Government.
17 I B. Solid Fuel
18 1. Within the Air Pollution Control District
19 no person shall burn any material in a
20 residential solid fuel burning device except
21 black and white newspaper, untreated wood and .
22 lumber, and products manufactured for the
23 sole purpose of use as fuel. Products
2'J manufactured or processed for use as fuel
25 must conform to other applicable sections of
26 this program
27 2. The use of coal as a fuel in a residen-
2S tial solid fuel t-urning device is prohibited
2-f) within the Air Pollution Control District.
30 C. Liquid Fuel
31 1. It shall be a violation of this Ordinance
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to allow diesel fuel burning vehicles or
locomotives to idle over a period exceeding
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one (1) hour during an Air Pollution AJ.ert.
SECTION 6: PERMIT; 4
(A) Class I Permits
1. The Government may issue a Class I Permit
for solid fuel burning devices if the emis-
sions do not exceed 3.0 grams per hour
weighted average when tested in conformance
with the Oregon Method or 4.1 grains per hour
weighted average when tested using the EPA
Method.
2. Class I permits issued for solid fuel
burning device which may be operated during
an Air Pollution Alert shall be valid for a
period of two (2) years for any solid fuel
burning device. They shall not be transfer-
able from person to person or from place to
place unless reissued by the Government.
After a Class I Permit expires, the Govern-
ment shall require information to determine
if the solid fuel burning device is capable
of meeting emission requirements before
issuing another permit.'
(B) Sole Source Heat Permit
1. Within the Air Pollution Control Dis-
trict, no personal in control of a residen-
tial solid fuel burning davice which is a
Sole Source of Heat shall cause, allow, or
discharge any emissions from such device
which are of a opacity greatet than ten (10)
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percent during an Air Pollution Alert called
by the Government unless a source of heat
permit has been issued for a residential
solid fuel burning device by the Government.
Sole Source Heat Permits shall be valid for
one (1) year. t .
(C) Temporary Sole Source of Heat Permit
1. In an emergency situation the Government
may issue a Temporary Sole Source of Heat
Permit. An emergency situation shall include
but is not limited to a situation where a
person demonstrates that his furnace or
central heating system is inoperable other
than through his own actions or the situation
where the furnace or central heating system
is involuntarily disconnected from its energy
source by a public utility or other fuel
supplier. The term of the Temporary Sole
Source of Heat Permit is at the discretion of
the Government based on need.
(D) Special Needs Permit
1. A person who demonstrates an economic
need to burn solid fuel for residential space
heating purposes by qualifying for energy
assistance according' to economic guidelines
established by the U.S. Office of Management
and Budget under the Low Income Energy
Assistance Program (L.I.E.A.P.) as adminis-
tered in the City and County of Butte-Silver
Bow by the District 12 Human Resource Devel-
opment Council, is eligible for a Special
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02
Need Permit which shall be issued by th
A Government.
2. Application for a special need permit ma:
be made to the Government at any time/ and i
special need permit shall be valid for s
period of not more than one (1) year from the
date it is issued. Special Need Permits may
be renewed providing the''applicant meets the
applicable need, and economic guidelines at
the time of application for renewal. Special
Need Permits shall be issued at no cost to
» the applicant. A Special Need Permit is not
i
transferable from place to place and is not
' transferable' to a person other than the
, person-to whom it is'issued.* «
SECTION 7: ENFORCEMENTt * ,'
» . ' »
1. The 'provisions of this Ordinance shall be
"r
enforced by the Butte-Silver Bow Health Department
health authorities or the appropriate law enforce-
ment officials.
2. Sole Source of Heat Permits, Special Need
Permits, Class I Permits and Temporary Sole Source
of Heat Permits for residential solid fuel burning
devices can be issued, denied, suspended and
revoked.
SECTION 8: PENALTIES; The minimum schedule of penalties for
violations of this Ordinance is as follows:
(A) First Violation - Twenty five dollars
($25.00)
(D) Second Violation - Fifty dollars ($50.00)
(C) Third or Subsequent Violation - One hundred
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L'S
SECTION 9:
SECTION 10:
SECTION 11:
dollars ($100.00)
(D) Np person or entity shall be cited for a
violation of this Ordinance more than once in any
Calendar Day. However, each Calendar Day of
violation may be considered a separate offense.
(E) For the purpose of Section 9, only those
violations of the Ordinance by a person or entity
which have occurred with one (1) year of a present
offense shall be considered as prior violations
(F) Violation of this Ordinance shall be consi-
dered a MISDEMEANOR punishable by a fine not to
exceed $500.00 and imprisonment in the county jail
for a term not to exceed six (6) months, or by
both a fine and imprisonment.
t
(G) Jurisdiction shall be in the Police Court of
Butte-Silver Bow.
SEVERABILITY: If any provision of this Ordinance,
or any section thereof, in any circumstances is
'
held invalid, the validity of the remainder of the
,*«» *«
Ordinance and of the application of any of the
other provisions * or sections shall not be af-
i 4
fee ted. "' « *
' « «
REPEALER; All ordinances and resolutions -in
conflict herewith are repealed.
EFFECTIVE DATE; This Ordinance shall be in full
force and effect from and after thirty days after
its passage and approval,
PASSED this 3rd day of AUGUST , 1988.
WL
CHAIRMAN OF THE COUNCIL OF COMMISSIONERS
"1
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./ 196
CHIEF EXECUTIVE
ATTEST
CLERK AND RECORD
APPROVED AS TO FORM:
COUNTY ATTORNEY
CHAIRMAN OF THE JUDICIARY COMMITTEE
II
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Appendix C
Item 4
TELLURIDE, COLORADO
Note: Illustrates:
Local standards more stringent than prevailing state
or federal standards (pp. 2-3)
Registration and permitting system for new and
existing RWC devices (pp. 3-4)
Limits one RWC device per dwelling (p. 4)
Ban on coal use (p. 4)
Emission fee in $/gram for certified levels (p. 5)
Fireplaces restricted to certain public areas (p. 5)
Mandatory retrofit of fireplaces (p. 5)
Fuel quality specifications (p. 5)
Rebates for conversion to alternative heating (p. 6)
Two for one offsets -- two permits for existing units
must be retired for each new device installed (pp.
6-7)
Inspection and enforcement (p. 7)
Appeals procedures (p. 8)
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Chapter 8.12
SOLID FUEL BURNERS
Sections:
8.12.010 Definitions
8.12.020 Standards for Regulation of Solid
Fuel Burning Devices
8.12.030 Administration
8.12.040 General Rules and Regulations
8.12.050 Abateaent
8.12.060 Number of Permits
8.12.070 Investigation and
Noncoa.pl iance
8.12.080 Appeals to Board of Adjustment
8.12.090 Penalties
8.12.100 Colorado Department of Health
8.12.010 Definitions
A. For the purposes of this Chapter, unless otherwise apparen
from the context, certain words and phrases used in this Chapter
are defined as follows:
1. "Appendix A" and "Appendix B" means the test procedures
promulgated by the State Department of Health as described in
Colorado Air Pollution Regulation No. 4, in effect as of August
15, 1985. See Exhibit A incorporated in this Chapter by
reference.
2. "Commission" means the duly- constituted Town Environmental
Commission.
3. "Department" means the Town Building Department.
4. "Person" means any individual, public or private
corporation, partnership, association, firm, trust, estate or any
other legal entity whatsoever which is recognized by law as the
subject of rights and duties.
5. "Solid fuel burning device" means any device, including,
but not limited to, fireplaces or wood stoves of any nature, as
defined in C.R.S. 25-7-402, or any other device used for the
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purpose of burning combustible material. This definition
specifically excludes barbeque devices or any other authorized
burning device used in Town-sponsored activities.
6. "Structure" means anything constructed or erected, which
requires location on the ground and is a combination of roof and
supporting walls and/or columns.
7. "Unit" means an individual space consisting of enclosed
rooms occupying all or part of one or more floors of a structure,
B. Any word, term or phrase not defined or specified in this
Chapter shall be defined in accordance with the Telluride Land
Use Code, as amended.
8.12.020 Standards for Regulation of Solid
Fuel Burning Devices
A. After the effective date for registration as set forth in
section 8.12.030, no solid fuel burning device permit shall be
issued unless said device has been certified by the State of
Colorado, Department of Health, and has an emission rate
calculated as per Colorado Air Pollution Regulation No. 4,
Section IV.A., which meets the following standards:
1. The solid fuel burning device shall emit particulates at a
rate of six (6) grams per hour or less when tested in accord with
Appendix A or four (4) grams per hour or less when tested in
accord with Appendix B.
2. No solid fuel burning 'device permit shall be issued unless
said device emits carbon monoxide (CO) at a rate of two hundred
(200) grams per hour or less, when tested in accordance with
Appendix A or Appendix B, whichever is more stringent.
3. In the event the state, San Miguel County, or the
Commission establishes more stringent emission standards, the
most stringent standards shall apply.
4. This standard specifically excludes solid fuel burning
devices registered according to the provisions of section
8.12.030 of this Chapter; notwithstanding, however, all solid
fuel burning devices shall be subject to the provisions for
abatement in section 8.12.050 of this Chapter.
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B. Any solid fuel burning device so certified as being with
the standards set forth herein shall be presumed to be operated
within the limits of those standards. Additional solid fuel
burning devices may be certified by the Department upon the
applicant's demonstration through testing that the solid fuel
burning device will meet these standards, provided tests on that
proposed model are conducted by a testing laboratory accredited
by the State of Colorado using a standard method and the results
are calculated according to TMC section 8.12.070.A as specified
in Air Pollution Control Regulation No. 4.
C. On or before August 1st of each year, beginning with Augus
of 1985, the Department will prepare a list of solid fuel bumin<
devices known to be certified, which list shall be available for
inspection of the Department's offices.
8.12.030 Administration
A. Between August 15, 1985 and October 15, 1985, all persons
who own real property wherein a solid fuel burning device is
maintained, used or operated within the Town shall register such
device with the Town Clerk on forms provided at the Town Hall.
If the owner does, not register such device by October 15, 1985,
the lessee, if any, may register such device within ten days
after the date in the same manner as set forth in this Chapter.
The right to register for a solid fuel burning device permit
shall be relinquished if no permit is applied for within the time
frame as set forth in this section. There shall be an
administration fee of fifty dollars for registration and issuance
of a permit. No solid fuel burning device permit shall be issued
unless the device is in existence within the structure prior to
September 15, 1985, or is planned for a structure in which there
is at a minimum a foundation in place prior to September 15,
1985.
B. All registrants shall be issued concurrently with the
registration of their solid fuel burning device a solid fuel
burning device permit which shall: identify the solid fuel
cookstove, fireplace insert, etc.; identify the number of solid
fuel burning devices in each individually owned unit; and
identify the name(s) and address(es) of the unit owner(s) or'
lessee(s). The original permit shall be valid for three years or
until October 15, 1988. Prior to March 1, 1989, the Department
will inspect each premises subject to a permit and validate the
permit as to full compliance with all provisions of this
Chapter. Upon validation this permit will remain in effect as
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long as Chapter 8.12 of the Telluride Municipal Cod* is in
effect, provided, however, that such permits may be subsequently
modified or terminated by the Town Council or its designee.
C. On or before August of 1985, the Department will prepare a
list of solid fuel burning devices known to be certified, which
list shall be available for inspection at the Department's
offices.
8.12.040 General Rules and Regulations
A. Only one solid fuel burning device shall be operated per
structure unless specifically exempted within this Chapter.
B. It shall be unlawful for any person to construct, install,
maintain, use or operate any solid fuel burning device within the
Town in any manner which is not in compliance with the provisions
of this Chapter.
C. No solid fuel burning device shall be operated in an
existing unit after the date for registration as provided in
section 8.12.030 of this Chapter without previously having
registered and obtaining a solid fuel burning device permit.
D. No coal shall be burned after October 15, 1985, unless used
as a primary heat source as of October 15, 1985. There shall be
a presumption of prior use upon the person using a solid fuel
burning device to burn coal, submitting an affidavit attesting to
this use to the Department on or before October 15, 1985. On or
after September 15, 1988, no coal shall be burned by any person
within the Town.
E. After the date for registration as provided in section
8.12.030 of this Chapter no building permits shall be issued for
a new structure which has plans or other provisions for a solid
fuel burning device unless there is:
1. Only one solid fuel burning device, which complies with the
particulate emission standard and the carbon monoxide standard
set forth in section 8.12.020 of this Chapter; and
2. The solid fuel burning device complies with the
manufacturer's installation requirements according to the
standards of the Town Building Department; and
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3. The solid fuel burning device does result in a net increas
in heating energy, that is, the heat energy gained by the unit &
structure oust be greater than the heat energy lost by the unit
or structure; and
4. A solid fuel burning device permit has been obtained from
the Town and the applicant has paid the required permit fee; and
5. In the event the cap on solid fuel burning device permits
is lifted by Town Council, the applicant for the permit must pay
an impact fee of seventy-five ($75) dollars per gran of
particulate emission per hour on that model of solid fuel burnim
device as determined by the standards defined in section 8.12.02
of this Chapter.
F. After the date for registration as provided in section
8.12.030, only one open fireplace will be allowed in the
following establishments: hotel lobby, multiple unit dwelling
lobby, bar/saloon, or restaurant. No open fireplaces will be
allowed in a new home construction.
G. Residential and commercial owners of existing fireplaces
will be required to retrofit their fireplaces with a certified
fireplace insert by October 15, 1988, as defined by the
requirements of certification by Colorado Air Pollution
Regulation No. 4.
H. All combustible material for use in a solid fuel burning
device shall be in a dry and burnable condition and safely storei
so as not to create a fire hazard.
I. All permits may be displayed so as to be clearly visible
from the public right-of-way.
J. Wood cookstoves will be exempt from the requirements of
this Chapter providing that those stoves are used as a primary
cooking source in the house and are in place on or before August
15, 1985. This exemption extends only for the lifetime of the
wood cookstove owner and is, therefore, not transferable.
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8.12.050 Abatement
A. After October 15, 1988, no person within the Town of
Telluride shall operate, construct, use or install a solid fuel
burning device unless he or she has obtained a permit froa the
Town and the solid fuel burning device complies as follows:
1. With the particulate emission standard and carbon monoxide
emission standard set forth in section 8.12.020 of this Chapter;
and
2. There is not more than one solid fuel burning device per
unit or structure; and
3. A permit has been issued by the Town for the solid fuel
burning device.
B. A rebate program is hereby established for solid fuel
burning device replacements as required within this Chapter: a
rebate of $200 for devices replaced from September 15, 1985 to
October 15, 1986; a rebate of $150 for devices replaced from
October 15, 1986 - October 15, 1987, and a rebate of $100 for
devices replaced from October 15, 1987 to October 15, 1988. A
full rebate of $250 will be given for total conversion to gas,
propane or electric at any time during the October 15, 1985 to
October 15, 1988 compliance period. This full rebate is
available only to residents who replace the existing permitted
solid fuel burning device(s) with a non-solid fuel heat source.
The permit for the extinct solid fuel burning device(s) shall
then be validated by the Building Department so that it may be
sold or used toward the two (2) permits required for installation
of one (1) solid fuel burning device in the future, in accordance
with section 8.12.030.C of the Telluride Municipal Code.
8.12.060 Number of Permits
A. The Town Council shall allow no additional solid fuel
burning device permits for new construction to be issued after
the date for registration as provided in section 8.12.030 within
the town. Upon the completion of modeling studies to be
conducted by the Commission in a written report to be filed with
the Town Council on or before October 1, 1986, issuance of
additional permits may be considered by the Town Council.
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B. It will be possible for a person wishing to install a new
solid fuel burning device in a structure to purchase two
relinquished permits, if any are available, in order to install
one new solid fuel burning device. In this event, the purchaser
oust present to the Town Hall proof of purchase of two permits
and verification of two deed restrictions, stating that no solid
fuel burning device may be used in that unit or structure as Ion
as this Chapter is in effect, in order to install the new solid
fuel burning device in a structure. Confonoance to all of the
provisions of this Chapter will also apply.
8.12.070 Investigation and Noncompliance
A. The Building Department shall inspect each solid fuel
burning device as reflected by the records of the Department.
The purpose of the inspection shall be to determine that the
permitholder is in compliance with the provisions of this
Chapter. If a permitholder or person operating the solid fuel
burning device refuses to consent to the Department's inspection
the Department may upon a showing of reasonable grounds for the
purpose of inspecting solid fuel burning devices only, apply for
an inspection warrant from the Municipal Court and execute and
conduct the inspection under order of the Court.
B. When the Department has reasonable grounds based upon its
investigation or upon written complaints sufficiently
demonstrating reasonable grounds that a person has violated this
Chapter, the Department shall issue a notice and order setting
forth alleged violations and the corrective actions that need to
be taken. The Department shall allow thirty days for the person
to take the necessary corrective actions and comply with this
Chapter.
C. When a person has not complied with the Department's notice
and order, the Department shall issue an order of noncompliance
and institute a summons and complaint on behalf of the Town with
the Municipal Court for violation of this Chapter. The
Department may also obtain injunctive relief through the
Municipal Court in order to enforce this Chapter. Any order of
noncompliance shall be stayed in the event an aggrieved person
files a notice of appeal with the Board of Adjustment of the'Town
as set forth in section 8.12.080 of this Chapter.
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8.12.080 Appeals to the Board of Adjustment
A. An appeal of the Department's notice and order of
noncompliance shall be filed with the Board of Adjustment of the
Town in writing no later than thirty days from the date of the
Department's notice and order.
B. The Board of Adjustment shall make such rules and
regulations as it determines are necessary for the conduct of its
hearings under this Chapter, and according to any other
applicable ordinances of the Town and/or the law of the state.
C. Upon a timely filing of a notice of appeal to the Board of
Adjustment, the Board of Adjustment shall set a hearing date to
review the notice and order of the Department. This hearing date
shall be on a date certain not to be less than five (5)days, nor
more than fifteen (15) days from the filing of the date of the
notice of appeal. The Board of Adjustment shall have the power
to subpoena witnesses and a record shall be kept of the hearing.
The Board of Adjustment shall issue its decision and order upon
the appeal within ten days of the date of the hearing.
D. The Board of Adjustment may affirm, modify, rescind or
delay the compliance order based upon the following standards:
1. Planned termination of operations of the noncompliance
solid fuel burning device;
2. Planned replacement of the noncomplying solid fuel burning
device with a certified device;
3. A change in the operations of the solid fuel burning device
due to excusable malfunction;
4. Extreme hardships, or life threatening emergencies.
E. The Department shall represent the Town before the Board of
Adjustment and shall have the burden of proof to establish
noncompliance by the preponderence of the evidence.
F. The order of the Board of Adjustment shall take effect
immediately, and shall contain written findings. The Board of
Adjustment may grant a greater time, at its discretion.
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G. All appeals from the Board of Adjustment shall be to the
court as provided in Chapter 18.36 of the Land Use Code.
8.12.090 Penalties
Any person, upon conviction of a violation of any provision of
this Chapter, shall be subject to a fine not to exceed three
hundred dollars or imprisonment in jail for a period of not more
than ninety days, or both, at the discretion of the court, for
each separate offense, and may be enjoined from any further or
continued violation of this Chapter. Each day any violation of
this Chapter shall continue shall constitute a separate offense
under this Chapter. onense
8.12.100 Colorado Department of Health
The inspector is directed to forward this Chapter to the
Division of Administration of the Colorado Department of Health
for inclusion in the comprehensive state implementation plan,
pursuant to C.R.s. 25-7-128(1), as amended; for administration o
the local regulations as part of the state plan, pursuant to
C.R.S. 25-7-ni, as amended; and for enforcement of the local
regulations as part of the state plan, pursuant to C.R.S.
25-76-115, as amended.
EDITOR'S NOTE: This Chapter 8.12 is a codification of Ord. 677
effective August 15, 1985. Ord. 677 was amended by Ord. 682,
series 1985; by Ord. 756, series 1986; and by Ord. Nos. 764 and
797, series 1987. Chapter 8.12 was recodified by Ord. 822,
series 1988 and was amended to delete a clerical error bv Ord
series 1988. '
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Appendix C
Item 5
CRESTED BUTTE, COLORADO
Note: 2 pages excerpts illustrates woodheater installation
requirements.
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Section 6-5-7. - Installation Requirements and
Standards. The following standards and requirements shall apply to
the Installation of any solid fuel burning device within the Town:
A. Hearth Construction and Clearances.
1. There shall be a minimum of two inches clearance
between the hearth and the bottom of the fire box,
unless the hearth and clearance of less than two
inches is installed as suggested by the manufacturer
of the specific solid fuel burning device.
2. When clearance between the hearth and fire box is
between two and six Inches, the following hearth
construction is required:
a. three and one-half inch grouted hollow brick
masonry units on edge, or
b. two inches of grouted masonry with 24 gauge
sheet metal between such masonry and the fire
box, or
c. totally non-combustible construction under
the hearth including floor joists, or
d. raise the unit to the point where the fire
box is six Inches above a two inch grouted
masonry hearth with a support system acceptable
to the Town, or
e. a U.L. listed "non-combustible floor
protector", or
f. such hearth construction and clearance as are
suggested by the manufacturer of the specific
solid fuel burning device.
3. When the clearance between the hearth and fire bo*
is six Inches or more, the following hearth
construction is required:
a. a two inch grouted masonry hearth, or
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b. any hearth described above for the two inch
to six inch clearance, or
c. such hearth construction and clearance as are
suggested by the manufacturer of the specific
solid fuel burning device.
B. Stovepipes and/or chimneys shall be installed a
required by the National Fire Protection Association's
National Fire Code, 1988 Edition, Section 211, which
standards are applicable through the Uniform Fire Code
as adopted by the Town.
C. The fire box clearance from combustibles in any
direction shall be as recommended by the manufacturer of
the specific solid fuel burning device. In the absence
of such recommendations being approved by the owner of
the solid fuel burning device, the clearance shall be as
provided by the National Fire Protection Association's
National Fire Code, 1988 Edition, Section 211, which
standards are applicable through the Uniform Fire Code
as adopted by the Town.
D. Any solid fuel burning device installed upon or
within any new construction shall have a piped
combustion air source originating outside of the
structure.
Section 6-5-8. - Application of License Fees. The
license fees collected pursuant to Section 6-5-4 of this Article
shall be applied as follows:
A. air pollution reduction programs,
B. hiring and/or paying of personnel to enforce air
pollution ordinances and regulations,
C. the improvement or replacement of solid fuel burning
devices maintained by the Town or other public entitles,
or
D. any other purpose of the Town Council determines will
improve air quality within the Town.
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APPENDIX D
EPA FACT SHEET ON HEALTH
EFFECTS FROM RWC EMISSIONS
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POTENTIAL HEALTH EFFECTS ASSOCIATED WITH WOODSMOKE
NATURE OF THE EXPOSURE
* Wood heaters emit several air pollutants, including paniculate matter, carbon monoxide,
hydrocarbons, and polycyclic organic matter (POM). Paniculate matter dominates these
emissions.
* "Woodsmoke" consists almost entirely of small, respirable particles (<10 micrometers
(um)), 80% are less than 2.5 um. Thus, woodsmoke can affect all areas of the respiratory
tract and readily reach the deep lung (alveolar region). Retention of panicles in the deep
lung can be quite long, with clearance times of months to years.
* The chemical composition of woodsmoke is diverse and contains a number of toxic,
irritant, and carcinogenic compounds.
* In some areas respirable particles from woodsmoke can easily exceed all other forms of
ambient air pollution, and on occasion, health-based ambient air quality standards have
been exceeded several fold. In addition, residential wood combustion can be a major
source of POM emissions, a class of compounds containing carcinogens.
* Woodsmoke generally accumulates near where it is emitted, directly impacting area
residents.
HEALTH EFFECTS
Overview
* Health concerns of woodsmoke are associated both with short-term and long-term
exposures, particularly where air pollution standards for paniculate matter are exceeded.
* Studies examining the effects of paniculate air pollution on human populations
(epidemiological studies) provide the bulk of the health effects information relevant to
woodsmoke. Based on characteristics of particle size and chemical composition, there is
no reason to believe that woodsmoke is less toxic or damaging than the general particulate
matter measures obtained in these studies; in some instances woodsmoke may be of
greater concern and the available health evidence summarized below may not fully
characterize health risks associated with woodsmoke.
* Healthy adults may not notice outward effects at high levels other than simple eye, nose,
or throat irritation.
* The major groups that should be concerned about more serious respiratory and other
responses are people with existing respiratory and cardiovascular disease (for example,
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asthma, bronchitis, heart disease), the elderly and children. These individuals may
experience a variety of oven symptoms such as cough, wheeze, shortness of breath, and
chest pain, with increased difficulty associated with everyday activities involving physical
exertion. At times symptoms may not be noticeable until several days after pollution
episodes.
* Children may be at risk as they breathe woodsmoke deep into their lungs for extended
periods while exercising at play.
* Studies have established that exposure to POM-containing mixtures is associated with
an excess incidence of lung cancer in humans. Exposure to POM in woodsmoke
may therefore pose some cancer risk.
Short-term Exposures
* Clear evidence from epidemiological studies implicates paniculate pollution in aggravating
disease among bronchitics, asthmatics, cardiovascular patients, and people with influenza
(U.S. Environmental Protection Agency, 1982, 1986).
* Specifically, paniculate matter pollution may:
- Increase mucus loading or otherwise affect the airways of bronchitics, aggravating their
debility.
- Cause bronchoconstriction (a common response to respiratory irritants) in a variety of
individuals (e.g., asthmatics, bronchitics) or even asthma "attacks" in some instances.
Associated depression in lung function may be incapacitating or even life threatening
for severely ill or sensitive patients.
- Affect oxygen uptake in the alveolar region; this is particularly important for patients
with severely compromised lung capacity (e.g., emphysema).
* Laboratory studies indicate that mucociliary clearance (the ability of the respiratory tract
to clear foreign particles, bacteria, etc.) or other lung defense mechanisms may be altered.
Several community epidemiological studies suggest increased respiratory infection during
pollution episodes.
* Particulate pollution episodes are associated with reduced lung function in children, these
changes may persist for up to two weeks after the exposure (Dockery et al., 1982).
* Studies conducted in areas with high paniculate pollution, comparable to levels
occasionally reported in areas heavily impacted by woodsmoke (i.e., 4-5 times the ambient
standard), report increases in mortality in the elderly and other sensitive populations (see
U.S. Environmental Protection Agency, 1982, 1986).
Long-term Exposures
* The effects of chronic exposure to air pollution can be quite difficult to discern without
fairly involved epidemiologic techniques. For paniculate pollution, a number of
community epidemiological studies indicate higher prevalance of respiratory symptoms
such as wheeze and cough, increased respiratory illness and disease, or lower lung
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function for populations living in areas of high pollution. In particular, children in such
areas may show increase! rates of illness (e.g., Ware et al., 1986), which might have
longer-term consequences.
Long-term exposure to particles has produced lung tissue damage in laboratory animals.
The presence of carcinogenic compounds in woodsmoke, and potential interaction with
other pollutants and cigarette smoke, raises some concern about possible lung cancer in
exposed populations.
REFERENCES
Dockery, D. W., et al. (1982) Changes in pulmonary function associated with air pollution
episodes. J. Air Pollut. Control Assoc. 32: 937-942.
U. S. Environmental Protection Agency. (1982) Air quality criteria for paniculate matter and
sulfur oxides. Research Triangle Park, NC: Office of Health and Environmental
Assessment, Environmental Criteria and Assessment Office; EPA report nos. EPA-600/8-
82-029-cF. 3v.
U. S. Environmental Protection Agency. (1986) Second addendum to air quality criteria for
particulate matter and sulfur oxides (1982): assessment of newly available health effects
information. Research Triangle Park, NC: Office of Health and Environmental
Assessment, Environmental Criteria and Assessment Office; EPA report no. EPA 600/8-
86/020F.
Ware, J.H., et al. (1986) Effects of ambient sulfur oxides and suspended particles on
respiratory health of preadolescent children. Am Rev. Respir. Dis. 133:834-842.
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APPENDIX E
HOW TO APPLY ESTIMATES OF EFFECTIVENESS TO DETERMINE TOTAL PM-10
SIP EMISSION REDUCTION CREDITS
In preparing the SIPs to address PM-10 nonattainment, it is necessary to
estimate how effective a given RWC emission control program will .be in
reducing ambient levels of PM-10. These estimates are referred to as
"credits." The credits are applied to the highest ambient levels that have
been experienced or are forecasted to occur (i.e., the design day or design
year conditions).
The purpose of this section is to explain this general process and to
illustrate specifically how credits from various program elements can be
combined to demonstrate attainment. For the hypothetical example, only the
24-hour standard -- which is sole cause of PM-10 NAAQS violation among
existing areas with serious RWC emissions problems -- is addressed. A similar
approach must also be used to address the annual standard.
1.0 GENERAL APPROACH TO DEMONSTRATING ATTAINMENT
In general the process of demonstrating attainment with the PM-10 NAAQS
includes the following six steps:
Step 1 -- Based on monitoring and modeling results determine the worst
case or design day ambient concentrations and the improvement in ambient
quality needed to attain the NAAQS.
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Step 2 -- Based on modeling or other source apportionment techniques
determine the proportion of PM-10 concentrations attributable to RWC compared
to PM-10 from all sources, as measured during the design day.
Step 3 -- Based on the overall PM-10 emission inventory for all source
categories -- such as RWC, road sanding, diesel exhaust, industrial emissions,
etc. -- determine overall emission reductions needed to attain the NAAQS.
This is accomplished by multiplying the percentage reduction needed (from Step
2) by the total PM-10 emitted during the design day (or design year, if the
annual standard is violated).
Step 4 -- Based on the contribution of various source categories and the
costs, effectiveness, and acceptability of controlling these sources, decide
which source categories should be controlled and which control programs will
be deployed in order to demonstrate attainment with the PM-10 NAAQS. Not all
source categories will be able to make the same percentage reductions in
emissions because of technical and economic difficulties. Therefore, policy
decisions on the degree of reduction from each control program will be
necessary.
Step 5 -- Based on the total estimate of PM-10 from RWC (from the
inventory in Step 3 and discussed in Appendix A of this report) and on the
policy decisions regarding the degree of emission reduction required from each
source category, it is possible to calculate the quantity of PM-10 reductions
needed from RWC. This becomes the emission reduction target.
Step 6 -- Select from among the various program elements in Section 3
through 5 of this report in order to find one element or a combination that
can accomplish the net emission reduction calculated in Step 5.
Typically there will be several iterations between steps 4-6 in order to
select the most cost-effective and most acceptable measures.
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The example in Section 2 below is a hypothetical illustration of all six
steps. Section 3 and 4 provide details that illustrate the application of the
credits and how to calculate the accumulative credits.
2.0 EXAMPLE -- SMALL TOWN WITH MODERATE PM-10 EXCEEDANCES
A town of 3,000 population set in a high mountain valley is determined
to be in violation of the 24-hour PM-10 NAAQS of 150
Step 1 - - Atmospheric monitoring results along with supplemental or
confirmatory modeling analyses show that last winter there were a dozen days
in which the PM-10 NAAQS was exceeded. The worst of these was a 300 Mg/ra3
episode. This is the design day. The area SIP is required to show a 150
/ig/m3 reduction in PM-10 ambient concentrations to demonstrate attainment with
the NAAQS.
Step 2 -- Based on modeling studies, it was determined that two- thirds
of all PM-10 concentrations on the design day are from RWC. In other words,
when the ambient PM-10 concentrations were at 300 /ig/m3, two thirds or 200
of PM-10 are attributable to RWC.
Step 3 -- The town staff prepares an emission inventory of all PM-10
sources and of RWC emissions based on a survey and emission estimating
techniques presented in Appendix A. PM-10 emissions on the design day are 465
Kg with RWC sources accounting for 310 Kg.
Step 4 -- The town council examines various alternatives for reducing
PM-10 emissions on the design day. They decide that paving the few unpaved
streets and their relying on RWC controls is the most cost effective and least
disruptive strategy for attaining the PM-10 NAAQS.
Step 5 -- Having decided that they can get about 65 percent of the
ambient improvement needed from street paving, the council must come up with
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the remaining 35 percent from RWC emissions reduction. Because emissions
reduction and ambient concentration reduction is assumed to be linear, the
cutback in RWC emissions is calculated to be 65 percent.
The 65 percent emission reduction must be applied to the baseline
inventory of RWC sources. (Appendix A of this report provides suggestions and
further references for developing such as inventory.) Following are some of
the base line inventory data for the design day extracted from the
hypothetical RWC inventory developed by the town staff (noted in Step 3).
600 conventional woodstoves emit: 200 kg/day (or 0.33 kg per
unit);
200 certified stoves (1/3 of which are EPA Phase II) emit: 40
kg/day (or 0.2 kg per unit);
100 fireplaces emit: 70 kg/day (or 0.7 kg per unit) based on very
limited number of hours that fireplaces are believed to be
operated;
Total: 310 kg/day all RWC sources (200 plus 40 plus 70).
If the total RWC emissions on the design day are 310 kg and if a 65
percent emission reduction is needed from RWC to demonstrate attainment with
the 24-hour PM-10 NAAOS. the amount of emission reduction from RWC sources is
310 kg X 0.65 - 202 kg. This 202 kg is the PM-10 emission reduction target
for RWC.
Step 6 -- Out of concern over health issues and the deteriorating
visibility over much of the winter, the town council decides to implement a
variety of measures that will address both the persistent and episodic
woodsmoke problem. The measures the council selected were from among those
presented in this report and summarized in Appendix F. The council hopes
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measures they have selected will achieve the 202 kg reduction needed to
demonstrate attainment with the 24-hour standard for PM-10. The hypothetical
measures are described below in Section 3.0 along with the emission credits
EPA agreed to award for each. The actual calculation of these credits is
provided in Section 4.0.
3.0 DESCRIPTION OF MEASURES AND CREDITS IN HYPOTHETICAL EXAMPLE
Registration and Permit System
In order to establish control over the growth of new RWC population and
the existing RWC population, the council decides to require all existing RWC
devices to be registered and issued a permit within 30 days. To pay for the
administration of the program and to fund a public awareness/education
program, the council establishes a permit fee of $30. The council also votes
to make it a crime (misdemeanor) to operate an RWC device without a permit.
Finally, the council also requests that the staff, working with the EPA Region
and State officials, develop a public awareness program.
Public Awareness/Education
The city staff decides to have a two-phase public awareness/education
effort. The first phase, which occurs during the 30-day registration period,
focuses on persuading the public that there is a problem and informing them of
the various approaches available for resolving the problem. The second phase,
which will begin with the adoption of the control measures, will continue the
persuasion effort, provide education material on RWC appliance selection and
operation, and provide specific information on the reason for and means of
complying with the control measures.
During Phase I, the council holds two public hearings (town hall type
meetings). The first focuses on the extent and causes of the woodsmoke
problem, the effects of woodsmoke on health and the local tourist industry,
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and a description of the various approaches. EPA and State experts make
presentations and field questions from the public. On the day before the
hearing, the experts make presentations at the local school and at two civic
groups. The local newspaper agrees to run a series of articles on these
topics before the second hearing, which focuses on a discussion of control
measures.
Although no emission reduction credits are given to the town by EPA for
this public awareness effort, the EPA regional staff are optimistic about the
eventual success of the overall program (i.e., package of control measures or
program elements) because of the increased likelihood of public support
generated by the public awareness program element.
Alternative Fuels Initiative
During the public hearings, the local LPG (liquid petroleum gas--
butane /propane) distributor offers to pay the LPG installation costs for the
first 200 owners of existing uncertified RWC devices who switch from wood to
LPG for residential heating if the town will pay each RWC device owner $100
for the voluntary surrender of his permit. The town council agrees to do
this. The EPA estimates that this will result in the removal of 25 fireplaces
and 175 conventional stoves during the first year of the program. The EPA
will grant a 100 percent emission credit for each unit involved in this
effort.
RWC Inspection Program
The town council decides to require that the permits be renewed each
year. The conditions of renewal are a $10 registration fee and a
certification that the RWC device (including the flue and chimney apparatus)
and the dwelling have been inspected by an industry-accredited and town
council-approved inspector. The EPA agrees to apply a 5 percent emission
credit for the RWC appliance inspection element. The credit will be applied
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to the emissions remaining after the application of the alternative fuels
initiative.
Wood Moisture
The inspector certification described above also includes a requirement
that each RWC device owner demonstrate that he has a covered wood shed and use
only wood that has been seasoned for nine months. Inspectors are encouraged
to use moisture meters or make visual observations to confirm that these
conditions are being met. The EPA agrees to allow another 5 percent emission
credit after application of the two previous measures.
Weatherization
As a final criteria for inspector approval (and therefore permit
renewal), the residence (which contains the permitted RWC device) must meet
minimum insulation and caulking requirements to minimize heat loss. The EPA
agrees to add another 5 percent for this program element. This credit is to
be given after calculation of the foregoing elements.
Opacity Limits
The town council agrees to have the city police officer who will enforce
the curtailment program to be trained as a smoke reader in order to ensure
that opacity from chimneys do not exceed 20 percent. The opacity ordinance
would be enforced during the periods when a curtailment is not in effect (any
opacity during this period would indicate noncompliance). The EPA agrees to
recognize another 5 percent for this program element--to be subtracted after
calculation of the foregoing elements.
E-7
-------
Mandatory Curtailment
As a final measure the town council agrees to adopt an ordinance
curtailment program. During a curtailment, all fireplaces and stoves that are
not EPA certified (Phase II) would be required to cease burning under penalty
of a $50 fine (going to $100 after the first offense). The EPA agreed to
award 50 percent emission credits for each woodstove and 60 percent emission
credits for each fireplace for each RWC device affected by the curtailment
order (i.e., after application of all the preceding "permanent" measures).
4.0 MATHEMATICAL CALCULATION OF CREDITS AS APPLIED TO THE HYPOTHETICAL
EXAMPLE
1) From the discussion above, 310 kg is the design day RWC emissions
estimate based upon:
600 conventional stoves 200 kg 0.33 kg per stove
200 certified stoves (one
third Phase II certificate) 40 kg 0.20 kg per stove
100 fireplaces 70 kg 0.70 kg per fireplace
310 kg
2) The emission reduction target is 310 kg times 0.65 equals 202 kg
where 0.65 is the amount of reduction need in PM-10 emissions.
3) The alternative fuels initiative results in the following change:
25 fireplaces x .7 kg/fireplace + 175 stoves X .33 kg/stove -
17.5 kg plus 58.3 kg - 76 kg emissions removed.
4) New emission inventory after alternative fuels initiative is:
425 conventional stoves 142 kg 0.33 kg per stove
(600-175)
E-8
-------
200 certified stoves (one
third Phase II certificate) 40 kg 0.20 kg per stove
75 fireplaces (100-25) 53 kg 0.70 kg per fireplace
235 kg
5) Each of the next four emission reduction measures results in a 5
percent reduction of emissions from the inventory. These are
additive (declining balance).
235 kg x .95 x .95 x .95 x .95 - 191 kg
The cumulative emissions reduction at this point is 310 kg (the
baseline inventory) minus 191 kg (the inventory after application
of alternative fuel initiative plus RWC inspection, wood moisture,
weatherization, and opacity limits). The resulting value is 119
kg (310-191 - 119). The 119 kg in "permanent" reductions still
falls short of the 202 kg needed for design day episodes.
Therefore, curtailment is added.
6) Curtailment effects all but one-third of the certified stoves
(because an estimated one-third of these stoves are Phase II
certified stoves). Therefore the number of RWC devices affected
by curtailment, is:
425 conventional stoves x 50* « 212 x (0.33 kg) x (.95)* « 57 kg
133 certified stoves (2/3 of 200) x 50% - 66 x (0.20 kg) x (.95)' - 11 kg
75 fireplaces x 60Z - 45 x (0.70 kg) x (.95)' - 26 kg
The total emissions reduction from curtailment is 57 kg
(conventional stoves) plus 11 kg (certified stoves) plus 26 kg
(fireplaces) equals 94 kg.
E-9
-------
7) When the 94 is added to the 119 (from 5 above) the total emission
reduction is 213 kg. The 213 exceeds the emission reduction
target and, therefore, the town has demonstrated that its RWC
emission control program is sufficient to bring it into PM-10
attainment within one year.
In summary, the town council (in this hypothetical example) has
implemented a RWC emissions control program which results in an estimated
reduction of about two thirds over the RWC baseline emissions. The
combination of measures results in both permanent cutbacks and temporary
reductions and is achievable within one year.
E-10
-------
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/2-89-015
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Guidance Document for Residential Wood Combustion
Emission Control Measures
5. REPORT DATE
September 1QRQ
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
Bob Davis and Barry Read
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
Radian Corporation
8501 Mo-Pac Blvd.
P.O. Box 201088
Austin, Texas 78720-1088
11. CONTRACT/GRANT NO.
Contract No. 68-02-4392
Task No. 40
12.
SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning & Standards
Air Quality Management Division
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES Reieardi Triangle Park
Radian Project Director: Bob Davis
EPA Project Officers: Thompson G. Pace and Martha E. Smith, PM-10 Programs Section
5 ARSTRACT
16. ABSTRACT
This publication was prepared to provide guidance to State and local air pollution
control agencies with regard to emission control measures for residential wood
combustion (RWC). The guidance is specifically directed to agencies that are
required by the U.S. EPA to demonstrate through the State implementation planning
process that the national ambient air quality standard for PM-10 will be attained.
There are four categories of RWC emission control measures: public awareness,
combustion efficiency, restriction or reduction in the number of RWC devices,"
episodic curtailment. A hierarchy of effectiveness and reliability of emission
control measures is presented. Methods for developing estimates of RWC emissions
are presented in order to apply a quantitative estimate of effectiveness of
control measures.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS C. COS AT I Field/Group
Residential Wood Combustion
PM-10 Emissions
Curtailment
Public Awareness
Control Measures
Effectiveness
18. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (Tins Report!
unclassified
21
NO OF PAGES
234
2O SECURITY CLASS (This page I
unclassified
22 PRICE
EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDITION IS OBSOLETE
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