RESIDENTIAL WOOD COMBUSTION
EMISSION CONTROL MEASURES
ORPORATION
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20
Ith****
Anniversary
8501 Mo-Pac Blvd.
CORPORATION DRAFT - DO NOT CITE OR QUOTE P-°- Box 201088
Austin, TX 78720-1088
(512)454-4797
RESIDENTIAL WOOD COMBUSTION
EMISSION CONTROL MEASURES
TECHNICAL REVIEW COMMITTEE DRAFT
20 February 1989
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CONTENTS
Section
1 INTRODUCTION
1.1 Scope of This Document
1.2 Background
1.2.1 RWC Emissions: Extent of the Problem,
Causes, and Control Techniques
1.2.2 EPA's Programs for Reducing RWC Emissions
1.3 Health Effects from RWC Emissions
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 PA Media 2-8
2.4 Program Effectiveness 2-20
2.4.1 Minimal Level of Effort 2-20
2.4.2 Medium Level of Effort 2-23
2.4.3 High Level of Effort 2-23
2.4.4 Maximum Level of Effort 2-25
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 3-5
3.2.3 Ban on Resale or Installation of Used
Uncertified Wood Heaters 3-8
3.3 Installation Quality Assurance 3-13
3.3.1 Introduction 3-13
3.3.2 Installer Training and Certification .... 3-15
3.3.3 Inspections 3-16
3.4 Technology Requirements 3-17
3.4.1 Introduction 3-17
3.4.2 Pellet RWC Devices 3-18
3.4.3 Low-Emitting Stoves 3-19
3.4.4 Retrofits 3-21
3.4.5 Accelerated Changeover Requirements .... 3-22
3.4.6 Accelerated Changeover Inducements 3-23
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CONTENTS (continued)
Section
3.5 Fuel Quality
3.5.1 Introduction
3.5.2 Moisture Content Regulations
3.5.3 Trash Burning Prohibition .
3.6 Reduce Fuel Use
4 LIMITING THE POPULATION OF RWC DEVICES IN A COMMUNITY . 4-1
4.1 Backup Heat or Alternative Energy Sources 4-2
4.1.1 General 4-2
4.1.2 Facilitating Availability of Alternative
Fuels 4-2
4.1.3 Economic Incentives (Loans and Fuel Subsidies) 4-6
4.2 Limiting RWC in New Dwellings 4-7
4.2.1 Ban on RWC Devices 4-8
4.2.2 Construction Offsets 4-11
4.2.3 Taxes on New Stoves 4-14
4.3 Eliminate Wood Burning 4-14
4.3.1 Incentives to Remove/Disable Appliances . . 4-15
4.3.2 Regulatory Requirements for Elimination of
RWC Devices 4-16
5. 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 5-11
5.1.6 Exemptions 5-11
5.1.7 Adapting the Plan 5-16
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 5-21
5.4 Enforcement 5-24
5.5 Program Effectiveness 5-29
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CONTENTS (continued)
Section
6. HOW TO APPLY ESTIMATES OF EFFECTIVENESS TO DETERMINE
TOTAL PM-10 SIP EMISSION REDUCTION CREDITS 6-1
6.1 General Approach to Demonstrating Attainment . . .
6-1 6.2 First Example -- Small Town with Moderate PM-10
Exceedances 6-2
6.3 Second Example -- Medium Sized City with Severe
PM-10 Nonattainment Problem 6-4
7. REFERENCES AND SOURCE MATERIAL 7-1
7.1 List of Personal Contacts 7-1
7.2 Written References 7-1
7.3 Bibliography 7-1
Appendices
A. Techniques for Estimating RWC Emissions A-l
B. Report Sponsor, Authors, and Reviewers .B-l
C. RWC Emission Control Ordinances C-l
D. EPA Fact Sheet on Health Effects from RWC Emissions . . D-l
IV
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FIGURES
Figure No. Page
2-1 Some representative brochures discussing a variety of RWC
devices 2-18
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 of Effectiveness for Hypothetical Public
Awareness Program Elements 2-21
3-1 Levels of Effectiveness for Hypothetical Improvement of
Performance Program Element 3-9
4-1 Levels of Effectiveness for Hypothetical Alternative
Fuel Use Program Element 4-5
4-2 Levels of Effectiveness for Hypothetical Restrictions
on RWC Devices in New Dwellings 4-12
4-3 Levels of Effectiveness for Hypothetical Incentives
for Eliminating RWC Devices 4-17
5-1 Curtailment and Complementary Program Elements 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 5-14
5-4 Methods of Notifying Residents of No Burn Conditions . . 5-18
5-5 Methods of Surveillance for Identifying Curtailment
Noncompliance 5-25
5-6 Penalties and Disincentives for Noncompliance 5-26
5-7 Reported Curtailment Program Effectiveness Levels .... 5-30
5-8(a) Assumed Effectiveness for a Baseline Curtailment Program 5-31
5-8(b) Assumed Effectiveness for a Most Stringent Curtailment
Program 5-33
5-8(c) Assumed Effectiveness for a Less Stringent Curtailment
Program 5-35
5-8(d) Assumed Effectiveness for a Voluntary Curtailment Program 5-37
7-1 List of Personal Contacts 7-2
7-2 Written References 7-4
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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 diameter or less (PM-10).
It can also be used for areas that -- although in attainment of the PM-10
standard -- want to reduce PM-10 emissions from woodsmoke in order to further
reduce health risks or to improve visibility.
This introduction includes an extensive 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.
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,
is aware of the full range of benefits from controlling RWC emissions,, and
knows how to reduce these emissions.
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Section 3 addresses control measures that have as their objective an
improvement in combustion efficiency. These measures include: (1) banning
all but high technology low-emitting RWC devices, (2) ensuring proper instal-
lation of RWC devices, (3) upgrading fuel quality, and (4) reducing demand for
fuel use through weatherization of residences conservation and other techni-
ques .
Section 4 discusses measures that have as their objective the reduction
of the number of RWC devices. This occurs through conversion 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 a relatively few 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 in evaluating PM-10 SIPs. These estimates are based primarily upon
the informed judgement of the authors of this report and of the Technical
Review Committee of knowledgeable authorities in the field. Many of these
estimates of effectiveness are intended to be examples of the degree of credit
that would be granted for a particular control measure. This is especially
true for in public awareness where the specific kind of program must be
tailored to community value and demographics, etc.
Section 6 shows, by way of three examples, how these emission reduction
credits can be applied in RWC emission control programs consisting of separate
program elements.
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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 RWC 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
RWC emission control programs. The list of those interviewed was drawn from
recommendations from EPA staff in several 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 7.
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 emissions are presented in Appendix A along with additional 8
references for those interested in conducting community RWC surveys developing
a RWC data base.
Appendix B lists the technical review committee members and other 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.
A final note on terminology and the scope of this document: although the
topic is residential wood combustion, often many of the programs are aimed
broadly at all solid fuel combustion (which would include coal-fired heaters)
in residences as well as other nonresidential settings (stores, shops,
offices, schools, etc). On the other hand, some programs pertain only to
certain types of solid fuel combustion devices while exempting others. To
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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 (Little, 1983)
indicated that there were 27 million RWC devices in use. 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 (Radian, 1986), it is
reasonable to estimate that by 1989 there were more than 33 million RWC units
--or about one for every three residences in the U.S.
RWC devices are estimated to be the largest man-made source of particu-
late matter (PM) in the country and one of the largest single sources of
carbon monoxide (CO). In gathering data to support the development of
national emission standards for enclosed wood heaters (i.e., primarily wood
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stoves and fireplace inserts), EPA estimated that in 1985 wood heaters
annually emitted 2.7 millions tons of PM 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
(EPA, ANPR, 1985).
In many areas of the country with PM-10 non-attainment 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 particulate matter
which often have tall stacks, large areas for dispersion, and are located in
nonresidential 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 /;m or less in size.
Eighty percent of RWC emissions are less than 2.5 /m. 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 (EPA, RIA, 1986).
1.2.1.2 Causes of RWC Emissions --
Simply put, the PM 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 combus-
tion situation in which carbon monoxide (CO) is formed and the particles and
organics are emitted uncombusted. A conventional wood stove -- typical of
those sold before state and federal regulations were developed -- will combust
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only about one half of the total energy available in the wood. The remainder
is emitted through the chimney in the form of CO, condensible organics, or
wood smoke particles.
The key to reducing these emissions is to improve combustion efficiency
by burning most of these unburned 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 --
Emission control technology--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 efficiencies of approximately 10 to
20 percent and emission reductions --as measured in the laboratory --of
between 70 and 90 percent of emissions levels characteristic of conventional
wood heaters. (Field testing of these models, however, has indicated more
modest emission reductions.)
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 a 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
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
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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.
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 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, introduction
of preheated secondary air, and combination of these and other features.
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
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through a convoluted duct. When the fire has died down to coals only, the
fire box is sealed.
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 there is a power
outage. Pellet heaters in general, have the lowest emissions of PM and CO
(EPA (RIA), 1986); however, since 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.
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 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 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
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instructions. This regulation also makes it a violation of federal law for
consumers to operate their wood heaters contrary to these instructions.
Although EPA does not intend to enforce these provisions, they could be
enforced at the state and local levels if the regulation is adapted at the
state 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 public awareness (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 a similar program in the State of Oregon,
a committee composed of representatives from the EPA, state governments,
consumer and environmental interests, and the wood heating industry developed
a new source performance standard (NSPS) requiring all new wood heaters to be
certified by EPA to meet emission limits. This regulation was promulgated in
early 1988 (Federal Register. February 26, 1988). The key features of this
NSPS are summarized below.
The standards control PM 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
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, boilers, furnaces, and cookstoves are not
covered under these standards; the regulation primarily affects
"airtight" woodstoves and fireplace inserts.
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The standards are being implemented under a certification
program whereby the manufacturer submits a representative wood
neater to an accredited laboratory by EPA to be tested
according to 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.
1.2.2.2 The PM-10 Ambient Standard
The Clean Air Act requires that all areas of the country be in attainment
of national ambient air quality standards (NAAQS). In 1971 EPA established a
NAAQS for particulate matter based on total suspended particulates. On July
1, 1987 EPA announced in the Federal Register a new NAAQS for only the
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smallest size particles -- those with diameters of 10 micrometers or less.
Particles of this size are respirable and of greatest health significance
(i.e., they penetrate to the tracheo-bronchial and alveolar regions of the
lung). Respirable particles can damage the lungs and aggravate cardiopul-
monary diseases.
The PM-10 NAAQS limits the amount of PM-10 in the air to 150 j*g/m3 when
averaged over a 24-hour period and 50 Ağg/m3 when averaged over an entire year.
Only one exceedance of the 24-hour average is allowed each year for an area to
remain classified as attainment.
RWC devices are one of many possible source categories of PM-10. Auto
exhaust and industrial fugitive and point sources are others. The PM-10 NAAQS
does not directly mandate RWC controls. However, of the 60 areas in the
country that did not attain the new PM-10 standard, approximately one-third
were significantly affected by RWC emissions. The PM-10 nonattainment SIP
process therefore is forcing many areas of the country to deal with the
problem of RWC emissions from existing wood heaters.
Eventually, 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 rate of improvement and concerns over the long term emission
control performance of certified wood heaters requires that additional control
measures be deployed in the PM-10 nonattainment areas with high RWC emissions.
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. Although PM-10 is one of many
substances of concern in wood smoke, the control measures for reducing RWC
emissions generally result in reductions of the other substances as well.
This underscores the importance of addressing all health effects rather than
simply those from PM-10 in the "selling" of control programs to the public and
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local officials. Also, many of the "bad actors" in wood smoke are contained
within the PM-10 category.
In the State of Washington,/where/the Department of Ecology and the Puget
Sound Air Pollution Control Agency has made a special effort to communicate to
the public and to state legislators/fthe health effects from exposure to wood
/^"~~^\
fsmoke/\the public and legislative support for a stringent set of controls has
been strong. Staff members from these two agencies have teamed with
t*4 researchers at the University of Washington to investigate the health effects
literature. Following is a summary of part of their findings (Koenig, et al.,
1988).
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, PM-10, and polycyclic organic materials (POM) specifically
including 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 occur rapidly and persist for up to
two to three weeks before recovery.
Measurements of particles less than 10 micrometers were made
during the winter of 1985-1986 in Olympia, Washington. For a
period of five days, the concentration was greater than 150
/jg/m3. Wood smoke concentration was high and responsible for
SOX-90% of the fine particles.
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. CO concentrations have been
measured in homes using wood stoves in the range of 1.2-43 ppm.
Aldehydes (including formaldehyde and acrolein). Exposure to
formaldehyde at concentrations above 0.4 ppm has been as-
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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, N02 is known to
cause accumulation of fluid in the lung (edema)- and scarring in
the lung (fibrotic changes).
N02 can have both acute and chronic effects. Studies have
shown that children from homes with gas cooking stoves
(which emit N02) experience a greater frequency of respir-
atory illness than do children from homes with electric
stoves. However, consistent lung effects in children due
to N02 exposure have been difficult to characterize.
Polvcyclic 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.
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 particulate
matter (PM) 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) up to 100 times as much mutagenic activity as some
well-known carcinogens. In addition, the mutagenicity 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 significant sources and
quantities of other pollutants (Kameus, et al, 1984). Other studies
reported that emissions from both traditional- and advanced-technol-
ogy wood stoves caused sister chromatic exchange (SCE) -chromosomal
defects - in mammalian cells. Even though the newer stoves produced
less particulate matter 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:
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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 and PAHs within the home. One study showed
that emissions from non-airtight stoves resulted in indoor con-
centrations of up to 650 pg/m3 of particulate matter. The new EPA
standard for PM-10 is 150 jig/m3 for a 24-hour period.
EPA has prepared a "fact sheet" addressing the health effects from wood
smoke. EPA recommends the use of this fact sheet, contained in Appendix D, in
state and local programs.
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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 and prepares
citizens with details of the RWC control regulation (or ordinance), their
responsibilities under the ordinance, and the justification for the ordinance
while (2) providing ongoing education 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, and (4) the effectiveness of
various levels 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" (1). The issue of 'the individual's right to burn is
based on assumptions that have 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
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burning RWC devices rather than threats of sanctions for failure to attain the
standard.
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 RWC emission problems in the community as a whole. For
example, in the case of Steamboat Springs, Colorado, curtailment was con-
sidered impractical and economically imprudent, so the PA program focuses its
message on improving RWC operation and on health issues.
In summary, policy makers must take into account community attitudes and
values in developing the overall RWC emission control plan and specifically
the PA program element.
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 associated with wood
smoke so that the community will support other program elements and (2) to
promote better wood burning practices or selection of alternative heating
systems. (Few areas rely on PA as a stand-alone program element to meet PM-10
nonattainment.) 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 PA program element to stress the health risks from wood smoke.
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Of the areas surveyed, the Puget Sound PA program element has taken the
most aggressive positions regarding PM-10 health effects. Working with 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 responsibility.
Wood Heat, Wood Smoke and You (63) 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, (54) 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
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habits that are unacceptable. The use of a survey, as described in Appendix
A, can provide this information.
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, Washoe County has a pamphlet that discusses fuel choice, fire
preparation and maintenance, and firewood characteristics of the area.
Most RWC 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,
treated 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.
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
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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.
Knowing how to burn properly requires a basic understanding of how a wood
stove works. Brochures that address proper burning techniques emphasize the
importance of burning small, how 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 and health issues of wood smoke.
Stove Types --
As reported earlier, the state of Washington equates the selection of a
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
(63) discusses catalytic versus noncatalytic stoves, and pellet stoves. Wood
Heat (55) 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.
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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 (62) 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 three
media that, when coordinated, forms a comprehensive and potent mean 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. Banner (1989) 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, who most use wood stoves and fireplaces,
are unlikely to read brochures (27).
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TABLE 2-1. STRENGTHS AND WEAKNESSES OF THREE DIFFERENT PUBLIC INFORMATION MEDIA
Strengths
Weaknesses
Print
Broadcast
NJ
Public Contact/
Public Education
Customized to address specific
issues/audiences
Generic messages can be shared among
regulatory agencies and communities
Most economical to produce and
distribute
Immediacy
TV has visual impact that other media
lack
Allows for immediate response to
public questions
People tend to respond more favorably
to public contact
t Most effective as an educational tool
Engenders a democratic approach by
allowing for diverse group
participation
Can be deliberately ignored
easire than electronic media
Cannot be revised or
distributed as quickly as
electronic media
Relatively expensive to produce
and distribute
Some mountain valleys may have
poor reception
Overdependence on voluntary
attendance
Has limited long-term impact
Presents logistic problem with
schedules of speakers,
audience, and meeting places
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2.3.1 PA Media
The three types of PA media can generally be ranked according to degrees
of impact, from "passive" (broadcast) to proactive (public contact/public
education). Of the areas surveyed, Washington State has the most comprehen-
sive PA program element, 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 stores 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.
Following is a discussion of the three media - direct public contact,
broadcast (or electronic), and print.
2.3.1.1 Direct Public Contact/Public Education Medium --
Washington State --In addition to a strong news media program,
Washington's PA program element has developed 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 DOE, the major message of the workshops is for each class par-
ticipant to reconsider, after hearing the facts about RWC, the practicality of
buying or continuing to use a RWC device. Immediate receptivity to the ideas
posited 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. M. Nelson (1988) reported that some of
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the class indicated they had decided not to buy a RWC device based on the
information presented in the seminars.
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 (43).
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 board 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.
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, cer-
tified, 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 better understanding between the local regulatory agency and the
industry that may perceive itself to be threatened by PM-10 legislation.
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Klamath County -- Klamath County, Oregon, has an extensive PA program
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
eduction 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.
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 "Breath of Life" fair that
combines the ideas of a 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
long-range planning and diversified resources for achieving PA program element
goals.
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2.3.1.2 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.
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.
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).
2.3.1.3 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
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
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medium has the greatest potential to reach the broadest yet specific target
audience. Table 2-2 lists all the printed material received from the 28
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 (Ref). 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.
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.
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 of
the better funded areas such as Washington State have produced numerous
brochures and fact sheets of relevant information that are suitable for
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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)
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TABLE 2-2 (CONTINUED)
Area
Tide of Publication
Topics Discussed
Montana
Missoula
(1) Heating With Wood
Sizing a wood stove
Better heating practices
Health risks
Lewis & Clark (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
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)
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TABLE 2-2 (CONTINUED)
Area
Title of Publication
Topics Discussed
Oregon
(1) Certified Wood Stoves
(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 stove
How to select appropriate wood
stove
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)
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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)
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TABLE 2-2 (CONTINUED)
Area
Title 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
Protection Agency
Buying an EPA-CertifiedWoodstove
EPA's wood stove regulations
Sizing and selecting the appropriate
wood stove
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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 (56, 57, and 58). 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 (62). In contrast to the
specialized approach, Washington's Wood Heat, Wood Smoke and You (63) and
Montana's Wood Heat (55) are quite comprehensive, discussing different facets
of wood heating.
Distribution -- 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 interviewed that has some form of printed material makes the
pamphlet/brochure available on request. Several communities reported that
they have a distribution 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.
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/
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inferior wood burning appliances and diminished air quality, and (2) services
as a verifiable record that a violator is aware of the ordinance and public
responsibility.
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 wood stoves/fireplaces 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 RWC emission control program. In summary, the PA
program element is a necessary - but often insufficient - ingredient in a com-
munity's comprehensive approach to PM-10 attainment.
Following is an attempt to characterize the effectiveness of three levels
of effort for stand-alone (i.e., not combined with other program elements) PA
program elements. Table 2-3 describes each of the three hypothetical levels
of efforts in terms of communication media, level of intensity (or frequency),
and the associated level of effectiveness. It must be emphasized that these
are presented for illustrative purposes only. The design of a specific PA
program element must take into account the attitudes, resources, demographics,
and other site-specific factors.
2.4.1 Minimal Level of Effort
We can project the value of a PA program element according to three
levels of effort. Reliance on any one medium will be the weakest approach,
whereas a comprehensive mix of print, broadcast, and public contact media
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TABLE 2-3. THREE LEVELS OF EFFECTIVENESS FOR HYPOTHETICAL PUBLIC AWARENESS PROGRAM ELEMENTS
Program Level
and Effectiveness
Media
Assumptions and Intensity
I. 4 percent
II. 8 percent
Broadcast only
Broadcast
plus
Public Contact
III. 15 percent
Broadcast, and
Public Contact
plus
Print Media,
plus
(see next page)
Several PSAs per week on at least one TV station
Several PSAs per week on at least one radio station
(Same as Level I above)
Three of the following:
civic groups,
town or neighborhood meetings
public/private school assemblies
t stove fairs
formal adult education curricula
(Same as Level I above)
(Same as Level I above)
At least one of the following:
At least one paid ad per week in widest read
newspaper in the area,
One brochure (printed in volumes equal to one per
RWC device in the area). Brochure should cover at
least three of the following:
Health effects of RWC emissions
Selection of RWC device
Operation and maintenance
Fuel selection and use
Nonhealth benefits of RWC emission control
(Continued)
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TABLE 2-3. (Continued)
Program Level
and Effectiveness
Media
Assumptions and Intensity
III. 15 percent
(continued)
IV. 20 percent
plus
Other
At least one of the following measures:
One billboard with an RWC emission control theme, or
Prominent sign in each motel/hotel room with RWC
device that has RWC emission control theme
Maximum possible for any program that relies exclusively
on public awareness and education
to
to
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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.
Its potential for changing wood-burning practices drops off sharply as soon as
viewers/listeners have received the message. Except for serving notice of
curtailment episodes, TV and radio alone, assuming several PSA messages are
broadcast per day for at least one TV station and several PSAs on at least one
popular radio station, would probably account for only a 4% reduction in PM-10
levels.
2.4.2 Medium Level of Effort
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. This midlevel approach to a PA program element might yield an 8% PM-
10 reduction.
2.4.3 High Level of 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/public
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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; and
Nonhealth benefits of RWC emission control.
\
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 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 Maycutt (1989), enlisting the support of the broadcast and
newspaper media early in the PA process helped ensure popular support for the
P-10 program goals (16). Developing wood heating-related TV and radio pro-
grams 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 wood heat 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 education, wherever there is a large number or concentration of wood
stove users, novel approaches to print communication (billboards, placemats,
bumper stickers, hotel room notices) can also be effective at educating the
wood-burning population. A comprehensive approach to PA programs that first
establishes a knowledge base then reinforces this base can reduce emission
levels by as much as 15%.
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2.4.4 Maximum Level of Effort
The most effective approach to PA program elements emerges as a broad-
based, comprehensive use of public speakers, all types of printed material,
and well-timed and 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. By using the PA program element exclusively at a maximum level of
effort, which combines all three media to the fullest extent, the best reduc-
tion in PM-10 levels a community would probably see is 20%.
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SECTION 3
IMPROVING WOOD BURNING PERFORMANCE
3.1 INTRODUCTION
Improving the performance of RWC devices reduces ambient levels of PM-10
by reducing the amount of particulate matter emitted from each RWC device in a
community. To the extent that RWC devices with higher emissions are replaced
in new or existing installations by devices with lower emissions, ambient PM-
10 levels can be reduced. Similarly, to the extent that operation and
maintenance practices by RWC device owners that result in poorer emissions
performance can be replaced by practices that reduce emissions, ambient PM-10
levels can be reduced. The goals of combustion improvement programs, there-
fore , are:
To promote a change in the mix of RWC devices in a community to
increase the proportion of cleaner ones (e.g., certified RWC
devices, low-emitting noncertified RWC devices, or new tech-
nologies) ;
To promote a change in the mix of fuel types burned in wood
combustion devices, eliminating those fuel types that inher-
ently create more particulate matter emissions (e.g., well-
seasoned versus poorly seasoned wood); and
To reduce the number and use of older RWC devices in the
community.
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 enhanced technologies (e.g., smaller fireboxes) that reduce the quan-
tity of particles created during the actual combustion process. Second, the
particulate matter produced during combustion can be reduced by controls on
the flue gases of wood combustion units (such as secondary combustion or
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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 used to heat a residence or building.
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 allowing regulators and consumers to distin-
guish between low-emitting and high-emitting RWC devices. A typical cer-
tification program consists of two primary parts. First, a regulatory author-
ity develops laboratory procedures for testing RWC devices to determine their
particulate matter emissions characteristics under typical 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. Enfor-
cement of this certification requirement is accomplished through audits of
manufacturers or retailers, or through in-home inspections.
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Certification programs reduce emissions by changing the mix of RWC
devices operated in a community, reducing the number of devices with high
emission levels and increasing the number of devices with reduced emissions.
The timing of this change can either be long-term or more immediate, depending
on the authority's selection of regulatory strategy. If the certification
requirement is applied only to new RWC devices, such as through a requirement
that a device must be certified in order to be sold at retail, the improvement
in emissions resulting from certification will be long-term, taking place as
homeowners discontinue the use of existing uncertified devices and replace
them with certified devices. Alternatively, a community faced with a more
urgent need to address RWC emissions could require existing uncertified
devices to cease operation by a specified date. In this way, the overall
reduction in emissions and ambient concentrations of particulate matter would
be more immediate.
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 representative wood heaters. Development of the EPA program drew upon
the experience of the Oregon Department of Environmental Quality's woodstove
certification program which went into effect in 1985.
The EPA certification program also includes requirements for the labeling
of wood heaters. The labels are intended to inform the consumer that the
stove is certified, as well as to convey information on the tested emissions
from the heater.
The effectiveness of certification programs in reducing emissions of
particulate matter is generally a function of three factors:
Growth (or decline) projected in the number of operating
devices in a baseline year;
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Rate of replacement of existing devices with certified devices;
and
The difference in average emissions between baseline and
certified devices, which is governed by the emission standards
selected.
A certification requirement reduces emissions to the extent that the per-
centage of certified devices devices relative to uncertified devices increases
in the community. If certified 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 emissions will
be reduced. If the total number of devices is expected to increase and new
devices are required to be certified, future emission increases will be
reduced, although actual emissions may still increase.
The emission reduction achieved in a given year can be measured by the
difference between emissions from certified devices compared to the emissions
from uncertified devices, multiplied by the fraction of all devices that are
certified. 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 replac-
ement of existing devices before their useful life expires, or through more
rigorous enforcement of the certification 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.
In Oregon, the reduction in emissions through the certification program
has been estimated at 68 - 75% within 15 - 20 years. In Missoula, limiting
new installations to low emitting RWC devices is credited with large
reductions emissions, but over a long term. The Missoula certification
program is expected to reduce emissions by over 92 percent over a 15 year
period, based on a constant growth rate. Without a requirement that new
installations be "clean" appliances, emissions would be expected to increase
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5.2 percent annually (47). However, these significant emission reductions are
based on differences between laboratory measurements certified wood heaters
and a presumed rate of emissions for conventional wood heaters. There is
evidence that in actual practice, the differences are less pronounced.
3.2.2. State Programs
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 wood 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.
Instead, EPA is encouraging state and local authorities to take steps to
enhance the effectiveness of the federal program. The first such step could
be the adoption of the EPA certification program (or, alternatively, the
Oregon program) as state law. After adoption, the certification requirement
could be implemented and enforced by the State as a matter of State law,
without requiring federal action. Currently, EPA does not plan to conduct a
vigorous retail level enforcement program and, although empowered to do so, is
very unlikely to enforce 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 re-
^Ithough 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).
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quired by the program. This entails using state personnel to inspect retail
outlets to ascertain whether units being offered for sale are certified, and
whether the labeling and other requirements are being complied with.
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 at WAC 173-433-100 (see full text in Appendix C) 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 that 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 rigorous 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
illegal the installation of uncertified devices from out of state, which can
be especially important in border areas, such as Jackson County (Pryor) with
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ready access to uncertified devices from states without a certification
requirement.
The California Air Resources Board (GARB) is considering a state regula-
tion that would address particulars problem faced by that State by moving the
effective date of the federal NSPS ahead by one year. First, this step would
allow the state to realize the benefits of the certification program a year
early. Second, it would address the "dumping" of noncertified RWC devices on
the market in California that cannot be sold in surrounding states and locali-
ties (i.e., Oregon and Washoe County, Nevada) (Young).
The effectiveness of a state program depends on the characteristics of
the particular program adopted. 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 EPA certification program.
The existing program reflects the level of reduction in emission rates achiev-
able using current wood heater technologies. No certification programs, for
example, address emissions from fireplaces,2 which in areas such as Denver
comprise 50 percent of RWC emissions.
Further, certification programs address primarily long-term changes in
emissions, since they require a substantial turn-over in the mix of RWC
devices in a community before they accomplish significant reductions in
ambient PM-10 concentrations.
The adoption of the federal certification program into state regulations
can accelerate the pace by which a reduction in emissions can be achieved
through the use of a certification program. By adopting the federal program,
the state is able to bring additional resources to bear on the implementation
and enforcement of the program that are not available through EPA. As a
consequence, although the end result of the certification program (i.e., the
Emissions from fireplaces, unlike "air tight" enclosed wood heaters, are not
readily controlled by catalytic or noncatalytic controls.
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conversion of the wood RWC device population in the community from uncertified
to certified) would remain the same, an incremental increase in the effective-
ness of the program can be achieved earlier than would be the case without
state involvement. This increase is not expected to be large, since com-
pliance by manufacturers and retailers is expected to be the rule. Table 3-1
reflects an estimate of 2 to 5 percent per year for the incremental increase
in emission reductions achievable in the first five years of the certification
program through adoption of the certification program by a state.
Certification programs also work with curtailment programs to promote the
change over from uncertified to certified RWC devices. Curtailment programs,
as described in Section 5, call for wood combustion to be curtailed during
episodes of poor air quality. Adoption of regulations that exempt certified
RWC devices from curtailment requirements would result in reductions in emis-
sions, as would a program that mandates the installation of certified RWC
devices in. new residences. These options are discussed elsewhere in this
manual.
3.2.3 Ban on Resale or Installation of Used Uncertified Wood Heaters
Most certification programs, including those developed by the EPA and by
the states of Oregon, Colorado, and Washington, apply only to new wood
heaters. Used wood heaters can still be sold by individuals and by retailers
without being certified. As a 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 heater(s) from the market.
Any consumer desiring to install a wood heater(s) in a residence would be
forced to purchase a new, certified wood heater(s). This would lead to a
faster turnover in the mix of wood combustion devices in the community, and
replacement of existing uncertified with new certified wood heater(s).
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TABLE 3-1. LEVELS OF EFFECTIVENESS FOR HYPOTHETICAL IMPROVEMENT OF PERFORMANCE PROGRAM ELEMENT
Effectiveness (%)
Program Element
1st Year
3rd Year
Assumptions
State Implementation of
NSPSa-b
15
Ban on resale of uncertified
RWC devicesb
Assumes that State resources will be
devoted to enforcement and
implementation of NSPS at levels
greater than EPA resources would
allow.
Assumes that used stoves cannot be
sold by stove owners for
installation in new residences.
CO
VO
15
Installer training and
certification program1*
Assumes that used stoves cannot be
sold by stove owners for
installation in new or existing
residences.
Assumes a voluntary program coupled
with a public awareness campaign to
encourage certification by
installers and preference for
certified installation by
homeowners.
15
Assumes a mandatory program,
requiring RWC device installation to
be by a certified installer.
(Continued)
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TABLE 3-1. (Continued)
Effectiveness (%)
Program Element
1st Year
3rd Year
Assumptions
4. Inspection program15
I"
o
5. Pellet stoves
45C
6. Low emitting stoves
15C
12e
85C
25b
30C
15*
Assumes program applicable only to
installation of RWC devices in new
residences, and that homeowners are
required to remedy any shortcomings
in installation.
Assumes program applicable to
installation of RWC devices in new
and existing residences and
homeowners are required to remedy
any shortcomings in installation.
Assumes mandatory replacement of all
existing RWC devices in community
with pellet stoves, phased in over 3
years.
Assumes requirement that all new RWC
devices installed in community be
pellet stoves.
Assumes mandatory replacement of all
existing RWC devices with certified,
low-emitting stoves.
Assumes requirement that all new RWC
devices installed in the community
be low-emitting stoves.
(Continued)
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TABLE 3-1. (Continued)
Program Element
Effectiveness (%)
1st Year
3rd Year
Assumptions
7. Retrofit requirement
Accelerated changeover
requirement
Accelerated changeover
inducements
10. Require fireplace inserts
10C
10b
10b
10*
10C
50°
27b
20b
10b
20b
15h
20°
Assume mandatory catalyst retrofit
program for all noncertified RWC
devices, phased in over 3 years;
assume 90 percent of RWC devices in
community are noncertified; assume
reductions of 42 to 71 percent per
RWC unit.
Assume program requires changeover
to certified RWC unit whenever
residence is sold.
Assume program of mandatory
substitution of catalytic RWC units
whenever residence is sold.
Assume low interest loan program for
purchase of catalytic RWC devices.
Assume tax credit designed to offset
difference in purchase price between
conventional RWC device and
catalytic or low emitting device.
Assume fireplace inserts required in
place of open fireplaces in all new
residential construction.
Assume fireplace inserts required as
retrofit for all existing
fireplaces.
(Continued)
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TABLE 3-1. (Continued)
Program Element
Effectiveness (%)
1st Year
3rd Year
Assumptions
u>
11. Wood moisture restrictions
12. Trash burning prohibition
13. Weatherization of residences
10C
5C
10b
25c
15°
30°
15°
30b
50°
Assume program directed at RWC
device owners with wood moisture
measurement services provided by
local authority.
Assume program directed at wood fuel
sellers, with wood moisture
measurement services provided by
local authority.
Assume weatherization standards
applied to new residences.
Assume weatherization standards
applied to existing residences.
"Increase in effectiveness relative to EPA NSPS.
Effectiveness in diminishing future increases in emissions.
cEffectiveness in reducing current emission levels.
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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 stove in a residence. This provision restricts
the sale of used RWC devices in the county, as well as the sale or installa-
tion of used, uncertified RWC devices from out of state.
The sale of used, uncertified wood RWC devices is calculated to comprise
a significant portion of all wood heater sales in any given year. It is
expected that many such devices are intended for new installations and are not
typically sold to replace existing uncertified devices in residences. To this
extent, a ban on the resale of used devices would not lead to a significant
decrease in the number of uncertified devices in a community or in a decrease
in the overall emissions from the existing wood heater population. Such a
requirement would, however, keep RWC emissions from increasing as the use of
wood heaters for residential heat increases in the community by assuring that
new residences install certified wood heaters, rather than uncertified ones.
Over the long-term, as uncertified wood heaters are retired and replaced
by certified one, a ban on the resale of used, uncertified wood heaters would
increase the incremental effectiveness of the certification program each year.
Table 3-1 reflects an estimate of the incremental increase in emission reduc-
tions achievable in the first five years of the certification program through
the adoption of a ban on the resale of used, uncertified wood heater at
approximately a 1 to 3 percent.
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 stove
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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 a wood
combustion device can affect PM-10 emissions from the device. Initially, the
device selected for use in a residence 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
(42). The heating needs of the residents and the structure should be examined
so that the device is adequate, but not inefficiently large.
Similarly, RWC devices that incorporate thermostatic control devices
should not allow such severe air supply cycling that sufficient oxygen for
complete combustion is frequently unavailable. The flue gas ventilauion
system also requires attention. Improperly vented wood combustion 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 accomplish the most efficient air flow through
the device. In addition, the design and installation of flue vents can also
aid in reducing ambient concentrations of wood smoke in some instances by
preventing the downwash of the particulate-laden flue gases.
The effectiveness of installation quality assurance programs generally is
a function of two primary 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
properly installed from one that is improperly installed. Both of these
measures may exhibit a range in the difference they make in emissions, depend-
ing largely in the degree of improvement possible in the installation of RWC
devices in a community.
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3.3.2 Installer Training and Certification
An installation training and certification program improves wood combus-
tion 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 of mandatory. A voluntary program offers a course in stove
installation and fireplace design, and individuals and businesses participat-
ing in the program are able to advertise their certification status.
Purchasers of RWC devices are then able to 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
community.
A mandatory program requires any individual installing a RWC device to be
certified, with the possible - although not necessary - exception of a home-
owner installing a device in a residence. This program differs from the
voluntary installer certification program because it affects all new installa-
tions 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 installed, 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, for instance, 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.
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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. Table 3-1 estimates emission reductions achievable through the
adoption of voluntary installer certification programs at 2 percent per year.
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 exempted.
Table 3-1 estimates emission reductions achievable through the adoption of
both voluntary and mandatory installer certification programs without home-
owner exemption. The estimates are for emission decreases of 2 and 5 percent
per year, respectively, and extend over a 3-year period.
3.3.3 Inspections
Through an inspection program, an air quality agency ensures that wood
combustion devices are properly installed by inspecting residences where new
wood RWC devices or fireplaces are installed. These inspections would ascer-
tain that flue systems, thermostatic controls, and catalysts are properly
installed to achieve reduction in emissions, as well as an efficient and safe
operation. These inspections could be carried out by the city or county
building inspection staff as part of an existing building permit and inspec-
tion system. Any such program would be mandatory for new RWC device installa-
tions, 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
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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.
The effectiveness of an inspection program in reducing emissions is a
function of whether the inspection is applicable to new installations or to
existing installations. Table 3-1 gives an estimate of the reduction in
particulate matter emissions achievable through an inspection program. For a
program applicable only to new installations, the 2 percent reductions projec-
ted are in terms of reductions in the increase of emissions, rather than
reduction from current emission levels. If the program were expanded to
existing sources, reductions in current emission levels of approximately 4
percent can be achieved. Table 3-1 indicates the performance of this program
element over a 3-year period.
3.4 TECHNOLOGY REQUIREMENTS
3.4.1 Introduction
Technology requirements reduce emissions of PM-10 from RWC devices by
requiring those devices to incorporate advanced design and technology that
inhibits the formation and emission of particulate matter. 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 device installed in a community must incor-
porate advanced technology to reduce emissions. In a more stringent program,
this requirement might also be applied to existing devices, requiring home-
owners to retrofit existing devices with catalysts.
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3.4.2 Pellet RWC devices
A requirement that only pellet stoves be allowed for new installations of
wood combustion devices lowers emissions because pellet stoves have inherently
lower emissions than other wood RWC devices. In more stringent programs, RWC
device owners can be required to substitute pellet stoves for existing RWC
devices to achieve immediate reductions in emissions. Pellet stoves provide
the aesthetics of other RWC devices but require specially manufactured wood
pellets and are dependent upon electricity to power the fuel feed system and
combustion air.
Although there are no existing programs that require installation of
pellet stoves in either new or existing wood stove installations, there are
program elements that indirectly promote pellet stove use. The Lewis and
Clark County, Montana, program exempts pellet stoves from the local curtail-
ment requirements. Lewis and Clark County also considered requiring pellet
stoves to be sold with maintenance contracts to provide for long-term perfor-
mance, 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 pellet stoves and existing stoves, and the
rate of adoption of pellet stoves to replace existing stoves. Table 3-1
contains the emission factors for the categories of RWC devices. As can be
seen from this table, pellet stove particulate matter emissions range from
approximately one-fourth the emissions from a catalytic wood heater to
approximately one-tenth the emissions of a conventional wood stove.
The overall reduction in emissions from the adoption of a pellet stove
requirement for new stoves depends on the mix of wood combustion devices in
the existing population and the rate of replacement of existing stoves. To
estimate the effectiveness of a pellet stove program on new installations, the
average emission factor for existing devices should be determined (as
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discussed in Appendix A, "Estimating Emissions"). Emissions reduction could
then be calculated based on the replacement rate for existing devices.
For instance, if the existing stoves have an average emission rate of 12
g/kg, the adoption of a pellet stove requirement would reduce emissions by
10.4 g/kg, or approximately 85 percent for every existing device that is
replaced with a pellet stove. If the replacement rate is 5 percent per year
and there are 10,000 devices in the community, this would mean that 500
existing devices would be replaced by 500 pellet stoves per year. Thus,
emissions would be reduced by approximately 5 kg/kg each year. Assuming and
average burn rate for all units of 1 kg fuel per hour and operation of the
devices for twelve hours a day for 180 days, this would mean an annual emis-
sions reduction of 10,800 kg.
As indicated in Table 3-1, a program element requiring the installation
of pellet stoves would result in significant reductions in particulate matter
emissions from wood combustion in a community. If all existing RWC devices in
the community were required to be retired or changed to pellet stoves, the
reduction in particulate matter emissions would be 85 percent or greater
(depending on the number of devices retired). Table 3-1 assumes that this
program would be phased in over 3 years to allow "hardship" cases to purchase
the pellet stove or to seek alternative heat sources. If the pellet stove
requirement is made applicable only to new RWC devices installed in the
community, the overall reduction achieved would be diminished.
3.4.3 Low-Emitting Stoves
A low-emitting stove requirement is similar to a pellet stove require-
ment. Low-emitting stoves are designed to achieve more efficient combustion
and lower particulate emissions than conventional devices, although their
emissions, as shown in Table 3-1, are higher than for pellet stoves.
Generally, pellet stoves are considered to be a subset of low-emitting stoves.
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Requirements that all new RWC devices be low emitting have been incor-
porated into a number of local residential RWC emission control programs. In
these programs, low-emitting stoves are often identified as certified, non-
catalytic RWC devices. Telluride, Colorado, and the surrounding San Miguel
County incorporate a low-emitting stove 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. Existing RWC devices had 3
years to comply from the adoption of the regulation. New devices are required
to comply immediately. Further, fireplaces were required to be dismantled or
retrofitted with inserts. Similarly, Juneau, Alaska, requires a permit for
new RWC devices, and qualifying ones must meet EPA Phase II standards for low
emissions.
As with a pellet stove requirement, the emission reductions achieved
through a low-emitting stove requirement are dependent on the replacement rate
for existing devices and the difference in emissions between the low-emitting
stove and the average wood combustion device in the community. The emission
reductions achievable through the adoption of a low-emitting stove requirement
could be calculated using the data on the mix of appliance types and current
emissions, as well as the turn-over rate for RWC devices in the community.
The effectiveness of a requirement that low emitting wood heaters be
installed is projected in Table 3-1. The first estimate is that these devices
will be required to replace all existing RWC devices that are not certified.
This would result in an initial reduction in emissions of approximately 15
percent in the first year. The rate of decrease would diminish after the
initial round of replacements to approximately 30 percent overall reductions
over 3 years. The second estimate of 5 percent reduction in particulate
matter emissions is based on the assumption that the low emitting devices will
only be required to replace uncertified devices in new residences. Assuming
that the rate of growth in new home construction stays steady, this rate of
reduction should result in a 15 percent decrease over 3 years.
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3.4.4 Retrofits
Programs that require emissions control devices be retrofitted onto
existing RWC devices usually specify catalysts as the retrofit technology to
be applied to conventional wood stoves. This option has been considered by
some communities, but has not yet been adopted into any mandatory residential
wood combustion program. Aspen (Pitkin County), Colorado, for instance, has
considered a proposal to require retrofitting of catalysts on existing stoves,
but has not adopted such a requirement. Routt County, Colorado, requires coal
stokers and wood stoves to be retrofitted with a catalyst device to meet Phase
II standards. In addition, some communities, such as Missoula, have directed
at least a part of their public education and awareness activities into
encouraging stove owners to install retrofit catalysts where possible.
Retrofit requirements apply to existing RWC devices and are generally
coupled with other requirements, such as a catalyst requirement for new stoves
and a ban on new fireplaces. The effectiveness of a retrofit requirement is a
function of the difference between the emissions from the retrofitted devices
and the emissions from those devices prior to the application of the technol-
ogy. The Oregon Department of Environmental 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. Since
catalysts are generally inapplicable to 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
and low emitting stoves.
On a community-wide basis, the reduction in emissions achievable through
a retrofit requirement depends on the contribution of low-emitting and conven-
tional stoves to the total wood smoke emissions, and on the relative number of
low-emitting versus conventional stoves being retrofitted. The total reduc-
tion in emissions could be estimated based on data collected in the household
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survey, as well as assumptions about emission factors and stove usage pat-
terns. The estimate of emission reductions described in Table 3-1 is based on
the assumption that catalyst retrofits will be required for all uncertified
RWC devices in the community, and that the requirement will be phased in over
3 years. It also assumes that 90 percent of the RWC devices are uncertified
and requiring retrofitting, and that emissions per device can be reduced an
average of 50 percent through the application of a retrofit catalyst.
3.4.5 Accelerated Changeover Requirements
Accelerated changeover requirements lead to a faster replacement of
existing RWC devices by lower emitting devices. Instead of basing the replac-
ement 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. The
mechanism for such an accelerated changeover is a direct regulatory require-
ment, banning certain types of devices or requiring their replacement with
approved devices.
For instance, 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 foster more widespread use of certified stoves and would reduce the
number of out-of-state wood stoves 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). Similarly, Crested Butte,
Colorado, has adopted a requirement that all existing solid fuel heaters be
removed or replaced with devices that meet the EPA Phase II limits.
An accelerated changeover requirement does not result in a reduction in
greater long-term emissions than that achieved by any other program element
for improving the emissions performance of wood combustion devices. This
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program element will, however, result in the benefits of any such program
being achieved earlier than would be the case under a "normal" replacement
programs. A requirement that only low-emitting or certified stoves 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 stoves be
upgraded on the sale of a home or other event, would quicken the pace of
emission reduction.
The effectiveness of an accelerated changeover program would depend on
the number 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. If the program resulted in a tenfold increase
in the number of existing devices replaced with low-emitting technologies,
then the reduction in emissions would also be ten-fold. The estimates of the
reduction in particulate matter emissions resulting from the acceleration in
the rate of changeover from uncertified to certified RWC devices are contained
in Table 3-1. The first scenario assumes a required changeover to a certified
RWC device whenever a residence is sold. The second scenario not only calls
for installation of certified devices, but of catalytic certified devices,
which have lower emission rates than certified devices generally.
3.4.6 Accelerated Changeover Inducements
Inducements to accelerate changeovers would be similar to required
changeovers, except that the mechanism would be financial or other induce-
ments, 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 wood 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.
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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 insulated.
Currently, these are estimated at 300-500 homes. The important sources of
variation in the effectiveness of the program element are the condition of the
residences being treated, the willingness of the homeowners to cooperate, and
the availability of funding. Klamath County, Oregon, is also looking to
implement a similar program.
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 very much a function of the success of the program
in motivating homeowners to invest in the newer technology. A program of
grants, such as that in Jackson County, will be most effective, in that it
entails virtually 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 pur-
chasers of new systems to adopt low emitting technologies.
In addition to the effectiveness of the inducements in increasing the
level of adoption of lower emitting technologies, the reductions achievable
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 RWC device sales (as opposed to cleaner
alternative fuels), resulting in a diminishment in the effectiveness of the
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incentives in reducing pollution. Additionally, as with accelerated change-
over requirements, the effect is to change the timing of the emission reduc-
tions, not to change the magnitude of the reductions ultimately achieved.
The decrease in emissions of particulate matter resulting from the
adoption of an incentive program are described in Table 3-1. These reductions
are based on two types of incentives. The first is a low interest loan from
the state to offset th epurchase prices of a certified RWC device. The second
is a tax credit used to offset the difference in price between certified and
uncertified devices. Because the tax credit would confer a larger economic
benefit on the purchaser, it is assumed that it would result in more substan-
tial benefits in terms of emission reductions.
3.5 FUEL QUALITY
3.5.1 Introduction
Certain fuels inherently produce more particulate matter when burned in a
wood combustion device than other fuels. The major characteristics of fuels
that contribute to the formation of particulate matter 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 county, users of coal who can show
that they burned coal prior to 1981 are exempted from the ban.) For wood used
as a fuel, the most important fuel characteristic contributing to particulate
matter emissions is fuel moisture.
3.5.2 Moisture Content Regulations
Regulations restricting the moisture content of fuel wood control par-
ticulate matter emissions by requiring wood burned in wood combustion devices
to be dried and cured to reduce the moisture content. These restrictions can
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be applied either to wood offered for sale, or to all wood burned in the
community.
Jackson County, Oregon, includes programs for providing wood moisture
measurement services. Jackson County's public awareness campaign is directed
at urging wood burners to use only well seasoned wood. In conjunction with
this effort, the county has installed instruments 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
in order 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
easily for enforcement purposes, the requirement for seasoned wood 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, particularly in a state
where many stove owners cut their own wood.
The effectiveness of a fuel moisture content requirement is measured by
the difference between the emissions from poorly seasoned wood used in the
community and properly seasoned wood required by the regulation. This theore-
tical difference must be tempered, however, by recognition that the enfor-
cability of any such requirement will be reduced by inherent limitations on
the enforcement of such a requirement. 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 the reduced heating performance and
efficiency that occurs when wet wood is burned. Improving operation of stoves
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through public education encouraging spring wood cutting was expected to
reduce firewood use and associated particulate emissions by 10 to 20 percent
in Medford, Oregon (47). Studies have estimated that vigorous programs to
reduce the moisture content of wood fuels can reduce emissions by 6 to 10
percent, although these estimates have not been confirmed by actual field data
(48).
The estimates of emission reductions achievable through wood moisture
regulations in Table 3-1 are based on two assumptions. The first is that the
program element will be directed toward RWC device owners, prohibiting them
from burning wood above a stated moisture content. The second program element
is directed toward retailers of firewood, prohibiting them from selling wood
above a certain moisture content.
3.5.3 Trash Burning Prohibition
A number of communities prohibit trash burning as a measure to control
particulate matter emissions from residential heating. Because of the vari-
able moisture content of trash fuels, as well as the potential for emissions
of potentially toxic materials from the combustion of plastics and other
substances, burning trash in heating devices typically increases particulate
matter as well as toxic pollutant emissions.
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, requires that only wood be burned, and prohibits burning garbage,
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coal, and other materials, although this prohibition, too, is difficult to
enforce.
The emissions reduction achievable through a ban on burning trash is
measured as the difference between the PM-10 emissions from burning trash
compared to burning well-seasoned firewood. In most areas, this difference
will be 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, in estimating
the effectiveness of such a requirement the experience of communities with
existing programs should be kept in mind. An estimate of the emission reduc-
tions achievable through a prohibition on trash burning is listed in Table 3-
l.
Any ban on burning trash in residential combustion devices would be
difficult to enforce. Therefore, although elimination of trash burning would
reduce particulate matter emissions, it is not anticipated that any such
requirement would accomplish significant reductions. Such reductions might be
as readily achieved through a public awareness campaign directed toward
eliminating trash burning that would emphasize the potential toxic emissions
from burning trash.
3.6 Reduce Fuel Use
In addition to employing technology to reduce particulate matter emis-
sions by reducing particulate formation during combustion or removing par-
ticles from flue gases, emissions can also be reduced by reducing the amount
of fuel combusted in a wood combustion device. Although there are several
potential approaches to reducing the demand for wood heat, the most feasible -
and the only one in practice - is weatherization.
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Weatherization reduces fuel use by reducing the heating requirements for
the residence. The addition of insulation, weatherstripping, 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.
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. Juneau, Alaska, has a program of
thermal standards for new homes. These standards include R-30 for ceilings,
R-19 for walls and floors, and maximum ratios of window areas to overall area.
The effectiveness of weatherization programs is difficult to calculate
because the relationship between weatherization and stove usage is uncertain.
Instead of reducing wood combustion, the owner of a better insulated residence
may elect to reduce the use of other heat sources (48). Although difficult to
calculate, particulate emission reductions achieved through weatherization
could be estimated by determining the number of residences that are weather-
ized, the change in energy efficiency resulting from weatherization, and how
weaterization affects the operation and installation of wood combustion
devices in the weatherized residences. The important sources of variation in
the effectiveness of the program element are the condition of the residences
being treated, the willingness of the homeowners to cooperate, and the availa-
bility of funding.
The Medford, Oregon, weatherization program is expected to result in
emission reductions of 30 - 50 percent, when coupled with guidance to
retailers and homeowners on determining the appropriately sized RWC device for
a residence (47). This range of values reflects programs applicable only to
new residences at the lower extreme, and programs applicable to new and
existing residence at the upper extreme. The Medford program has been used as
the basis of the estimates of emissinos reductions achievable through weather-
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ization programs, assuming weatherization standards for new residences only in
one case, and for both new and existing residences in the second.
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SECTION 4
LIMITING THE POPULATION OF RWC DEVICES IN A COMMUNITY
Limiting the population of RWC devices in a community reduces ambient
levels of PM-10 by reducing the amount of wood combusted for space heating.
By limiting the population of RWC devices, these program elements would cause
residents to turn to alternative fuels, such as natural gas or electricity.
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.
First, efforts can be made to make alternative fuels more available as an
alternative for residential heating, and their use in residential heating
promoted by the local air quality agency through various incentives. This
approach would result in an increase in the use of lower emitting fuels and a
reduction in the amount of wood combusted.
The second approach would be directed at restricting growth in the use of
wood heat by prohibiting the use of RWC devices in new residences or the
installation of new devices in existing homes. New residences would have to
adopt other technologies and other fuels for space heating. Initially, this
would slow the increase in emissions from the installation of RWC devices in
new residences in a community. In the longer term, as existing RWC devices
are retired and are replaced by other heat sources, current particulate mater
emission levels would be reduced.
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In the third approach, the amount of wood combusted in existing devices
would be reduced through a combination of regulatory actions and economic
incentives and disincentives aimed at 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 desigend to lead to this type
of conversion.
These three approaches to limiting or eliminating the use of RWC devices
for residential heating are discussed in greater detail below.
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, solar, and oil are
widely available fuel sources 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, such as the use of geothermal sources
of heat. Particulate matter emissions from oil 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.
4.1.2 Facilitating Availability of Alternative Fuels
Natural gas is the primary alternative to the combustion of wood as a
residential heat source in terms of emissions, convenience, and cost.
Electricity and oil, while popular choices for residential, are typically more
expensive and less efficient than natural gas. The basic limitation to the
use of natural gas as a residential fuel, however, is availability. Natural
gas is only available to homeowners where pipelines and service lines have
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been constructed to bring this fuel to the community. Therefore, one of the
elements that could be adopted into a 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, invited 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 sources 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 attractive 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 city 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 heating sources are more
available, as well as more economical, for use in residential hea-ting.
The effectiveness of this program element in reducing particulate matter
emissions from wood combustion stems from the relative attractiveness of wood
as a heating fuel compared to natural gas, electricity, or other heat sources.
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. 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 in order to determine whether and to what extent this
program element would be successful in reducing emissions.
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If existing economic considerations do not make natural gas, electricity,
or other fuels attractive and lead to the adoption of those fuels in pref-
erence to wood, the local authority can also alter the regulatory context of
this decision. 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 alterna-
tive fuels more available should generally be seen as part of a program that
includes other elements that influence the choice of fuels toward the selec-
tion of fuels other than wood.
There has been little experience with programs that include elements that
would make alternative fuels more available that would indicate the level of
reduction in particulate matter emissions that could be achieved through this
measure. Such effectiveness would, as discussed above, depend on a variety of
other factors in the decision making process. In Table 4-1, two estimates are
given of the effectiveness of this element.
The first assumes that natural gas is made available in a community where
it was not previously available, and homeowners make their own decisions based
on relative cost, convenience and reliability. In this instance, it is
projected that 10 percent of the homewoners would elect to switch to natural
gas for residential heating, resulting in a 10 percent reduction in emissions.
Because it is anticipated that most changes from wood to natural gas will take
place in the first year after this fuel is made available, the effectiveness
of this program element is projected to reduce in each year after the first
and after three years is projected to result in an overall reduction of 20
percent.
In the second estimate, the availability of natural gas is coupled with
an active public information campaign aimed at presenting homeowners with
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TABLE 4-1. LEVELS OF EFFECTIVENESS FOR HYPOTHETICAL ALTERNATIVE FUEL USE PROGRAM ELEMENT
Effectiveness (%)
Program Element
1st Year
3rd Year
Assumptions
1.
Availability of
alternative fuels
10
20
2.
Economic incentives
for fuel conversion
in new dwellings
15
20
40
12
45
Assumes natural gas made available in community for
first time.
Assumes natural gas made available and an active
public awareness campaign to encourage its adoption
as a residential heating fuel.
Assumes rate structure providing only incremental
difference in relative cost of natural gas or
electricity versus wood.
Assumes rate structure providing substantial cost
savings for adoption of natural gas or electricity;
three year effectiveness reflects assumption that
change in fuel use will require longer for some
residences than others.
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information on the relative cost, convenience, reliability, and environmental
consequences of each fuel. Through this added measure, it is projected that
an additional 20 percent of homeowners will elect to heat with natural gas in
a community where this fuel was not previously available. This public
information effort is also expected to result in most changes in fuel use
occurring in the first year, with a 40 percent reduction over three years.
4.1.3 Economic Incentives (Loans and Fuel Subsidies)
The use of economic incentives to encourage homeowners to change from
wood to other fuels is the next step from making those fuels available in the
community. In this program element, the relative economic attractiveness of
:.Tood versus other fuels is changed by making the other fuels less costly, at
least initially. Through tax incentives or grants, the community can
subsidize lower-emitting fuels, such as natural gas or electricity, making
them attractive to more homeowners.
The town of Telluride, Colorado, provided economic incentives to
homeowners to convert from wood combustion to alternative fuels. This
incentive program was coupled with Telluride's requirement that uncertified
wood heaters and fireplaces be removed or dismantled over a 3-year period.
During the first year of a 3-year grant program, grants of $250 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 raised to $750 per residence. The purpose of this 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.
Boise, Idaho, developed an incentive program to encourage howeowners to
switch from wood to electricity for residential heat. The goal of this
program element is to reduce or eliminate the cost advantage that wood has
over electricity in the perception of many homeowners. Under this program
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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 requirement is then
compared to the monthly electric power demand for the residence following the
installation of the electric heating system. The electric utility then
reduces by half the cost per watt of electricity for the usage that exceeds
the established monthly average.
The effectiveness of these incentive programs depends on the number of
homeowners who are persuaded to change from wood to other fuels. The success
of the incentives in encouraging homeowners to use fuels other than wood is
dependent on the level of incentive and the degree to which the incentive
alters the economic attractiveness of each fuel. Estimates of the participa-
tion of homeowners in program elements using utility rate structures to
promote the use of electricity in residential heating range from 6 percent in
Montana to 46 percent in northern California. These estimates are shown in
Table 4-1 and reflect different assumptions about the level of incentive
employed and the relative price and availability of other fuels.
4.2 LIMITING RWC IN NEW DWELLINGS
Three program elements have been identified that address the choice of
heating fuel and residential heating appliance for new residences. The first
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, particulate matter emissions from these sources can be virtually
eliminated. Further, as existing RWC units are retired, the current particu-
late matter emissions levels can be reduced over time.
The second 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 achieved by retiring RWC devices elsewhere in the community.
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Through this device, 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 to install and
make other fuels realtively more attractive.
The third 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.
Each of these program elements is discussed in more detail below.
4.2.1 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
use of wood as a fuel for space heating in residences in the community. San
Miguel County, Colorado, bans the installation of fireplaces in new dwellings
entirely, in addition to requiring offsets for new solid fuel combustion
devices. A new ordinance is being considered in Telluride that would limit
the number of devices in the community to the present level by issuing no more
permits, although allowing existing permits to be traded or sold. Similarly,
Missoula, Montana, has considered moving from a certification requirement to a
ban on the installation of all RWC devices in new dwellings if the growth in
population and number of stoves results in a recurrence of NAAQS violations.
Communities could also extend such a ban only to certain types of RWC
devices. A variety of such programs exist that ban, for instance, high
emitting stoves from installation in new dwellings, or that ban fireplaces.
These program elements are typically connected to a certification requirement.
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In Washoe 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).
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.
Mammoth Lakes, California, has a zoning ordinance limiting the number of
solid fuel burners to one per residential unit or commercial building and one
per single family residential unit. The devices installed under this require-
ment must be certified. Similarly, the Lake Tahoe Regional Planning Agency
has an ordinance that allows them to limit the number of stoves to one per
house and to ban 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). Their goal is to
limit the number of stoves per house to reduce wood usage by 10 percent and
emissions by 60 percent by the year 2005.
Several ski resort communities in Colorado have also enacted limits on
the number of devices that are allowed in new dwellings. In Aspen (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 regardless of the number of units
in the building.
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Banning certain RWC devices in new dwellings will not, by itself, result
in reductions in emissions or ambient concentrations of PM-10 throughout a
community. A ban, whether total or partial, that is limited to new dwellings
would only operate to restrict the rate of increase in emissions resulting
from overall growth in the community. This effect would be measured by
determining the difference between the emissions from wood stoves operated in
the new dwellings in the absence of a ban, and the emissions from the more
limited number or devices installed pursuant to the ban. The hypothetical
emissions from new dwellings in the absence of the ban could be estimated by
assuming that new dwellings constructed would continue to have the same
average number of devices with the same average emission rate as existing
dwellings.
Under a total ban, these emissions would be eliminated and there would be
no increase in emissions. Under a ban that is limited to certain types of
devices, the emission reductions attributable to the ban would be calculated
by the potential emissions of the banned devices. If the ban only operates to
reduce the number of devices in a dwelling, the reduction would be based on
the difference in the average number of devices prior to the ban and the
average number after the ban.
A ban on installation of certain types of devices would have an effect in
a program like Washoe County's, where there is a specific provision calling
for the elimination of replacement of existing devices on resale of a resi-
dence. In this case, the effectiveness of the program element would depend on
the rate of turnover in ownership of existing homes.
In Washoe County, planners have projected a 25 percent reduction in
annual emissions of particles from residential wood combustion in the fifth
year of the ban. 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
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residential structures will comply with the provision of the ban by eliminat-
ing 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 noncertified heaters. These estimates have been used
as the basis for the effectiveness projections listed in Table 4-2.
4.2.2 Construction Offsets
A construction offset program for RWC devices would reduce emissions of
particulate matter in a way similar to the reductions achieved from existing
offset programs applicable to industrial sources. Under an offset program,
the builder or owner of a new dwelling would have to reduce emissions from
other sources that would equal or exceed the projected emissions from the new
wood combustion devices in the dwelling. In most existing programs that
incorporate this element, this means that before a new wood combustion device
can be installed, the owner must find an existing device to take out of
service. This may mean negotiating with other homeowners for the purchase of
their wood stoves or 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.
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
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TABLE 4-2. LEVELS OF EFFECTIVENESS FOR HYPOTHETICAL RESTRICTIONS ON RWC DEVICES IN NEW DWELLINGS
ho
Effectiveness (%)
1.
2.
3.
Program Element
Ban on RWC devices
in new dwellings
Construction
offsets
Taxes on RWC
devices new
dwellings
1st Year
8
6
4
3
20
10
15
3rd Year
24
18
12
9
50
30
45
Assumptions
Assume all RWC devices are prohibited in new
dwellings.
Assume fireplaces and uncertified stoves are
prohibited in new dwellings.
Assume only fireplaces are prohibited in new
dwellings.
Assume 1 certified RWC device permitted in each new
dwelling.
Assuming a 2:1 offset ratio of retired to new RWC
devices .
Assumes a 20 percent tax on all RWC devices
installed in new dwellings.
Assumes a 20 percent tax on fireplaces and
uncertified heaters and a 10 percent tax on
certified heaters.
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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
stove is approximately $1,000, so the offsets for a new stove would cost
$2,000.
Okanogan, Washington, has a similar program 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.
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, 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 wood combustion devices, emission reductions would be commensurate.
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 program, this
would mean that 150 new wood combustion devices have been permitted in
Telluride, but that 300 devices were retired as part of the offset program,
resulting in a net reduction of 150 devices in two years. Based on this
experience, it is projected in Table 4-2 that a 20 percent retirement rate
could be expected in a community during the first year of an offset program,
and a 15 percent retirement rate in each of the next two years, for a total 3-
pear reduction of 50 percent.
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4.2.3 Taxes on New Stoves
Imposing or increasing taxes on new RWC devices would restrain 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. 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 wood combustion 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 fuel combustion devices going into new dwellings in the
community.
Table 4-2 projects reductions in emissions from two types of tax pro-
grams. The first places a 20 percent tax on all RWC devices to be installed
in new dwellings. It is estimated that this would result in a fifty percent
reduction in the number of RWC devices installed in new dwellings each year,
with a resulting 15 percent reduction per year in particulate matter emis-
sions. The second projection is for a program that taxes fireplaces and
uncertified wood heaters at 20 percent, but taxes certified wood heaters at
only 10 percent. This program is expected to promote the use of certified
heaters over fireplaces and uncertified heaters. The projection is that this
would result in emissions reductions of 10 percent per year.
4.3 ELIMINATE WOOD BURNING
The elimination of wood burning addresses the reduction in particulate
matter emissions from RWC devices by providing incentives for homeowners to
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remove or disable existing devices in residences. There are two program
elements that have been identified to accomplish this goal. 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 to be removed from residences or, in the case of fireplaces,
disabled so they are no longer operational.
4.3.1 Incentives to Remove/Pisable Appliances
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. In some cases, 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. Alternatively, tax credits 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 tax bill.
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 incen-
tive 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 particulate matter emissions. A
high enough incentive level (probably substantially higher than the cost of
the conversion to another heat source) could result in virtually all RWC
devices being removed. Since the need of most localities to reduce particu-
late matter emissions will probably fall between these two extremes, the
incentive level would probably need to be set at some intermediate level.
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As with the incentive program elements described in Table 4-1, 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. These projected emission
reductions are described in Table 4-3, along with an incentive program that
would result in virtually total elimination of existing RWC devices.
4.3.2 Regulatory Requirements for Elimination 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 regulation requiring the removal or disabling of existing RWC devices
would obviously be a politically sensitive act by the local authority in any
community, and no total bans are curently in effect. Partial bans on certain
RWC devices, most notably fireplaces, have been implemented in communities
such as Telluride and Aspen, Colorado. Table 4-3 describes effectiveness
levels for two program elements involving bans on existing RWC devices, one
aimed at a total ban and the other a ban on fireplaces, both phased in over 3
years.
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TABLE 4-3. LEVELS OF EFFECTIVENESS FOR HYPOTHETICAL INCENTIVES FOR ELIMINATING RWC DEVICES
Program Element
Effectiveness (%)
1st Year 3rd Year
Assumptions
Economic incentives
for fuel conversion
15
12
45
I
tğ
ĞğJ
40
95
Regulatory ban on
existing RWC
devices
20
100
15
Assumes a tax credit providing only incremental
difference in relative cost of natural gas or
electricity versus wood.
Assumes a grant or tax credit providing substantial
cost savings for adoption of natural gas or
electricity; three year effectiveness reflects
assumption that change in fuel use will require
longer for some residences than others.
Assumes a program primarily using grants set at a
level greater than the replacement cost of the
heating source designed to achieve the highest
level of elimination possible.
Assume a total ban on all RWC devices in the
community, phased in over a 3-year period.
Assume a ban on fireplaces in the community, phased
in over a 3-year period.
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SECTION 5
CURTAILMENT
Episodic curtailment is the fourth basic control measure available for
reducing PM-10 emissions form residential wood combustion. In its simplest
form, a curtailment program element involves the elimination of wood burning
during periods (episodes) when ambient levels of PM-10 approach are or
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 woodsmoke,
the other control measures may be more appropriate. 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 public awareness 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 nonattainment results from violations of the 24-hour
rather than the annual standard.
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TABLE 5-1. CURTAILMENT1 AND COMPLEMENTARY PROGRAM ELEMENTS
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 (M*)
PA, SL, P, TS, OL
PA, OL, P
Cert
Cert, PA, grants follow income for
replacement
PA, SL
PA
PA, OL
PA, TC, P
PA
PA, Cert, OL, fuel restrictions
PA, Cert, Removal of dirty 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.
"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 non voluntary 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, 2 were voluntary only; 8 were mandatory only; and 1 has 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
perceived in effectiveness of voluntary programs (BPA, E, 1988).
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 PM-10 levels exceed the NAAQS of
150 ng/m3 (or 100 PSI2). At this point the visibility is significantly
impaired and the publically literally sees the value of eliminating wood
burning.
Overall, the experience suggests that despite its relative ineffective-
ness, a voluntary program can 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 can 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 can
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. Where excursions of the PM-10
Pollution standard index, where for any NAAQS 100 equals the NAAQS, 200 is
twice the NAAQS, 50 in half the NAAQS, etc.
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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
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 communication 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 case
burning.
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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. The DMAQC is a coordinating agency created by the Governor to
develop SIP for the Denver area. It includes the areas covered by six
counties and 23 municipalities but has no regulatory authority in itself.
Communication of no burn days, compliance determination, and enforcement
becomes complicated when several jurisdictions are involved. The effective-
ness of the Denver area curtailment programs are 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 communication
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 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 sold on 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
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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
non compliance that is more thorough and less costly than organized patrolling
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 public awareness and education
program, 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" section.
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 public awareness programs.) The messages may include the
following themes and content:
1. The 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 (Maycutt, 1989).
2. The true economic costs of wood burning may be much higher than most
people realize. Provide consumers with a means (1) to calculate the
actual costs of wood burning (including the value of homeowner's
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time for cutting and hauling wood, ash disposal, etc.) and (2) to
compare this with alternative heating costs.
3. The 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.
4. 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 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 messages 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
its proven effectiveness in other locales. Finally, the fourth message--
information about how the program will work--will promote acceptance because
it will counteract the inevitable rumors that would occur in the absence of
good communication. A description of how the program will work is particular-
ly important if there are exemptions for sole-source heaters and/or certified
stoves or if there is a phase-in period.
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 .
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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
education program should communicate to the public that if voluntary com-
pliance 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 insufficient
response from the public.
In addition to or instead of a voluntary-to-mandatory phasing, the no
burn "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 /*g/m3 to 100 /*g/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. Thas 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
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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 episodes is occurring. At a minimum, the forecasting of
potential episodes of unacceptably high emissions requires access to weather
forecasts and the realtime monitoring and reporting of PM-10 ambient levels in
the affected areas.
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 than an air
stagnation is in effect, although local programs can use other criteria and
methods.
Ambient Monitoring --
A system of ambient monitoring of PM-10 levels is also necessary. Many
programs use nephelometers as a basis for declaring a curtailment. 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 correlate well with measured PM-10
levels (Idaho Department of Health and Welfare, 1988).
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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
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 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 thin. 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
5-11
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TABLE 5-2. HOW DIFFERENT PROGRAMS DETERMINE WHEN TO CURTAIL WOOD BURNING"1
Program Location
Action Points
Comments
Ui
i
Boise
Butte
Denver
Jackson Co.
Juneau*
Missoula*
Puget Sound APCA*
Washoe Co.*
Lewis & Clark Co.
110 Mg/m3 PM-10
100 jig/m3 PM-10
9 ppm, CO
130
100 Aig/m3 (air alert)
150 A*g/m3 (air emergency)
100 Mg/m3 (air alert)
150 Mg/m3 (Stage II)
90 Ağg/m3 PM-10
100 A*g/m3 PM-10
PSI >100 "yellow"
PSI >150 "red"
100 Mg/m3 TSP
Averaged over any 4-hour period - or
when predicted.
Based on CO, not PM.
Voluntary only.
City mgr. may call curtailment.
City mgr. shall call curtailment.
Permitted stoves must shutdown.
Only Class I permitted stoves can
burn. No solid fuel burning.
Discretionary to call an alert.
Must call an alert.
Triggered by either CO or PM-10. A
100 PSI is equal 150 /ig/m3.
Or when 100 pg/m3 is forecast.
1Sources: Radian interviews; Batson, 1987.
*Two stages.
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with a cleaner burning one. Table 5-3 presents the exemptions and criteria
for various curtailment programs.
Exemptions for Sole Source Heaters and Economic Hardship --
It is estimated that approximately percent of the homes in this
country are heated exclusively by wood burning (REF ). Many of these house-
holds are low income and thus unable to easily convert to an alternative fuel.
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 woodheating survey
is conducted in the community as 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 cold. The use of a sole-source exemption can defuse this argument against
episodic curtailment.
5-13
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TABLE 5-3. EXEMPTIONS TO CURTAILMENT AND CRITERIA FOR QUALIFICATION FOR EXEMPTIONS1
Program Location
Exemption Type2
Criteria for Exemption
I
H-ğ
eğ
Boise
Jackson Co.
Juneau
Lewis & Clark Co.
Missoula
Puget Sound
Washoe Co.
Butte
C.S.
S.S.
E.H.
C.S.
S.S.
C.S.
E.H.
coal-burners
C.S.
E.H.
C.S.
S.S.
S.S.
C.S.
S.S.
E.H.
EPA, Phase II Certification
Must apply and meet income limits. Low sulfur coal
only & only existing units.
Stoves with <4 gph emissions.
Income low, applications are screened.
4.1 gph EPA method (permitted).
Grandfathered units only.
Must qualify for low income assistance.
1Sources: Radian interviews; Batson, 1987.
2C.S. = Certified stoves.
S.S. = Sole source.
E.H. = Economic hardship
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Exemptions for Clean-Burning Appliances--
An exemption from the no burn mandate is often made for woodburning
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
laboratory results and in-field performance, limit 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 exemptions is that this
creates the need for a permit or registration system in order to ensure that
the dirty stoves are removed, the new stoves qualify, and that the installment
is properly conducted (or for sole source heaters to identify where they are
located).
Under a permit approach, permitted stoves are allowed to continue to burn
during the curtailment episodes. If a homeowner is challenged by a neighbor
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or an enforcement officer for having smoke emitting from his 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).
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 multi-staged
program: Stage Ivoluntary no burn; Stage 2--no burn except for permitted
stoves; and Stage 3--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, and wood burning cook-
stoves, furnaces, and fireplaces) should be avoided (Batson, 1987). 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 Adapting 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 adapted by an elected
body (legislature, county commissioners, or city council). Appendix C
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includes the ordinances and statutes from most of the programs cited in this
section.
5.2 COMMUNICATION STRATEGY
Once the design of curtailment plan is accomplished and the issues of
program scope are resolved, details -- such as how to notify the public of a
no burn conditions -- must be addressed. This section addresses the external
and internal communications. External communications is notifying the public
that a curtailment is in effect. Internal communications 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.
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 precorded tapes ensures that the messages
will be accurate and consistent.
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
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2/8/89 Revision
TABLE 5-4. METHODS OF NOTIFYING RESIDENTS OF NO BURN CONDITIONS
Program Location
Notification Method
Boise, Idaho
Hotline
Newspaper
TV and radio
Butte, Montana
Juneau, Alaska
Lewis & Clark Co.,
Montana
Missoula, Montana
Washoe Co., Nevada
Hotline
TV and radio
Newspaper
Hotline
Newspapers
10 folddown road signs
Radio and TV PSA's
Hotline
Radio & TV PSA's
Newspaper
Sirens scream continuously until PM-10
levels diminish to 130 /*g/m3.
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 woodstove 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-?
eluding those with Class I certified woodstove 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. Wbodstoves 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 woodstove 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.
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newspaper's deadline for the evening edition or next morning's edition, the
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 news-
papers 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.
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.
Telephone Hotline--
The most essential notification element is a telephone hotline where
residents may 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 air quality conditions. To accommodate
several callers at once, most telephone companies provide a service whereby
simultaneous messages can be communicated.
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 reduce 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 the green (okay to burn), yellow
(either voluntary or partial mandatory curtailment), and red (mandatory or
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most stringent curtailment in effect). The three periods can be easily
communicated because of the familiar analogy to a traffic light. A copy of
the Reno daily newspaper with its graphic presentation 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.
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
night-time 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
Sumy, high 44, low 21
CompM* WMttMf report, p*g* IDA
Monday* mag towfc 87 (imdonta)
0-49 150-99 1100-149 150-139 200-299
Story: Miners' Walsh
qqits after Super Bowl
MIAMI - BUI 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
Francisco 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 Susan Skonipa/QuMğJounwi
A strong, high-pressure system over the
Reno-Sparks area has pushed today's
expected 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'!
sunny skies with nig
upper 40s.
The Washoe Distri
ment's air quality rati
low. Area residents ar
or stop wood burning
ride Citifare if possit
door activity, such a
advised.
Residents in home
Bush eyes
..... *
Educators flex muscle
Figure 5-2. Newspaper notification in Washoe Co.
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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 (REF ). 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 to using police are that policy consider wood smoke complaints
and violations 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
woodburning efficiency.
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As noted earlier, leads on probable noncompliance often originate by
citizens who complain, usually anonymously. Table 5-5 shows various means by
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 wood burning is also more difficult to detect and
therefore may require special training or the use of special equipment such as
spotlights devices. 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 (Maycutt,
1989).
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 a level (i.e., more
than $10) that overcomes whatever marginal economic benefits there may be for
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1/30/89 Revision
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., police
Lewis & Clark Co. C.C., police staff
1Sources: Radian interviews; Batson, 1987.
2C.C. - citizen complaints.
Staff Ğ- staff of local air pollution or health agency.
5-25
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1/30/89 Revision
TABLE 5-6. PENALTIES AND DISINCENTIVES FOR NONCOMPLIANCE
Program
Location
Butte
Juneau
Lewis & Clark Co.
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 "raids"
on chronic violators . Also
injunctive relief available.
5-26
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DRAFT - DO NOT CITE OR QUOTE
burning wood versus alternative fuels. This is important, otherwise it would
be cheaper to pay the fines.
On the other hand, most of the programs do not immediately began 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 can increase 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
effortsuch as the publication of the names of persons issues notices of
violation--the deterrent effect is significantly increased at little extra
costs to the program. The most extreme form of this is in Washoe County where
television crews follow police vans with their flashing red lights (as in drug
bust) 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 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 two-fold: (1) it avoids the
possibility of a violent confrontation between the violator and the staff
person or policeman, 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
5-27
-------
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, )
No.
-vs- )
COMPLAINT
)
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_
(signature or inspector)
On this day of _ , 19 , this
complaint was~presented to me and Fh"e conTp'lainant under oath swears
that the charges are true.
(Signature ot Judge or Notary)
NOTICE TO APPEAR
TO:
(Violator's name, ITdcTFessJ phone numBer & firm name 5" address, it any)
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
day of , 19 , at the hour of 8:30 a.m.
or 4f8f0 p.m., to answer" the 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 .
(inspector)
Received this day of , 19
(Signature ot Respondent)
Figure 5-3. Example of violation notice form used in Lewis and Clark County.
5-28
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DRAFT - DO NOT CITE OR QUOTE
penalties high enough to overcome the benefits of wood burning is effective;
and that (2) that it only requires a relatively small amount of enforcement
effort to yield a good response (Batson, 1987).
5.5 PROGRAM EFFECTIVENESS
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 Hissoula which appear meet the criteria stated above.
Based on these data, Table 5-8(a) - (d) describes four EPA recommended
hypothetical episodic curtailment programs with varying levels of assumed
effectiveness. The first is the baseline program, the second is a more
stringent alternative, and the last two are less stringent alternatives to the
baseline program. For each program the following attributes are given:
Voluntary versus mandatory;
Phasing (increasing stringency over time);
Staging (increasing stringency within a curtailment episode, e.g.,
green, yellow, red approach);
Ambient action points for triggering various stages;
Exemptions;
Extent of public awareness and resources;
5-29
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TABLE 5-7. REPORTED CURTAILMENT PROGRAM EFFECTIVENESS LEVELS
Program
Location
Reported Effectiveness
Overall1
Peak'1
Method/
Assumptions
Washoe Co.
Mandatory (Red)
Voluntary (Yellow)
Jackson Co.
Voluntary
90%
33-50%
25%
Visual survey of
chimneys.
Visual survey of
chimneys.
Visual survey of
chimneys.
Ul
I
CO
o
Juneau
Monitored ambient air:
t Reductions in
highest levels
averages over past
three years.
Reductions in 2nd
highest levels
averaged over past
three years.
Approximate percentage of emission reductions over the heating season based on total woodsmoke emissions.
Approximate percentage reduction in emissions for peak PM-10 episodes (e.g., design day).
-------
TABLE 5-8(a). ASSUMED EFFECTIVENESS1 FOR A BASELINE CURTAILMENT PROGRAM
Program Aspect
Rationale
Mandatory
Three Stages
Exemptions
Public Awareness
after 1st year voluntary
(1) No curtailment until
predicted level of 90
(2) Voluntary 90-110
AĞg/m3
(3) Mandatory >110
EPA Phase II (1990
certified, all pellet
burners .
2 year exemption sole
source .
No other solid fuel
burning allowed.
At least one man year
staff plus 50? per capita
in purchased media.
Includes at least 3 of
the following:
Stove fairs, press
releases/fact sheets,
brochures , town hall
meeting with health
experts , TV/radio ads .
Results in better public acceptance.
Gives public a chance to see if voluntary
program can work.
Provides incentives for turnover of older high
emitting stoves.
No effective controls for fireplaces and coal
fired devices.
(continued)
-------
TABLE 5-8(a). (Continued)
Program Aspect
Rationale
5. Public Notification
(external
communication)
6. Surveillance
01
i
CO
to
7. Enforcement
Telephone hotlines
Radio/TV notices
Night time windshield
surveys.
Encourage citizen
complaints.
t Publicize enforcement
efforts.
Fine schedule that
exceeds or equals $50 for
1st violation and $75 for
subsequent violations.
Assumed Effectiveness:
80%
in second and successive years.
Effectiveness based on episodic not seasonal emission loadings.
-------
TABLE 5-8(b). ASSUMED EFFECTIVENESS1 FOR A MOST STRINGENT CURTAILMENT PROGRAM
Program Aspect
Rationale
i
u>
OJ
1. Mandatory
2. Three Stages
Exemptions
Public Awareness
in 1st year (no phasing)
(1) No curtailment until
predicted level of
75 /ig/m3
(2) Voluntary 75 -
100 pg/m3
(3) Mandatory >100
120 A*g/n>3 Stage I
Alert
(4) Mandatory >120 pg/m3
Stage II Alert
(1) EPA Phase II and
pellet burners, and
sole source heaters
in Stage I.
(2) No solid fuel fires
in Stage II.
At least one man year
staff plus 75C per capita
in purchased media.
Includes at least 4 of
the following:
Stove fairs, press
releases/fact sheets,
brochures, town hall
meeting with health
experts, TV/radio ads.
Gets significant results in short-term.
Need some margin between complete ban and
NAAQS.
Maintains incentive to replace high emitters
with low emitters.
(continued)
-------
TABLE 5-8(b). (Continued)
Program Aspect
Rationale
co
5. Public Notification
(external
communication)
6. Surveillance
7. Enforcement
Telephone hotlines
t Radio/TV notices
Night time windshield
surveys.
t Encourage citizen
complaints.
Maintain large staff ob
observers which can be
dispatched with each
episode.
Publicize enforcement
efforts.
t Fine schedule that
exceeds or equals $50 for
1st violation and $75 for
subsequent violations.
Investigate every
complaint.
Assumed Effectiveness
95%
in first and subsequent years,
Effectiveness based on episodic not seasonal emission loadings,
-------
TABLE 5-8(c). ASSUMED EFFECTIVENESS1 FOR A LESS STRINGENT CURTAILMENT PROGRAM
Program Aspect
Rationale
Mandatory
Three Staees
Ln
i
u>
Ui
Exemptions
Public Awareness
after 1st year voluntary
(1) No curtailment until
predicted level of
90 /*g/m3
(2) Voluntary 90 -
110 ng/m3
(3) Mandatory >110 j*g/m3
Any EPA certified 9.
Permanent sole source
At least one-half man
year staff plus IOC per
capita in purchased
media. Includes at least
2 of the following:
Stove fairs, press
releases/fact sheets,
brochures, town hall
meeting with health
experts, TV/radio ads.
t Results in better public acceptance.
Gives public a chance to see if voluntary
program can work.
Provides incentives for turnover of older high
emitting stoves.
No effective controls for fireplaces and coal
fired devices.
(continued)
-------
TABLE 5-8(c). (Continued)
Program Aspect Rationale
5. Public Notification t Telephone hotlines
(external Radio/TV notices
communication)
6. Surveillance t Night time windshield
surveys.
t Encourage citizen
complaints.
<" 7. Enforcement At least $25 per
w violation.
Assumed Effectiveness: 70%
Effectiveness based on episodic not seasonal emission'loadings,
-------
TABLE 5-8(d). ASSUMED EFFECTIVENESS1 FOR A VOLUNTARY CURTAILMENT PROGRAM
I
to
vj
Program Aspect
Rationale
1.
2.
3.
Voluntary
One Stages
Exemptions
Begins at 90 /ig/m3
All EPA certified devices
Provides incentives for turnover of older high
4. Public Awareness
sole source heaters.
At least one man year
staff plus 500 per capita
in purchased media.
Includes at least 3 of
the following:
Stove fairs, press
releases/fact sheets,
brochures, town hall
meeting with health
experts, TV/radio ads.
emitting stoves.
No effective controls for fireplaces and coal
fired devices.
(continued)
-------
TABLE 5-8(d). (Continued)
Program Aspect Rationale
Ol
OJ
00
5. Public Notification t Telephone hotlines
(external Radio/TV notices
communication)
6. Surveillance Gather compliance data
and publicize results.
7. Enforcement None.
Assumed Effectiveness: 20%
Effectiveness based on episodic not seasonal emission loadings.
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DRAFT - DO NOT CITE OR QUOTE
Methods of public notification;
Surveillance approach; and
Enforcement (penalties and enforcement resources).
Given these attributes, an assumed level of program effectiveness is provided
for each of the baseline programs, the more stringent alternative, and the
less stringent and least stringent (voluntary) alternatives. All alternatives
assume an accurate and reliable ambient monitoring network and weather
forecasting procedures.
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SECTION 6
HOW TO APPLY ESTIMATES OF EFFECTIVENESS TO DETERMINE TOTAL PM-10
SIP EMISSION REDUCTION CREDITS
In preparing the SIPs to address PM-10 nonattainraent, 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
specifically to illustrate how credits from various program elements can be
combined to demonstrate attainment. For each of the two examples, only the
24-hour standard -- which is sole cause of PM-10 NAAQS violation among
existing nonattainment areas with serious RWC emissions problems -- is
addressed. A similar approach could be used to address the annual standard.
6.1 GENERAL APPROACH TO DEMONSTRATING ATTAINMENT
In general the process of demonstrating attainment with the PM-10 NAAQS
includes the following steps:
Step 1--Based on monitoring results determine the worst case or design
day ambient concentrations and the improvement in ambient quality needed to
attain the NAAQS.
Step 2--Based on modeling or other source apportionment techniques,
determine the proportion of PM-10 from RWC compared to all PM-10 measured
during the design day.
Step 3--Based on overall PM-10 emission inventory of all source
categories -- such as RWC, road sanding, diesel exhaust, industrial emissions,
etc. -- determine overall emission reductions needed to attain the NAAQS.
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This is accomplished by multiplying the percentage reduction needed (from Step
2) by the total PM-10 emitted during the design day.
Step 4--Based on the contribution of various source categories and the
costs and effectiveness of controlling these sources, decide which control
programs will be deployed in order to demonstrate attainment. 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 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.
Step 6--Select from among the various program elements in Sections 2
through 5 of this report in order to find one or more that have the net
emission reductions needed to equal or exceed the total emissions 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.
The example in Section 6.2 below is a simple illustration of all six
steps. The example in Section 6.3 is presented in order to show how multiple
credits for RWC can be applied in a situation where there are several RWC
program elements.
6.2 FIRST EXAMPLE -- SMALL TOWN WITH MODERATE PM-10 EXCEEDANCES
A town of 2,500 population set in a high mountain valley is determined to
be nonattainment for the 24-hour PM-10 NAAQS of 150 jig/m3.
Step 1--Atmospheric monitoring results show that last winter there were a
dozen days in which the NAAQS was exceeded. The worst of these was a
300 /Jg/m3 episode. This is twice the level of the NAAQS. A 150 j*g/m3
reduction in PM-10 concentrations is required to demonstrate attainment in the
area SIP.
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
6-2
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DRAFT - DO NOT CITE OR QUOTE
the ambient concentrations were at 300 pg/m3, two thirds or 200 MS/1"3 are
attributed to RWC.
Step 3--The wood burning survey indicated that in this town there were
1000 RWC devices broken out as follows:
500 conventional wood stoves;
200 certified wood stoves; and
300 fireplaces.
The survey also indicated that during air quality episodes all wood
stoves and half of the fireplaces are in use. Applying the emission factors
given in Appendix A of this report to the types and numbers of units above.
Step 4--The town council decides that given the various sources of their
P-10, the preponderance of RWC emissions to the overall total, and the range
of alternatives for reducing RWC, that their attainment strategy will rest
entirely upon a RWC emission control program. They also want to bring the
town into attainment in one-year, if possible.
Step 5--In order to demonstrate attainment, the RWC emission control
program must demonstrate a 75 percent emissions reduction. This is based upon
the fact that on the design day there are 100 ^g/m3 of concentrations from
sources other than RWC. Because the NAAQS is at 150 /ig/m3, this leaves only a
margin of 50 /ig/m3 for RWC. To reduce RWC concentrations from 200 /ig/m3 down
to 50 /Jg/m3, a 75 percent reductions in RWC emissions is required. (The
percentage reduction in emissions required for attainment is assumed to be
equal to the percentage reduction in concentrations.)
Using the techniques and emission factors discussed in Appendix A, the
city staff calculates that the 24-hour emissions from the 1000 RWC devices are
as follows:
Conventional stoves (500 units): 180 kg
Certified wood stoves (200 units): 38 kg
Fireplaces (150 units in use): 262 kg
TOTAL 480 kg
If the total RWC emissions are 480 kg and if a 75 percent reduction is
needed, then the emissions reduction target for the RWC emission control
program is 360 kg. (This is derived from 480 kg x .75 - 360 kg).
Step 6--The town council decides to implement a mandatory curtailment
program that most resembles the baseline curtailment program described in
Section 5 of this report. It has an associated credit of 80 percent.
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Multiplying the 80 percent credit times the 480 kg of PM-10 being emitted
by RWC during the design day gives a total of 384 kg emission reduction. The
384 kg value exceeds the 360 kg emission target level from Step 5 above.
Therefore, this single program element is capable of attaining the NAAQS
within one year.
In many circumstances, several program elements may be required to
achieve the desired emission reduction targets. The following example focuses
on Step 6 because it entails a more complex application of RWC emission
reduction credits.
6.3. SECOND EXAMPLE -- MEDIUM SIZED CITY WITH SEVERE PM-10 NONATTAINMENT
PROBLEM
This city of 50,000 persons has a severe PM-10 nonattainment problem
caused in large measure by RWC. Each winter there are more than 30 days in
which the NAAQS is exceeded and the overall seasonal PM-10 levels are very
near the annual NAAQS.
Steps 1 through 5--Because of the large number of residents with sole
source heaters (which would be exempted from curtailment) and because of the
persistent visibility and odor problems and concerns over health effects, the
city council directs the city staff to develop a RWC emission control program
that does not rely on episodic mandatory curtailment but instead couples
voluntary curtailment with other approaches designed to reduce overall RWC PM-
10 emissions.
The wood heating survey indicates that emission inventory and wood
heating survey data indicates the following:
Appliance
Type
Conventional
Wood Stoves
Catalytic Wood
Stove
Noncatalytic
Adv. Design
Wood Stove
Emission
Factor
(g/hr)
15.0
6.6
9.6
Total No.
in City
6,840
1,500
1,5*0
No. Operated
On Design
Day
(operated
24 hours)
6,160
1,425
1,460
Emissions
on Design
Day
2218 kg
225 kg
336 kg
6-4
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Furnace 1.6 700 700 27 kg
Fireplace 9.3 A.560 2.550 569 kg
15,1*0 12,285 3375 kg
From Steps 1 through 5 (not performed in detail in this example), it is
determined that for the design day an 83 percent emission reduction --or
2800 kg -- is required in order to demonstrate attainment of the PM-10 NAAQS.
(The 2800 is determined by multiplying 3,375 times the emission reduction
percentage of 83 percent which was based upon a combination of ambient air
quality and policy goals not shown in this example.)
Using the more sophisticated annual RWC emissions estimating techniques
(from Appendix A) and considering the need to reduce the persistent emissions
levels, a secondary target of at least 50 percent reduction in overall
seasonal RWC emissions is also established. This is not required for attain-
ment but was set as a desirable long term goal.
In summary, the city staff must now select from among the program
elements in Sections 2 through 5 of this report those that collectively have a
net emission reduction of 2,800 kg of 83 percent for the design day.
Step 6--The city staff recommends a RWC emission control program that
consists of the following elements:
A weatherization program element that would require - - and
provide city revenue bonds as a subsidy -- every residence to
meet stringent weatherization levels (storm windows; caulking;
maximum floor, ceiling and wall insulation; etc). The program
would be complete by the third winter season (50 percent
effectiveness for the third year).
A high level public awareness program element that would
develop over a three-year period (20 percent effectiveness for
seasonal emission reductions).
Accelerated changeover program element whereby each residence
that is sold must either remove the RWC device or install an
EPA-certifled (Phase II) wood heater (10 percent per year
effectiveness for seasonal).
Voluntary curtailment program element (20 percent effectiveness
for episodic conditions; much less for seasonal).
The net effectiveness, or total credits for this RWC emission control
program package is calculated as follows:
Step A. Start with total baseline RWC emissions of 3375 kg/day.
6-5
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Step B. Apply the 50 percent weatherization credits to get
1688 kg/day remaining emissions and 1688/kg emission reduction.
Step C. Apply the 20 percent public awareness credits to the
remaining emissions of 1688 kg to get an incremental reduction of
338 kg (1688 x .2 equals 338). The new remaining emissions level is
1350 kg/day (1688 minus 338 equals 1350). The new net emission
reduction is 2026 kg/day (1688 plus 338 equals 2026).
Step D. Applying the 10 percent per year credits from accelerated
changeover results in a three-year total reduction of 27 percent
(not 30 percent because of a declining base). Applying the 27
percent to remaining emissions level of 1350 kg/day in Step C above
results in an incremental emission reduction of 364 kg/day for a new
remaining emissions level of 986 kg/day and a new net total emission
reduction of 2390 kg/day.
Step E. Applying the 20 percent credits from the voluntary
curtailment program, results in an incremental emission reduction of
197 kg/day and a final remaining emission total of 789 kg/day. The
final emission reduction credits from all program elements is
2587 kg/day. The 2587 is still short of the 2800 kg/day target
level required to demonstrate attainment.
The City can either add more program elements to further reduce the
remaining emissions or can more aggressively address the episodic problem with
a mandatory curtailment program -- perhaps one that is voluntary until the
third year.
6-6
-------
SECTION 7
REFERENCES AND SOURCE MATERIAL
7.1 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 7-1 provides the names of the officials we
interviewed, 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.
7.2 WRITTEN REFERENCES
Table 7-2 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.
7.3 BIBLIOGRAPHY
Table 7-3 lists printed material related to PM-10 and RWC topics but was
not used as reference material in this document.
7-1
-------
TABLE 7-1. 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 Bateraan, 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)
7-2
-------
TABLE 7-1. (Continued)
Reference
Number Contact
15 Larson, R. Butte-Silver Bow Health Department, Butte,
Montana, 21 December 1989.
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. Klamath Falls County Health Department, Klamath,
Washington,
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.
7-3
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TABLE 7-2. WRITTEN REFERENCES
Reference
Number Reference
41 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.
42 Burnett, and Tiegs. 1984.
43 "Citizens Against Wood Fumes Newsletter." Seattle, Washington,
1988.
44 Comis, S.K. Draft State Implementation Plan for Particulate
Matter - Yakima Area. Washington Department of Ecology,
Redmond, Washington, 1988.
45 Gay, R.L., W.T. Greene, andJ.J. Shah. A National Assessment
of Residential Wood Combustion Air Pollution Impacts. Nero and
Associates, Inc., Portland, Oregon, unknown published date.
46 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.
47 Grotheer, W.E. Overview of Control Strategies for Residential
Wood Combustion. EPA-84-70.1, U.S. Environmental Protection
Agency, Seattle, Washington, 1984.
48 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.
49 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.
50 Kameno, 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)
7-4
-------
TABLE 7-2. (Continued)
Reference
Number Reference
51 Klamath County Voluntary Compliance Plan. Klamath County,
Oregon, 1989.
52 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.
53 Little, A.D., Inc. "Survey of Wood Heating Devices." Consumer
Product Safety Commission, 1983.
54 Halo, 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.
55 Montana Department of Resources and Conservation. Wood Heat.
Department of Natural Resources and Conservation, Helena,
Montana, June 1988.
56 Oregon Department of Environmental Quality. Catalytic Wood
Stoves. Portland, Oregon, 1986.
57 Oregon Department of Environmental Quality. Certified Wood
Stoves. Portland, Oregon, 1986.
58 Oregon Department of Environmental Quality. Sizing Wood
Stoves. Portland, Oregon, 1986.
59 Radian Corporation, "Woodstove NSPS Issue Paper: Scope of the
Standard and Definition of Affected Facility." Prepared under
contract to U.S. EPA, revised 1986.
60 U.S. Environmental Protection Agency. "Advanced Notice of
Proposed Rulemaking (ANPR), RWC NSPS." Federal Register. 2
August 1985.
61 U.S. Environmental Protection Agency. Regulatory Impact
Analysis (RIA) Residential Wood Heater New Source Performance
Standard. 1 December 1986.
(Continued)
7-5
-------
TABLE 7-2. (Continued)
Reference
Number Reference
62 U.S. Environmental Protection Agency. Buying an EPA-Certified
Woodstove. 1986.
63 Washington Department of Ecology, Wood Heat. Wood Smoke and
You. Seattle, Washington, 1987.
7-6
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APPENDIX A
TECHNIQUES FOR ESTIMATING RWC EMISSIONS
A-l
-------
APPENDIX A
TECHNIQUES FOR ESTIMATING RWC EMISSIONS
1.0 INTRODUCTION
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 the emission reduction necessary to realize ambient air
quality goals. These emissions must be estimated in two ways. Seasonal
emissions of PM-10 from wood combustion are 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 70 /ig/m3. Seasonal emissions are 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, the day on which PM-10 emissions from wood stoves (and other
sources) are expected to be the greatest, usually because cold weather
requires greater use of wood combustion for heating residences. The design
day emissions are important because these are the days on which the 24-hour
PM-10 NAAQS is most likely to be violated. Control of emissions on the design
day is necessary to prevent "episodic" violations of the NAAQS. Almost all
PM-10 nonattainment occurs because of exceedances of the 24-hour standard of
150 /ig/m3.
An essential part of the emissions estimation process is the household
survey. The household survey is designed to obtain information on patterns of
residential wood combustion for heat, the types of wood burned for residential
heating, the types of wood combustion appliances in use, and the numbers of
each appliance installed in residences. Questionnaires should be carefully
A-2
-------
designed to be clear and succinct in order to obtain the information desired,
and they should be administered to a selected random sample of the population
of the locality that is expected to be representative of the community as a
whole. Further information on conducting household surveys to document
residential wood combustion patterns may be found in reference 14 of this
appendix.
When information has been gathered through the use of the survey on
residential wood heating, the five steps outlined below should be followed to
estimate both seasonal and design day emissions of PM-10.
2.0 CALCULATING RWC EMISSIONS
This subsection describes a recommended methodology for using the survey
results to derive emission estimates. The overall approach for estimating
annual PM-10 loading from RWC 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 month with the highest number of
heating degree days.
The following step wise approach illustrates how the compiled survey data
should be used to calculate RWC emissions.
Step 1: Identify typical wood characteristics for vour area
The first step in estimating emissions of particulate matter from wood
combustion units 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
A-3
-------
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 outlined here 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 annually is 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, and
aggregated to estimate 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 dry 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
the total amount of each species combusted (at determined from the survey
data) a "typical" mass value for each cord of wood combusted in the locality
can be determined by weighting the individual mass per cord values by the
A-4
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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
16.5
29.1
18.9
13.7
20.6
21.4
20.6
19.7
22.3
17.1
17.1
21.4
37.8
24.5
17.8
26.7
27.8
26.7
25.6
28.9
22.3
22.3
(Black, White and
Sitka)
Source: Wood Handbook, Agricultural Handbook No. 72, U.S. Department of
Agriculture, 1974. Washington, D.C.
A-5
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TABLE A-2. DETERMINING QUANTITY OF FUEL COMBUSTED
Wood Fuel
Type
White Oak
Western
Douglas Fir
TOTAL
Number of
Cords
Consumed
Annually
400,000
150,000
550,000
Wood Density
(lbs/ft3
dry mass)
37.8
27.8
Assumed
Solid
Wood/Cord*
(ft3/cord)
80
80
Dry Wood
Per Cord
(Ibs/cord)
3,024
2,224
Dry
Wood/Cord
(kg/cord)
1,371
1,009
*Note that a standard cord is 128 ft3 including wood and void spaces. This assumption is that approximately
80 ft3 of that is solid wood.
-------
relative amount of each wood type combusted, using the following general
equation:
n
MPCw =
n
2
-------
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
Non-Catalytic,
EPA or State
Certified
Catalytic
Furnace
27,500
27,500
82,500
1,272
1,272
1,272
3.5 x 107
3.5 x 107
1.0 x 108
A-8
-------
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.
When these emission factors are multiplied by the annual quantity of wood
consumed by each appliance 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 annual emissions from one appliance type (fireplace) would be
as follows:
2.1 x 108 kg wood X 9.3 g PM X Mg = 2.0 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 wood burning appliances in the
locality. Table A-5 depicts an example of the calculation of annual emissions
for a typical mix of appliances 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 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 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 (HDD)
figures for Denver, Colorado drawn from Table A-6, it is assumed that the
A-9
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TABLE A-4. RWC EMISSION FACTORS
Appliance
type
Fireplace
Conventional Stove/
Insert0
Noncatalytic0
Catalytic0
Furnace0
Pelletd
PM-10
(g/dry Kg)
9.3a
15.0
9.6
6.6
--
1.6
CO
(g/dry Kg)
85b
140
130
39
--
18
"Averages of values from references 12 and 13.
"From 1983 AP-42.
"Reference 14.
dAssume same emissions factors as conventional stoves.
A-10
-------
TABLE A-5. EXAMPLE OF AGGREGATION OF EMISSIONS FOR APPLIANCE TYPE
Appliance
Type
Annual
Consumption
(Kg/year)
PM-10 Emission
Factor
(gAg)
PM-10
Emissions
(Mg/year)
Fireplace
Conventional
Stove
Noncatalytic
Advanced
Design
Catalytic
Furnace
2.1 x 108
3.1 x 108
3.5 x 107
3.5 x 107
1.0 x 108
9.3
15.0
9.6
6.6
1.6
2.0 x 103
4.6 x 103
3.4 x 102
2.3 x 102
1.6 x 102
A-ll
-------
TABLE A-6. NORMAL MONTHLY AND SEASONAL HEATING DEGREE DAYS, 65° BASE-SELECTED ROCKY MOUNTAIN/
WESTERN AND PACIFIC NORTHWESTERN CITIES
f
I ğ
State
CA
CO
NE
OR
UT
WA
Station
Los Angeles
Sacramento
San Francisco
Denver
Omaha
Portland
Salt Lake City
Seattle-Tacoma
Spokane
JAN
286
611
512
1,101
1,017
809
1,128
803
1.218
FEB
233
412
375
879
773
610
865
622
913
MAR
240
366
378
837
756
592
753
645
849
APR
180
229
306
528
558
438
474
459
576
MAY
106
83
226
253
333
263
220
313
339
JUH
54
21
139
74
124
118
53
169
140
SEP
18
7
80
135
171
111
97
169
209
OCT
132
82
148
414
456
332
377
388
539
NOV
139
360
315
789
767
585
759
606
903
DEC
255
601
490
1,004
1,172
747
1,076
744
1,116
-------
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 relative-
ly mild, so that burning wood for 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 5: Calculate the PM-10 emissions from wood combustion on the design day
that would represent the worst case for emissions.
There are two alternative methods for determining the PM-10 emissions on
the day that typifies maximum wood combustion and, consequently, maximum
emissions. The first method uses the PM-10 emissions rate for the average
HDD, as calculated in Step 5, and bases emissions on the emission rate on a
typical day in the month requiring the most wood combustion for residential
heating. Using this method, the month with the greatest heating demand is
identified (i.e., the month with the greatest number of heating degree days).
Next, the average number of HDD in that month is calculated by dividing the
total number of HDD by the number of days in the month. This average number
of HDD per day in the worst month is then multiplied by the emission factor
for each HDD calculated in Step 5 to determine the PM-10 emissions for a
design day.
In the example below, again based on HDD data for Denver, January is
identified as the month with the greatest heating requirement at 1,101 HDD for
the month, or approximately 36 HDD per day.
36 HDD X 0.33 Me - 11.88 Mg/day
day HDD
The alternative means for calculating emissions for the design day is
based on an emission factor expressed as grams of PM-10 emissions per hour of
A-13
-------
operation for each appliance type. A gram/hour emission factor can either be
found in references, or can be calculated from the grams/kilogram of wood
burned factor discussed above. The EPA has determined that wood stoves burn
wood at an approximate rate of 1 kilogram per hour. For fireplaces, the rate
of combustion is approximately 7.5 kilograms per hour. As shown in Table A-7,
the emission factors in grams/kilogram in Table A-4 can be converted to
emission factors in grams/hour. Based on information about the mix of
different appliance types in the locality and assumptions about the number of
devices being used on the design day and the number of hours they are used,
total PM-10 emissions for the design day can be estimated, as shown in
Table A-7.
3.0 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
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
A-14
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TABLE A-7. ESTIMATION OF DESIGN DAY EMISSIONS
Emission Emission
Appliance Factor Factor
Type (g/kg) (g/hr)
Fireplace 9.3 71.0
Conventional 15.0 15.0
Stove
Noncatalytic 9.6 9.6
Advanced
Design
Stove
i
£ Catalytic 6.6 6.6
Stove
Furnace 1.6 1.6
Hours of No. of Emissions
Operation Appliances (kg/day)
24 200 340.8
24 150 54.0
24 50 11.5
24 50 7.9
24 10 3.8
TOTAL 418.0
-------
performed by the U.S. Department of Agriculture may be useful in evaluating
response. (Reference A-l) As a rule of thumb, respondents overestimated
annual 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 resurveys to have
overestimated 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 outlines. For
perspective, Table A-8 presents 1980-1987 national estimates of total wood
consumption by appliance type and average per unit consumption by appliance
type. Table A-9 presents fuelwood consumption characteristics by timber
region.
Apparent data outliers should be identified and follow-up contacts made.
During recontact interviews, respondents should be allowed and encouraged to
describe fuelwood consumption in terms that are familiar to them. Surveyors
should use the information in the responses to estimate a revised annual
consumption if necessary. Table A-10 lists guidelines for assisting surveyors
in evaluating these follow up responses.
4.0 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.
A-16
-------
TABLE A-8. 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-17
-------
TABLE A-9. FUELWOOD CONSUMPTION CHARACTERISTICS BY TIMBER REGION, 1980-81
Characteristic
Percent of Households burnine Fuelwood Consumption
Timber Region
Northwest
North Rocky
Mountains
i
& South Rocky
Mountains
WEST
Total Number
of Households
in Region
2.5
0.8
11.8
15.1
Any
Amount
Millions
55*
42*
29*
34*
Households
1/3 cord Burning
or more Any Amount
Million
47* 3.2
34** 0.8**
16** 3.1**
22* 7.1*
Households
Burning 1/3
Cord or More
Cords --
3.2**
0.8**
2.8**
6.8*
Relative standard error is 10 pet or less
"Relative standard error is 10.1-15 pet.
Source: Skog & Watterson.
-------
TABLE A-10. 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: Stog and Watterson.
A-19
-------
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 1949 to 1981. Washington, DC 20585, August 1982.
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. Technical Support Document for
Residential Wood Combustion. EPA-450/4-85-012, February, 1986.
A-20
-------
12. 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.
13. 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
14. U.S. Department of Agriculture, Forest Products Laboratory, Wood Handbook.
Agricultural Handbook No. 72, Washington, DC. 1974.
Heating Degree Data
15. National Oceanic and Atmospheric Administration. Historical Climatology.
Series No. S-l, July 1931 - June 1980. Asheville, North Carolina:
National Climatic Center. 1981.
16. U.S. National Oceanic and Atmospheric Administration, "Climatography of
the United States, No. 81," September 1982.
A-21
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APPENDIX B
REPORT SPONSOR, AUTHORS, AND REVIEWERS
B-l
-------
APPENDIX B
REPORT SPONSOR, AUTHORS, AND REVIEWERS
This report was made under the direction of Thompson G. Pace,
P.E., Senior Environmental Engineer, for 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.
The names and professional affiliations of those who served on
the technical review committee appear below.
Name Title Position
Kevin Golden
Andy Goodrich
Jim King
George Lauderdale
Bob Lebens
Bob McCrillis
Thompson G. Pace, P.E. Senior Environmental Engineer
Dallas Safriet
Martha Smith
Jeff Telander
John Watson
Dale Wells
Ann Williamson
Barry Young
-------
APPENDIX C
RWC EMISSION CONTROL ORDINANCES
C-l
-------
APPENDIX D
EPA FACT SHEET ON HEALTH
EFFECTS FROM RWC EMISSIONS
D-l
-------
"FACT SHEET"
POTENTIAL HEALTH EFFECTS ASSOCIATED WITH WOODSMOKE
NATURE OF THE EXPOSURE-
Wood heaters emit several air pollutants, including
pafticulate matter, carbon monoxide, hydrocarbons, and
polycyclic organic matter (POM). Particulate matter
dominates these emissions.
"Woodsmoke" consists almost entirely of small, respirable
particles (<10 micrometers (urn)), 80% are less than 2.5 urn.
Thus, woodsmoke can affect all areas of the respiratory
tract and readily reach the deep lung (alveolar region).
Retention of particles 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 where air pollution standards
for particulate matter are exceeded.
Studies examining the effects of particulate 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
D-2
-------
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, asthma,
bronchitis, heart disease), the elderly and children. These
individuals may experience a variety of overt 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 breath woodsmoke deep into
their lungs for extended periods while exercising at play.
Short-term Exposures
Clear evidence from epidemiological studies implicates
particulate pollution in aggravating disease among
bronchitics, asthmatics, cardiovascular patients, and people
with influenza (U.S. Environmental Protection Agency, 1982,
1986).
Specifically, particulate 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)
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Studies conducted in areas with high particulate pollution,
comparable to levels occasionally reported in areas heavily
impacted by wbodsmoke (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 particulate pollution, a
number of community epidemiological studies indicate higher
prevelance of respiratory symptoms such as wheeze and cough,
increased respiratory illness and disease, or lower lung
function for populations living in areas of high pollution.
In particular, children in such areas may show increasd
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.
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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 particulate 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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