Staff would develop estimates of any additional resources
necessary for this program and would bring them to the Board
during the next budget cycle.
The purpose of this memorandum is to provide background
information to those Board members who did not participate
in the deliberations of the committee.
Committee Activity
At its March 4, 1998 meeting, the Board appointed and Ad
Hoc Committee on Woodsmoke and requested a recommendation
to the Board by the end of 1998 for an overall woodsmoke program.
The committee began looking at the woodsmoke issue and developed
the policy recommendations and the model ordinance described
in the memorandum.
The committee conducted five meetings from April through
November. These meetings were attended by representatives
of the Hearth Products Association, the Homebuilders Association
of Northern California, the Tri-County Apartment Association,
local realty associations, and the hearth products manufacturers
and sellers.
At the first committee meeting, District staff and the Advisory
Council made presentations regarding the activities related
to woodsmoke. The Advisory Council presented a draft model
woodburning ordinance it ha developed. In subsequent meetings,
the committee reviewed a matrix of policy options in four
broad categories:
- Public education
- Market-based incentive programs
- City and county regulation of fireplaces and woodstoves
- District regulation of fireplaces and woodstoves
After discussion of policy options and model ordinance, the
committee developed the three recommendations noted above
and discussed below.
The Model Ordinance
The model ordinance is based upon Petaluma's 1992 ordinance
regulation new installations of woodburning appliances. The
model ordinance, like the Petaluma ordinance, is intended
to reduce the proliferation of new sources of woodsmoke pollution.
The primary provision of the model ordinance is a restriction
on what types of woodburning appliances can be installed in
a locality adopting the ordinance. Under the model ordinance,
installations of gas-burning devices would be allowed without
restrictions, but a woodburning device would have to be one
of the following:
- A pellet-fueled wood heater. These are inherently
cleaner -burning devices because they control the mixing
of fuel and air more tightly than conventional woodstoves
by using pelletized fuel. Emissions of virtually all these
devices are lower than emissions from EPA certified wood
heaters.
- An EPA certified wood heater. These are woodstoves
that meet EPA's particulate emission standards found in
their New Source Performance Standards for Wood Heaters.
These devices incorporate combustion controls, generally
a secondary combustion zone, or they use catalysts akin
to the catalytic converters used in motor vehicles.
- A fireplace certified by EPA, should EPA develop
a fireplace certification program. Though EPA does not yet
have a fireplace certification program, this provision was
included by the committee in order to keep the door open
for cleaner-burning fireplaces.
One of the primary issues discussed by the committee was
whether the model ordinance should include an emission standard
for fireplaces, and specifically whether the Washington State
fireplace standard, the nations' only such standard, was appropriate
for the inclusion in the model ordinance.
After lengthy discussion and debate regarding fireplace emissions,
the committee decided that it was inappropriate to include
the Washington standard or test method for fireplaces in the
model ordinance because both appeared inadequate. In addition,
there appear to be, at present, no available technologies
to significantly reduce emissions from open fireplaces. Because
the committee wished to leave the door open for cleaner fireplaces,
it decided that model ordinance would allow fireplaces certified
by EPA, should EPA develop a fireplace certification program.
EPA does not yet have a test method or certification program
for fireplaces. However, some EPA-certified "fireplace" woodstoves
(sometimes known as "EPA fireplaces") offer much of the aesthetic
feel of a conventional fireplace.
These restrictions on new woodburning devices imposed by
the model ordinance would be enforced by the building department
of a locality adopting the model ordinance. All localities
already require a permit for such an installation. The ordinance
would simply require a person to provide additional documentation
that a device to be installed is one of the allowed devices.
The ordinance also include two other general requirements:
(1) a prohibition on woodburning when the District issues
a "Spare the Air Tonight" warning, and (2) a prohibition against
using certain specified fuels, such as garbage and plastic,
in a woodburning appliance. Note that these requirements would
not be enforceable by a building department and would require
a locality to establish some other enforcement mechanism.
These could be treated as optional provisions.
The District
Rule
The District rule would complement the model ordinance and
would give the District authority to restrict woodburning
when particulate matter (PM) levels are high. It would not
address installations of new woodburning devices, which would
be left to the model ordinance. The committee decided to recommend
development of a rule that would incorporate the following
basic concepts:
- The rule would include two tiers of restrictions of woodburning.
- At the first tier, which would be triggered when the District
forecasts that particulate matter levels will approach the
federal PM standard, restrictions would be voluntary. This
first tier would be similar to the District's current Spare
the Air Tonight program.
- At the second tier, triggered when the District forecasts
a violation of the federal PM standard, restrictions would
be mandatory.
- Restrictions would be imposed on a sub-regional basis,
probably using the District's five current forecast zones.
- Mandatory restrictions would not go into effect until
about 2003.
Staff would develop estimates of any additional resources
necessary to develop this rule and bring them to the Board
during the next budget cycle.
Public Education
A public education program would provide outreach to accompany
the model ordinance and would aid the effort to develop and
implement the District rule. For the model ordinance, the
District would provide outreach to communities and additional
assistance to those that desire to adopt the model ordinance.
This work would be done by staff in the District's Public
Information and Outreach Division working with county resource
teams and could proceed after two current vacancies in that
division are filled. Staff would develop estimates of any
additional resources necessary for this program and would
bring them to the Board during the next budget cycle.
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