Ideas for Lowering Wood Smoke Emissions on the Wasatch Front Submitted by: John Mortensen Energy Distribution Systems 1824 Alexander Street SLC, UT 84119 801-974-0899 cell 801-698-7282 Brett J. Hogge Hearth & Home Distributors of Utah 3380 S. 1325 W. Ogden, UT 84401 801-621-3921 cell 801-791-4047 As local suppliers of fireplaces and stoves we ask for your consideration of the following concerns that we have about current & proposed DAQ regulations and our ideas for reducing residential wood smoke emissions. Each of our companies has been in the fireplace business for forty plus years. We feel that by working together with our State Legislators that we can reach our common goal of improving our air. This will not only benefit the quality of our air and our state, but it can also help our citizens stay warm, cut heating costs and be prepared for emergencies, while at the same time helping our local hearth industry remain a healthy contributor to our states economy. DAQ Rules implemented in the last year: Exemption for wood burning appliances that produce zero visible emissions on restricted days removed. Lowered the PM 2.5 threshold for declaring restricted days. DAQ can now call restricted days based on forecast rather than actual. All sales of fireplaces and wood stoves have to be EPA approved. Existing non-EPA certified woodstoves currently in a residence cannot be sold, transferred or purchased. (see attached “Wood Smoke Workshop”) Our Concerns: 1. By removing the exemption for EPA stoves that are burned with no visible emissions, older dirty stoves and newer EPA cleaner burning models, are now restricted from burning at the same cutoff point. This removes much of the incentive old technology owners might have to upgrade to a cleaner stove if there appears to be no advantage to do so. 2. About one third of the controlled burning season, (Nov 1 – Mar 1), for the last two years have been mandatory no burn days. If you add in voluntary days it is about fifty percent of the burning season that residents have been asked not to burn. Again, no incentive to upgrade if restrictions kick in at the same time for both old and new technology. (see attached “Utah Historical Summary”) 3. By forbidding the sale, transfer or purchase of non-EPA stoves, these stoves have essentially been reduced to a zero value. If someone wanted to upgrade to a cleaner burning model, previously they would have sold the old one and applied those monies (approx. $100 - $400) to the purchase of a new EPA woodstove or a gas stove. We agree that it is in our best interest to get the old dirty burning stoves out of use. We are simply stating that by restricting the sale of older models alone, incentive to upgrade is diminished. DAQ Proposed changes: Removal and scrap of old non-EPA appliances upon sale of a home. Change out program for non-EPA appliances to EPA approved or to natural gas appliances. Retire sole source exemptions (207 households). Ban solid fuel (wood burning) devices in new construction. (see attached “Wood Smoke Workshop”) Our Concerns: 1. Again, removal and scrap of older stoves with no compensation leaves wood stove users sour on the whole deal. Not only did they get nothing for the stove that they invested in, but it will cost them to dispose of it. 2. We do applaud the idea of a change out program to update to either new technology wood appliances or to gas appliances. Monies collected from fines associated with environmental violations could be put to good use by incenting those who own older dirty burning stoves to upgrade. Now they can get some value out of their old stove by choosing the upgrade path, either to a new technology wood stove or to a natural gas stove that can be burned year round. 3. We are concerned that there are more sole source users than those currently registered with the state. We believe that many of those who fall into this category do not search out and read public notices that are hidden in the newspaper or the DAQs website. They most likely are unaware that they are supposed to register. If enforcement picks up, we will find many more who belong in this category. DAQ goals: Reduce wood smoke emissions. Improve wood smoke restricted compliance to at least 95%. (see attached “Wood Smoke Workshop”) Our Concerns: 1. The current regulations are no carrot and not much stick. Currently there are only 7 inspectors for the entire state. If very little enforcement happens then compliance will go down. The system right now calls on neighbors to rat on neighbors. What a great way to encourage and develop community spirit. We feel that a combination of state, county, local cities and towns enforcing the rules along with incentives to upgrade will increase compliance. DAQ stated inventory of wood burning appliances: Fireplaces: 10,510 Woodstoves and Inserts non-EPA: 12,914 Woodstoves and Inserts EPA: 6,955 Pellet Stoves: 3,984 Furnace: Indoor cordwood non-EPA 2,459 Total: 36,822 (see attached “Wood Smoke Workshop”) Our Concerns: 1. We do not think that these numbers are an accurate reflection of the wood burning appliance inventory. Sales volumes of wood burning stoves were magnitudes greater during the seventies and eighties than they are now. Also, from the time this valley was first settled up until the 1990s, a large percentage of homes were built with wood burning fireplaces in them. 10,000 fireplaces seems to be pretty low for the number of fireplaces in the seven non-compliant counties. 2. Because of the preparedness mentality and the independent and frugal nature of our population, especially during the energy crises of the 1970s, we believe the number of non-EPA stoves in our area is greater than 13,000 and greater than national averages. In 1979 Energy Distribution Systems alone sold over 4200 woodstoves. At least a third of them were sold into this area. We were but one of many businesses selling woodstoves back then. In the seventies during the energy crises there were a large number of manufacturers and dealers selling woodstoves in Utah. The number of non-EPA woodstoves listed above in our opinion is understated and the national averages that these numbers were developed from are not very accurate here. 3. After the energy crises of the seventies ended and EPA regulations came about in the late eighties, the number of manufacturers and dealers that were previously in business was reduced by almost 90 per cent. Leaving the few dealers that are left in the present day. With smaller demand and prices that have tripled with better technology, fewer new technology stoves have been sold into the market. 4. Central wood fired furnaces are all but non-existent here. During the years of eighty to eighty two a few were sold. Because the DAQ is using the EPAs national averages, 2,459 was listed as the number of central wood fired furnaces in these seven counties, even though the DAQ has acknowledged that this category of woodburning appliances does not apply in this geographic area. They have used this number anyway. 5. In summary, by under estimating the number and types of appliances in these seven counties, more emissions are attributed to fewer stoves, greatly exaggerating the impact that woodstoves are having upon our airshed. Having said this, we do understand that we need to do our part and share in the responsibility of cleaning up the air. However, we feel that because the number of appliances is estimated too low, results expected from reducing wood burning will not be as great as anticipated. Even if wood burning was stopped completely. DAQ stated comparisons of heating with wood vs. heating with natural gas: Heating your home with fireplaces: = heating over 100,000 homes with natural gas (in terms of PM2.5) = heating over 1 million homes with natural gas (in terms of VOC) (Salt Lake County) Heating your home with a conventional wood stove: = heating over 90,000 homes with natural gas (in terms of PM2.5) (Sandy) = heating over 250,000 homes (in terms of VOC). (More than SLC) Heating your home with an EPA-certified catalytic wood stove: = heating over 60,000 homes with natural gas (in terms of PM2.5) = heating over 70,000 homes with natural gas (in terms of VOC). (see attached “Contribution of Woodsmoke to PM2.5 During Wasatch Front Inversions”) DAQ uncertainties: Uncertainties: •Inventory - how many people actually burning on an inversion day? •Inventory - based on national average data. •Source attribution - only tracks direct PM •Source attribution - cannot resolve cooking and woodsmoke Currently collaborating on a study to resolve woodsmoke from cooking. (see attached “Contribution of Woodsmoke to PM2.5 During Wasatch Front Inversions Our Concerns: 1. As mentioned previously, we feel that the total inventory of wood burning appliances has been understated. Assuming that all of the math has been done correctly, if the numbers input into the models are not correct the results can be hard to believe. The example above states that by using open fireplaces to heat one home, it produces the same level of emissions as those produced by using natural gas to heat 1 million homes. 2. Let’s assume though that the modeling is correct. Using these numbers to educate the public will make them skeptical. Apparently the environmental community and Kerry Kelly have already discovered this because they have backed off of using these numbers publicly. Our concern is that if the DAQ is not taken seriously, that their efforts to encourage compliance will be less effective. 3. At the end of Board Member Kerry Kelly’s power point presentation, she acknowledges the uncertainties of their data. Summarizing, they say that they do not know how many people are burning and how many and what types of woodburning appliances exist in these seven counties. The test method she has used can only track direct PM production and not VOCs , and they cannot tell the difference between PMs produced from cooking and those produced by woodburning. It was stated by the DAQ that there are over 7500 restaurants in this area. If the actual emissions from these restaurants are not taken into consideration then reducing woodburning in the valleys will not produce the level of reductions in PM2.5s that they are looking for. 4. As stated by Joel Karmazyn during the Wood Smoke Workshop on Jan 15th 2014, Residential woodburning has been targeted because it is the lowest hanging fruit and the easiest category to restrict, with the lowest cost to achieve emissions reductions. Lowest cost for whom, the DAQ, or the affected citizens of our state. Most reports that we have seen, state that woodburning accounts for 5% to 10% of the PM inventory in our airshed. While we realize that there is a serious problem with our air quality, and that residential woodburning is definitely a contributor, we feel that homeowners who would like to burn wood to keep warm are being unfairly asked to shoulder a disproportionate share of the burden, at their own personal expense. Summary and Suggestions: 1. Change Out Program - If a tax incentive or rebate can be given to those who upgrade to an EPA approved or gas burning appliance it would be a positive approach to encouraging changeout and compliance. Instead of completely devaluing their woodstoves, it will give them some compensation if they choose to upgrade. Monies earmarked for environmental improvements could be used for this. If there is no perceived advantage to upgrade to a cleaner wood or gas appliance, they will stick with their old dirty stove rather than just throw it away. 2. 2 Stage Burn Restrictions - By implementing a 2 stage plan for burning restrictions we can reduce emissions even more while at the same time giving incentive to upgrade to a cleaner burning appliance. For example: a. In the chart below the top line (red) shows the current rules for burning restrictions. This plan gives no reward to those who have invested a good share of their money to upgrade to the latest, most efficient cleaner burning stoves. They have to shut down at the same time that those with old dirty stoves are required to. b. Proposal 1 - The second line (green) shows an alternative that would call for an earlier mandatory shut down of dirtier burning appliances and then allows EPA Phase II appliances to continue burning, if burned with zero visible emissions, until a mandatory no burn period is called. Those burning EPA appliances improperly, producing visible smoke, would be in violation. This plan would at the least, equal the emissions occurring in the current voluntary no burn period. And at the most, because of the 70% fewer emissions produced by the EPA approved stoves and the relatively small number of them installed in homes, particulates production would be even lower. This would create a great incentive to upgrade to a cleaner burning appliance for those who wish to continue burning wood, especially if it is combined with a tax incentive or rebate. c. Proposal 2 – The third line (blue) shows another alternative. This plan would implement an earlier voluntary no burn period for dirtier stoves. And allow a period that cleaner EPA stoves could continue to burn unrestricted, if burned with zero visible emissions. Those burning EPA appliances improperly, producing visible smoke, would be in violation. At the point where the current plan calls for a voluntary no burn for all woodburning appliances, this proposal would start a mandatory no burn for non-EPA appliances and a voluntary no burn period for EPA approved appliances. This plan is a no risk plan for the DAQ. It shuts down most of the woodburning sooner than their current plan does. For those who wish to continue burning wood, this would still give incentive to upgrade to a cleaner EPA approved model, especially if combined with a tax incentive or rebate. d. On December 12th 2013 the Hearth Industry was invited by the DAQ to host a workshop for the local hearth dealers. It was held at the office of Energy Distribution Systems. This meeting gave the DAQ and the local hearth professionals an opportunity to meet and discuss the upcoming changes to the State Implementation Plan (SIP) and the associated regulations. When either of the proposals discussed above were brought up, they were pretty much ignored and not discussed. Obviously they did not want to entertain any alternative options. The same thing happened at a workshop at the DAQ offices on January 15th 2014. Again, they did not even acknowledge the proposals for a 2 stage plan. These have been successfully implemented and enforced in several other areas of the country. Two examples are Tacoma Washington and the Puget Sound. 3. Work Together as a Community - We are concerned that the current approach is no carrot and not much stick. Those who are affected by these new regulations are feeling unfairly targeted. We all want clean air and we all want to do our share and contribute where we can, but we should all shoulder the burdens together. The DAQ refers to residential wood burning as last of the low hanging fruit. Individual home owners are not organized and don’t have a powerful lobby at their disposal to represent their concerns. Compliance will come grudgingly and will not reach the level of compliance to make the DAQs SIP work. It needs 95% plus to make their plan work. Using unreal numbers to make their case creates skepticism. Encouraging neighbors to rat on their neighbors creates discord and further entrenches non-compliance. Making their stoves worthless and requiring them to throw them away upon sale of their home does not foster a sense of love for their government and the rules that they produce. This all means that compliance will not be won easily. It will require a lot of enforcement. Currently there are seven compliance inspectors for the entire state. This type of approach will require the highest cost for enforcement. We believe that a balanced approach with incentives and increased enforcement will make the plan work the most economically and will help foster a greater sense of community and desire to work together to solve our challenges. 4. Preparedness and self sufficiency – If the DAQ and the local environmentalists had their wish, wood stoves would all just disappear. This may not be the best scenario. Attached is a February 1st 2014 article from NBC News about the twenty four states that have declared an energy emergency. Because of the bitter cold across much of the eastern part of our country, people are struggling to find the resources to stay warm. Propane shortages are occurring and prices are rising. Natural gas users are being asked to turn their thermostats down so as not to overload the supply system. In an emergency like this how are we expected to keep our families warm. Some who own woodstoves do not burn regularly, they just want to know that they have backup when they need it and that they can legally use it. (see the attached article “Prolonged Cold Blast Worsens Propane shortage Across Midwest”) 5. More Study – We would encourage the DAQ to continue efforts to develop techniques to differentiate between the emissions contributions of cooking and those of woodburning. Over 7500 restaurants, many running 24 hours a day, have to be making a measurable contribution to the particulate levels in our atmosphere. Also, efforts to determine a more accurate inventory of wood burning appliances and their types, and the frequency of their use in our area, will go a long way towards producing a more realistic picture of the emissions contributions of these appliances. 6. March HPBA Trade Show in SLC – This coming March 6-8 the Hearth Patio & BBQ Association will be holding its annual tradeshow here in Salt Lake City again. Though our numbers are smaller because of the downturn in new construction and the economy in general, over 6,000 attendees will be coming into town for the convention. We invite any state and local legislators who would like a complimentary walk through of our tradeshow to see the latest technology in action, to contact us for a pass. Our industry is committed to producing the most efficient and environmentally friendly products possible. Please contact either John Mortensen or B. J. Hogge and we would be happy to arrange it for you. Our contact information is on the
Posted on: Tue, 30 Dec 2014 15:20:57 +0000