August 19, 2014

Air board should take closer look before doubling of no-burn days

The San Joaquin Valley is no stranger to air pollution issues and has long struggled to find solutions for high levels of particle emissions in the air.

The San Joaquin Valley is no stranger to air pollution issues and has long struggled to find solutions for high levels of particle emissions in the air.

On July 31, the San Joaquin Valley Air Pollution Control District had a public workshop to discuss proposed regulation changes related to wood-burning fireplaces and wood-burning heaters ( District Rule 4901). A very small audience of Valley residents attended, despite the fact that the rule amendments would effectively more than double the number of projected no-burn days and prohibits burning for most Valley residents for more than half of the 120-day winter season.

As members of the community ourselves, and as a longtime San Joaquin Valley company, we at Duraflame understand the challenges the Valley faces around pollutant dispersion and are invested in providing cleaner burning solutions for residential fireplaces.

As the air district announced the rule change proposal during the summer, when residents are not actively thinking of their fireplaces and the impact that a winter with twice as many no-burn days would have on their day-to-day comfort, we believe citizens should be given an opportunity to closely evaluate these proposed changes.

The new proposed rule lowers the fine-particulate matter (PM2.5) concentration threshold for calling no-burn days by 10 points, from 30 µg/m3 to 20 µg/m3. This proposed threshold is 43 percent below the federal standard, despite the fact the district presents no substantial evidence that this drastic regulation change will have any significant impact on the Valley’s air quality.

The district continues to position residential wood-burning as the leading cause of fine-particle emissions during winter months, when its 2014 public survey indicates that 78 percent of residents have reduced wood-burning activities. Despite a decline in general fireplace use, pollution levels were still high, indicating that other sources of PM2.5 were exacerbating pollution levels.

In order to thoroughly address air quality in the Valley, the district must more closely evaluate and determine ways to regulate larger particulate emissions and consider all clean-burning solutions for residential fireplaces. For example, a manufactured fire log produces 80 percent fewer fine-particle emissions than a wood fire of a similar duration.

We ask that the community thoughtfully consider how the impending regulation would affect their winter season, and to provide responses during the open commenting period, which opened Tuesday and closes Sept. 2. We call on the district to re-evaluate the severity of this rule change and consider the full impact on the community of stricter burn regulations and the projected doubling of no-burn days.

The district has an obligation to the Valley to enact sensible and balanced regulations with factual-based, strategic foundations that work toward cleaner air.

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