California Hearths & Homes

Emerging Fireplace Regulations in the California Bay Area

Questions & Answers
12/28/99

BACKGROUNDER
CONTACT
Erich Parker
703 875 8650
Michael Gersick
916 491 1998
Questions & Answers about Wood-burning Fireplaces and the Environment
Q. Are emissions from log-burning appliances a significant contributor to air pollution?
A. That all depends upon the kind of log-burning appliance in use. Some wood-burning stoves and other such "closed system" fireboxes have for some time been significant contributors to air pollution. This fact is ironic, given that their widespread use began during the Carter Administration when the back-to-nature environmental ethic was so popularized. In 1988, the U.S. Environmental Protection Agency (EPA) instituted a log-burning appliance certification program specifically aimed at controlling air pollutants from these suddenly very popular closed system stoves. (The EPA defines a closed system as a log-burning appliance with a 35-to-1 air-to-fuel ratio or less. This ratio excludes log-burning fireplaces.)
Q. Has the United States EPA instituted a certification program for open log-burning fireplaces?
A. No. No regulatory activity or ³certification² program has ever been initiated by the United States EPA for fireplaces. It is a popular misconception that there exists an EPA standard or certification for open, masonry fireplaces. There is none.
Q. What does wood smoke release into the atmosphere that concerns the Bay Area Air Pollution Control District?
A. Open fireplaces release PM10. PM stands for "particulate matter," which can best be described as very small liquid and solid particles floating in the air. The ³10² refers to particles less than 10 microns in diameter (smaller than the thickness of a human hair). PM10 is a public health concern, because these particles are small enough to be inhaled into the lungs.
Q. In addition to log-burning fireplaces, what are the other sources of PM10?
A. There are many sources of PM10, including automobile and truck exhaust, construction and demolition dust, ocean spray, smoke from commercial kitchens, agricultural field and waste burning, landfills, and industrial and power plant emissions, to name a few.
Q. Do open-system log-burning fireplaces release enough PM10 into the atmosphere to be a legitimate public health concern in the Bay Area?
A. Only very rarely, according to the Bay Area Air Quality Management District (BAAQMD) itself. In its ³Woodburning Handbook,² the BAAQMD states: ³On the handful of nights when pollution levels approach unhealthy levels, the Air District encourages Bay Area residents to refrain from burning wood unless clean-burning wood stoves and fireplaces are used.² [Italics added for emphasis.]
In 1988, the EPA established a rigid, 24-hour, federal standard for acceptable levels of PM10 from all sources. The PM10 levels throughout the San Francisco Bay area have been safely below the federal standard every single day since 1991. (In 1990, the standard was exceeded six calculated days, and in 1991, three.) Thus, according to U.S. Environmental Protection Agency standards, PM10 levels in the Bay Area do not pose a threat to public health today, nor have they for almost a decade.
Shortly after the enactment of the federal standard, the State of California enacted a new, even stricter PM10 standard, one that goes well beyond what the federal government mandated. Since 1989, the number of times the California standard has been exceeded has steadily and dramatically decreased from a high of 51 calculated days in 1989 to low of three calculated days in 1996. During the most recently reported period, 1997, the California standard was exceeded four calculated days, again, from all sources of PM10 emissions.
Q. Isn't reducing PM10 emissions even more a good idea?
A. Protecting the environment and safeguarding public health is always a good idea‹one fully embraced by California Hearths & Homes, the coalition of masonry, log-burning fireplace builders in the State of California. Despite the fact that EPA standards suggest there is no PM10 public health threat, and the fact that open fireplaces account for only a fraction of what is recorded in the atmosphere‹the log-burning fireplace builders in California have been working for several years to design and produce even cleaner burning open fireplaces. Tests underway this month, at OMNI Labs in Washington, will contribute further to the industry effort to match its clean-burning designs with EPA standards for woodstoves.
Q. The Bay Area Air Quality Management District has drafted a proposed ordinance to ban traditional log-burning fireplaces. What's behind the public demand for cleaner burning open fireplaces?
A. Unlike the period in the early 70s when high energy prices drove consumers to shut off their furnaces and burn wood in the fireplace for heat, the typical homeowner today enjoys home heat from a central furnace. Log-burning fireplaces typically are relegated to special occasion use, when the crackling sounds and dancing flames of a log-burning fire add a special ambience to a room.
The new generation of cleaner-burning open fireplaces reflects the concerns of the general public about energy conservation and air quality. Changes in fireplace design may account, in some measure, for the steady decline in California PM10-standard violation days since 1988. This dynamic will, in itself, continue to drive the log-burning fireplace industry to produce even more efficient, cleaner systems than are on the market today. Simply stated: There is no incentive for the industry to do otherwise.
Q. Would any of these clean-burning fireplaces be exempt from the proposed ban?
A. No, although the language of the Model Ordinance is misleading. The draft ordinance makes exceptions only for log-burning fireplaces that are ³EPA certified². There is no such EPA log-burning fireplace certification program, and the EPA has no plans to institute any such program. In order to be exempt from the ban, a log-burning fireplace would be required to display a non-existent ³certification² of compliance with a non-existent federal standard.
Q. For the purposes of the Bay Area Air Quality Management District's (BAAQMD) proposed ordinance, how accurately is PM10 being measured?
A. The approach that the district is taking to measure PM10 is a matter of considerable debate within the environmental, regulatory, and log-burning fireplace communities. Their proposed ordinance is based on data that are open to interpretation because:
(1) The ³chemical mass balance² method of interpolating data is effective at differentiating among different source categories, but cannot differentiate actual sources within a category. That is, the BAAQMD¹s analytical hardware can distinguish between construction dust PM10 and carbon-fueled combustion PM10, but it cannot distinguish between wood smoke, domestic cooking and restaurant smoke, tobacco smoke, yard waste and debris burning, and barbecues.
(2) The study that is being used extensively to provide the "scientific" basis for the ordinance is nearly a decade old‹relying on samples taken during an era of generally higher PM10 concentrations throughout the Bay Area, and on readings from only two of the Bay Area's 17 pollution monitors‹two monitors located in San Jose that historically produce high PM10 not demonstrably related to fireplace use.
Q. Do Bay Area residents consider fireplaces a significant enough source of pollution to justify such a stringent ordinance?
A. Apparently not. In a July, 1999 survey of registered voters in the Bay Area conducted by Opinion Dynamics Corporation, a highly respected public opinion research firm, fewer than four in ten people voiced initial support for the ordinance. After learning more about the ordinance, two-thirds of those questioned opposed it.
Q. In addition to the masonry fireplace industry's efforts to design and build cleaner burning open fireplaces, what can be done to further reduce PM10 emissions from their fireplaces, short of this outright ban?
A. Consumers can do a lot to reduce PM10 fireplace emissions, but that requires public education on such issues as how and when to use fireplaces. The way you build a fire and the type of wood you use affects the amount of PM10 emitted from a chimney. There are a host of other steps that can be taken as well: voluntary curtailment during Spare the Air (no-burn) Days; use of manufactured logs (presto logs); and after-market devices that can be used in the fireplaces to reduce wood smoke pollutants by an amount certified to be in excess of 50%. California Hearths & Homes was established to begin and promote just such public education.
Q. What is California Hearths & Homes?
A. Headquartered in Sacramento, the California Hearths & Homes is a coalition of masonry, log-burning fireplace builders in the State of California. It is devoted to encouraging the development of cleaner burning open fireplaces and to promoting public education about how to use log-burning fireplaces responsibly, while keeping our environmental footprint light. In addition, California Hearths & Homes advocates the enactment and enforcement of No-Burn Days throughout California.
California Hearths & Homes can be reached at 916/491-1998.

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