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1035 Monroe Street |
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August 19, 1999
Jo Crumbaker, Air Quality Planning
1001 North Central Ave.
Suite 201
Phoenix, AZ 85004
602 506 6705 (fax 602 506 6179)
Dear Ms. Crumbaker,
We would like to apply for approval in Mericopa County, AZ of our Rumford fireplaces
that meet or exceed the emission standards for Phase II stove emissions.
Two Rumford fireplaces were tested by OMNI Environmental Services, an EPA certified
lab, pursuant to the Washington state fireplace emissions law. The Washington test was
designed to be an equivalent test standard to the EPA Phase II stove standards but
incorporating appropriate procedures for fireplaces. Our Buckley Rumford Fireplace
test results are attached.
Further we would ask, as approved in Washington, that you approve two untested sizes in
between the two sizes we actually tested. The dimensions of all four Rumford models are
proportional and we have every reason to believe, having tested the smallest and the
largest, that the two intermediate sizes would have similar emissions.
I have read the Maricop County Air Pollution Control Regulations, Rule 318, Approval of
Residential Woodburning Devices and I talked with you personally a couple of weeks ago by
telephone. It seems to me that our Rumford fireplaces should be approved since they have
been shown by tests conducted by an EPA certified lab to meet the "performance standards
that are equivalent to the standards in 40 CFR 60, Subpart AAA as amended through
July 1 1998" as specified in Section 201.4 of Rule 318.
I am aware that Section 201.4 goes on to require approval by "the Control Officer and the
Administrator of EPA" but since the EPA Administrator does not and will not approve
fireplaces, this would seem to be an unfair and unenforceable rule. I am also aware that
Section 302.1 of Rule 318 requires testing protocols to be "substantially equivalent to the
certification procedures and testing protocols used by the Northern Sonoma County Air
Pollution Control District" but since the Northern Sonoma County Air Pollution Control
District does not have certification procedures and testing protocols in place as of this date,
and since the draft certification procedures and testing protocols they do have are
"substantially equivalent" to the Washington certification procedures and testing protocols,
which are the only ones in existence appropriate for fireplaces, I urge you to rule favorably
on our request for approval in Maricopa County.
If you have any questions or would like submittal of our test results directly from OMNI,
please call me a 360 385 9974.
Best,
Jim Buckley
Copy:
Bob Bishop - bd5jbish@primenet.com
Charlie Wilson
