Faulkner Architects
12242 Business Park Dr.
Truckee, CA 9616
530 582 7400
(Greg Faulkner called about approval in Truckee 10/03. Has talked with Bill Miller, Chief plans examiner?)

1035 Monroe Street
Port Townsend, WA 98368
360 385 9974 (fax 360 385 1624)

August 19, 1999

Kim Dalbol
Planning Department
11570 Doner Pass Rd.
Truckee, CA 96161
530 582 7820 (fax 530 582 7889)

Dear Ms. Dalbol,

We understand that you disapproved a wood-burning Rumford fireplace plan submitted by
Architect, Judy Hemingway last week even though the Rumfords were tested for emissions
by an EPA certified lab and are approved in Washington and other places that recognize the
Washington fireplace emissions standard. The reason you gave was that the fireplaces
were "not on the San Luis Obisbo list".

We would like to appeal your decision and formally apply for approval in Truckee of our
Rumford fireplaces that meet or exceed the emission standards for EPA Phase II stove

Our 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.

We would further submit that the Washington fireplace emissions testing protocol and
standard, expressed as an emission factor of 7.3 grams of PM10 per kilogram of fuel
burned, is the only existing testing protocol and standard appropriate for fireplaces. There
are people who disagree with the Washington Technical Advisory Group that developed the
standard and the Washington legislature which approved it. Specifically, Paul Reitz in San
Luis Obisbo doesn't agree with the idea of using an "emission factor" instead of the
"emission rate" used by EPA for stoves. But neither Paul nor anyone else has put forward
any other fireplace standard.

In the absence of any other fireplace appropriate standard, we urge you to recognize the
Washington standard. Getting on the SLO List in the absence of any objective criteria is
purely up to the subjective whim of Paul Reitz. To disapprove our Rumford fireplaces
because they are not on the SLO List amounts to holding us to a non-existent standard. We
think that is unfair.

If you have any questions or would like submittal of our test results directly from OMNI,
please call me at 360 385 9974.


Jim Buckley
Copy: Judy Hemingway, Hemingway Stock Architects (fax 925 944 4729)

Fireplace Emissions
Buckley Rumford Fireplaces
Copyright 1996 - 2003 Jim Buckley
All rights reserved.