A Case Study
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Date: Thu, 12 Jan 2006 From: Michael Reddell To: Jim Buckley I just spoke to Tim Fuhs at the San Luis Obispo County Air Pollution Control District and he told me that Rumford fireplaces are not on their approved list of wood-burning devices. He did seem open to new data that might change their minds on the subject, but at this point they will not allow me to install a Rumford in the house I am preparing to build this summer. It is possible that my architect, Mark Primack, copied on this note, could design the fireplace space in such a way that we could temporarily block out the space and add the fireplace later if things change, although this would be a costly and inefficient approach. I'm hoping against hope that we can solve this in time to just do it right from the beginning. Here is a link to the San Luis Obispo County Air Pollution Control District web site for your reference: http://slocleanair.org/programs/woodstoves-approved.asp Tim told me that he thought they had looked at Rumford data in the past, but again, they are open to new data. The person he said you should talk to is Paul Reitz (preitz@co.slo.ca.us) I'm really hopeful that we can use a Rumford, and eager to hear back from you on this.
Thanks,
Michael (and hello to you, Mark), Well, it's always worth another try. I will write to Paul Reitz and, in the meantime, I recommend that you print off our test results at http://www.rumford.com/testRumfordresults.html and submit them to Tim Fuhs with your application for approval. We have had quite a struggle with SLO and in particular Paul Reitz. See the email exchanges on line at http://www.rumford.com/emissions/SLO.html But the reason it might be worth another try is because we have never really tried before. Always before Paul has said "no" for whatever reason comes to mind and none of our customers have ever taken it further. We did participate in another round of testing in 2000 using the Northern Sonoma fueling protocol which Paul told me at one time that he would respect. The problem remains that the grams of particulates per hour "rate" demanded by Northern Sonoma County is inappropriate for fireplaces so, like for all fireplaces and masonry heaters, the EPA certified test lab reports our results as an "emissions factor" in grams per kilogram of fuel. See our test results at http://www.rumford.com/testRumfordresults.html On the SLO approved list at http://slocleanair.org/programs/woodstoves-approved.asp you cite, however, I notice that several appliances called "site-built, clean-burn masonry heaters" are approved based on g/kg rather than g/hr results. We tested to the same standards in the same lab but a Rumford is a "fireplace" - not a "masonry heater" even though the rules do not define a masonry heater. Seems unfair to me that Paul will approve a masonry heater with no better test results than ours just because "he knows" without any objective criteria, that a masonry heater is clean-burning. There is also another possibility we haven't tried in SLO. Even thought a grams per hour rate standard is inappropriate and unfair for fireplaces, two of our Rumfords did pass the stove g/hr rate standard. See the grams per hour results at http://www.rumford.com/testRumfordresultsgh.html The 48" Rumford, which burns about four times as much wood in an hour as an EPA certified stove, passed which means that it is really about four times cleaner than a stove measured in terms of emissions per kilogram of fuel or heat output or any other meaningful measure. EPA certified stoves are not necessarily clean. They are just small. So, if Tim Fuhs seems open to change, let's submit our latest test results - even the ones reported in the unfair g/hr standard and see what he says. Maybe he will approve it. If not, I hope you will respectfully appeal the decision. I will be right there to help you with the appeal.
Best, PS: We are working with the masonry industry and the metal fireplace industry on an ASTM fireplace emissions standard that we hope will set a national standard that the EPA and all these local air quality regulators will have to accept. ASTM works like molasses in January, however, so it might be a few years. Rather than rough in the space for a Rumford and wait for a rule change as you propose, I would push the Rumford with gas logs issue as a back-up if the wood-burning Rumford is denied. Again see the discussion at http://www.rumford.com/emissions/SLO.html
Paul Reitz Paul, We have another customer interested in building one of our "Certified Rumford Fireplaces" in San Luis Obispo (see below). Some time has passed since we applied for approval and, in the interim, we participated in another round of testing at OMNI using the Northern Sonoma fueling protocol. The latest test results, under a cover letter by Paul Tiegs, is on our website at http://www.rumford.com/testRumfordresults.html Two Rumfords also passed the 7.5 g/hr stove "rate" standard but we never pushed that since they were closed door tests and we always thought the stove rate was unfair to masonry heaters and masonry fireplaces. But I mention it because I don't think we ever submitted those test results to you. The g/hr rate test results are on line at http://www.rumford.com/testRumfordresultsgh.html You told me once that you would reconsider approving our Rumford fireplaces if we tested to the Northern Sonoma standard. Well, we used the Northern Sonoma fueling protocol but OMNI still reports the results as an "emissions factor" (grams of particulate emissions per kilogram of fuel) which they think is more appropriate for fireplaces and less manipulatable than the stove g/hr "rate" standard. The latest efforts to develop an ASTM fireplace emissions standard will also result in a standard expressed as an "emissions factor" (g/kg) rather than as an "emissions rate" (g/hr). I notice that on your list of approved "WOOD BURNING DEVICES THAT ARE NOT EPA-CERTIFIED" at http://slocleanair.org/programs/woodstoves-approved.asp that you list a number of masonry heaters that were approved based on test results expressed as an emission factor in g/kg so I don't know how important it is to you to stick with the stove "rate". Since our Rumford fireplaces have been shown in an EPA certified test lab to meet the performance standards that San Luis Obispo has set for stoves and masonry heaters (tested, in many cases, with the same fueling protocols and in the same test labs as other approved wood-burning devices) I appeal to you to review our test results again and approve our "Certified Rumford fireplaces". I look forward to hearing from you.
Regards,
Never mind. I just found your SLO county page. http://www.rumford.com/emissions/SLO.html I don't have the capital to sue these people, but it looks like that's what needs to be done. Michael
Michael, Our email messages crossed. You'll see that I have tried again. Times are changing and maybe they will approve. If not I hope you will appeal. That doesn't take capital and you don't have to hire a lawyer or sue. You may not even have to attend the appeal. But act as though you will. Most building officials are overworked (or think they are) and don't want to go to an evening commission meeting where they might look silly. They also know that fireplace emissions are inconsequential. We've had more than one Rumford approved just because we acted as though we would appeal and the official didn't want to do the work necessary to prepare for an appeal. By the way, I will support you and be there for any appeal. I'm always polite and respectful but, if you read the SLO page on my website, you can tell they've got my blood pressure up.
Best,
Date: Thu, 12 Jan 2006
I have forwarded your notes to my architect and my wife. We will discuss how to proceed and get back to you. As a point of reference, our architect is a former Santa Cruz city councilman and Santa Cruz planning commission member, and is very savvy about dealing with bureaucrats. He has already coached us through seemingly insurmountable roadblocks in the past, and is no doubt up to this challenge.
Also, our project has been in planning and design for about 3 years now, and I have found that the single most significant thing I can do is to demonstrate to these bureaucrats that I am not going to roll over or go away. They don't generally have any rebuttal for that, and a friend of mine who works as a crew boss and inspector for the county roads department has confirmed my theory in so many words. Both he and a member of the planning department have told me off the record that they routinely turn down unusual projects just to see if you will go away. Once they know that you won't, they find a way to accommodate you. It sounds like their strategy has worked so far on Rumford fireplaces.
If you want to get a sense of our project, look at http://windhook.net.
We are near completion of the design stage for our facilities, which will include 3000 sq. ft. of studio space, 8 guest rooms and a common living space, sort of a lodge, in which we want to feature the Rumford.
Michael
To: Michael Reddell
Michael,
Thank you for that feedback. I think you are correct. You can fight City Hall and often doing so will result in a better relationship and more mutual respect.
Your architect, Mark Primack, has been a friend to us for years and has a Rumford in his own home. I didn't know he was a former councilman. Sounds like we have the right team to win an appeal.
Best,
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