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


George Erdman
Northern Sonoma County Air Pollution Control District
150 Matheson St.
Healdsburg, CA 95448
707 433 5911 (fax 707 433 4823)


While I am pleased with your hard work and good efforts to develop a fireplace emissions standard, I have a general complaint to register with regard to your fuel loading rules. It seems to me that in the fueling protocol rules the Northern Sonoma fireplace standard goes out of the way to put Rumford fireplaces at a disadvantage in two ways - by overly restricting the amount of fuel and by requiring that the fuel be laid horizontally.

By any meaningful measure the 36" wide 36" tall Rumford is a larger fireplace by about one third than the 36" wide 27" tall standard fireplace we are also testing yet the fuel load permitted in the Rumford, determined by inner hearth area, can only be a little more than half of that permitted in the smaller standard fireplace.

For a couple of hundred years the design guides, currently reflected in all the national building codes, determine the throat and flue cross-sectional areas based on the cross-sectional area of the fireplace opening. The cross-sectional area of the opening (or perhaps the firebox volume) - rather than hearth size - should be the basis of the fuel load.

Secondly, the placement or orientation of the fuel is restricted in the way most beneficial to a Rumford. The Rumford is a tall, shallow, vertical firebox. Firewood is most advantageously placed in the fireplace vertically. Even though it can be placed horizontally, placing the logs vertically leaning against the straight and narrow fireback results in a cleaner, more efficient and structurally more stable fire. It's pretty intuitive based on the shape of the firebox and, in the smaller Rumfords, it's virtually impossible to get 20" long logs in any other way. Most of our customers do build the "tipi" fires we recommend and you can see the increasing number of tipi fires shown in magazines these days.

Yet, Paul Tiegs quotes you as saying "I don't want any teepee fires or other fueling tricks" which seems to me to be an unnecessarily prejudicial remark which makes me think there is little point in asking you for an exception - your remark is clearly aimed at me.

I think the Rumford will do OK in the emission tests only because the rules do permit spitting the wood into smaller pieces. We'll have a fast but small kindling fire in an effort to produce an optimum sized fire for the size of the Rumford - a fire similar in size and intensity to that in the standard fireplace. But I wish to record my objection to rules that seem to have been intentionally selected to disadvantage a Rumford fireplace.


Jim Buckley
copy: Paul Tiegs

Reply from Barbara Lee

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