Jeff McNear on BAAQMD Staff Report

November 13, 1998
To: Chairperson Johnson And Members Of The BAAQMD Ad Hoc Committee On Woodsmoke
From: Jeff McNear, McNear Brick & Block
Re: Fireplace "Equivalence" In The Model Ordinance
After attending the November 9 meeting of the Ad Hoc Committee On Woodsmoke, I would like to reiterate my strong support of the proposal that you include some form of “equivalence” for fireplaces in the proposed Model Woodburning Appliance Ordinance. McNear Brick & Block has manufactured brick in San Rafael since 1865, and we have supplied the brick for a good portion of the million and a half fireplaces in the greater Bay Area. More recently, we have promoted and distributed Rumford fireplaces designed by the Buckley Rumford Co. Because fireplaces are an important part of our business, we have long paid attention to their role in the lives of the Bay Area's inhabitants.
Research conducted by our company and the Home Builders Association has shown the following to be true:
1. Fireplaces are very important to home buyers; many rate them right after indoor plumbing on the list of features they could not do without.
2. 83% of home owners use their fireplaces fewer than 10 times annually, generally during family or social gatherings, and not as primary heat sources.
3. EPA approved woodstoves and inserts are not equivalent to open fireplaces in functional or esthetic ways; they are not what people mean when they say they want a fireplace.

The Executive Summary presented by Bill Guy at the November 9 meeting was generally an excellent study of the controversies surrounding air pollution standards for woodburning fireplaces, but I must disagree with some of Mr. Guy's findings and conclusions.

Mr. Guy finds that "Equivalence" between the standards for fireplaces and wood stoves is not possible. But in his Executive Summary, he states that the Washington State Test Protocol is adequate for testing emission factors. His report also states that an emission rate limit, as used in the EPA woodstove standard, is unusual in air pollution control, and an emission factor limit, as is used in the Washington State standard, is the normal way to control air pollution. Given the basic operational differences between woodstoves and fireplaces, one burning slowly and steadily, and the other burning cyclically through periods of intense combustion followed by embers, it seems entirely appropriate that an emission factor standard for fireplaces be considered equivalent to the emission rate standard used by the EPA for woodstoves.

Mr. Guy seems resentful that the Washington State standard was derived from the unorthodox method of equivalency, rather than the usual technology driven development. But what does it matter how a standard is developed, so long as it serves its purpose? The EPA standard for woodstoves is itself unorthodox, according to Mr. Guy.

Mr. Guy appears to reach contradictory conclusions regarding the efficacy of the Washington State test protocol. One of his findings is that the test is unable to distinguish between cleaner and dirtier fireplace technologies, while a later finding is that the test appears to be adequate. Paul Tiegs of Omni Environmental Services Inc. states that the results of the 20 Washington State protocol tests done so far show a range from barely passing to less than half the 7.3 g/kg standard, indicating that the test can indeed discern between cleaner and dirtier fireplaces. Additionally, while there does not yet exist a body of corroborative tests to support the results obtained from Omni Labs, it is also true that there is no evidence that suggests their tests are unreliable.

Anecdotal evidence suggests that the Washington State standard will have a dramatic effect on the air pollution produced there by new fireplaces. Mr. Tiegs says that, as happened in the woodstove industry, only the very cleanest devices are being submitted for the expensive testing. The older, dirtier devices are being abandoned.

Mr. Guy has apparently been given inaccurate information concerning the cost of a typical masonry fireplace. While they are not the cheapest alternative, they are commonly built into mid-range homes. A typical Rumford fireplace should cost in the neighborhood of $5000 installed. The stated seismic concerns are both irrelevant and exaggerated.

Mr. Guy finds that there are no technologies available at a reasonable cost that produce significantly cleaner fireplaces. It is not clear what his definition of a significant reduction is, but the results produced so far by Omni Labs show that a significant reduction of the order of 50% is possible. The Rumford fireplace is just one example of a significantly cleaner fireplace available at a reasonable cost.

The controversy surrounding the Washington State protocol sampling period for PM emissions is irrelevant to a standard based on an emmission factor, and as Mr. Guy states, emission factor limits are much more normal in air pollution control.
The Executive Summary also fails to note simple yet effective devices that can dramatically reduce fireplace PM emissions, such as gas log starters, and the forced combustion air/grate system offered by Andiron Technologies, Inc.. These solutions, either alone or combined, will likely meet anybody's definition of significant reduction.
Fireplaces are an important cultural and esthetic part of our homes, but they should not be allowed to be gross polluters. By drafting a model woodsmoke ordinance that includes a fireplace equivalency using an emission factor standard, the BAAQMD would provide local jurisdictions with an ordinance that would both reduce pollution from fireplaces, as well as encourage the industry to develop even cleaner fireplace technologies.

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