Statement to BAAQMD Board

Buckley Rumford Company
1035 Monroe Street
Port Townsend, WA 98368
360 385 9974 (fax 360 385 1624)
buckley@rumford.com
December 15, 1998
To:
Carol Bradley, Clerk of the Board
BAAQMD
939 Ellis
San Francisco, CA 94109
415 771 6000 (fax 415 928 8560)

From:
Jim Buckley, Buckley Rumford Co.

Subject:
Fireplace Emissions

Carol,
I will not, unfortunately, be able to attend the BAAQMD meeting tomorrow. It's my twentieth wedding anniversary.
I did, however, meet with lawyers from the environmental law firm, Heller Ehrman White & McAuliffe Attorneys, today in Seattle toward forging a legal-leads-to-political strategy. The gist of the strategy is yet to be worked out but will probably entail jumping through all the administrative hoops - for example they said there was an "administrative appeals process" through the California Air Resources Board (CARB) and that they would make specific recommendations after checking with their California office.
I would claim that to require fireplaces to meet a non-existant EPA fireplace standard is clearly unfair and propose that the Board adopt the Washington fireplace standard (perhaps modified) until such time that they come up with a better fireplace standard. I hope the attached "statement" can be included in the record even if it's too late to be distributed to the Board members.
Best,
Jim Buckley

Buckley Rumford Company
1035 Monroe Street
Port Townsend, WA 98368
360 385 9974 (fax 360 385 1624)
buckley@rumford.com
December 15, 1998
To:
Board of Directors
Bay Area Air Quality Management District
(c/o Carol Bradley, Clerk of the Board)
939 Ellis
San Francisco, CA 94109
415 771 6000 (fax 415 928 8560)

From:
Jim Buckley, Buckley Rumford Co.

Subject:
Fireplace Emissions

Statement to the BAAQMD Board Concerning Fireplaces:
We oppose the Ad Hoc Committee on Woodsmoke's recommendations to the BAAQMD Board to require fireplaces to be "certified by EPA should EPA develop a fireplace certification program".
The EPA does not approve fireplaces and has no test procedure appropriate for fireplaces so the Committee's recommendation is to require fireplaces to meet a standard that does not exist.
Especially since the committee understands and agrees that the EPA emissions rate and test procedure for stoves is inappropriate for fireplaces, by refusing to allow the concept of "equivalency" and by not adopting an appropriate fireplace standard for the sake of expediency, the Committee's recommendation is fundamentally unfair.
We propose that the Board adopt the Washington Fireplace Standard (perhaps modified as recommended by everyone who testified before the Committee) as the best and most appropriate fireplace standard available until such time as a better fireplace standard is developed.
Although time has not permitted formal approval, I think I speak on behalf of the Masonry Fireplace and Chimney Association (MFCA), the Clay Flue Lining Institute (CFLI), the Brick Industry Association (BIA), the Masonry Heater Association (MHA) and the Western States Clay Products Association (WSCPA) on this matter.

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