We in the masonry industry who design and build masonry fireplaces, especially those of us who have developed clean-burning and efficient fireplaces, oppose the proposed ordinance for one simple reason: It would require fireplaces to meet a non existent standard and in so doing would effectively ban fireplaces, whether they are clean-burning or not, without due process and without any apparent improvement in air quality.

The Model Ordinance would allow only "EPA approved fireplaces" but the EPA specifically does not approve fireplaces and does not have an appropriate testing protocol for fireplaces. Fireplaces are not the same as stoves in the way they are built, used or transmit heat. Even the drafters of the BAAQMD Model Ordinance admit the inappropriateness of applying the narrowly focused EPA stove standard to fireplaces yet chose not to allow or specify appropriate testing methods that would result in an "equivalent" fireplace standard.

There are fireplace standards and testing procedures which are thought to be "equivalent" to the EPA stove standard for emissions. We think the Washington State Fireplace Standard, while not perfect, is the best of these.

We would support the proposed ordinance if it were amended to allow fireplaces that have been tested in an EPA certified lab and shown to meet the Washington Fireplace Emissions Standard or some other standard considered to be "equivalent" to the EPA woodstove standard. We too are concerned about the quality of the air we share but we'd like to be treated equally under the law and on the same basis as other wood-burning appliances.

Jim Buckley
1035 Monroe Street
Port Townsend, WA 98368
360 385 9974
buckley@rumford.com