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State of Washington SHB 2261 Wood Smoke Work Group

Meeting #3 Summary

DATE: August 1, 2007

LOCATION: Seoul Room, SEATAC Airport, WA.

Members Present


Paige Boulé (for Bob Saunders)

Air Quality Program

Department of Ecology

Amy Fowler

Puget Sound Clean Air Agency

Regional Air Agencies

Bill Dameworth

Spokane Regional Clean Air Agency

Regional Air Agencies

John Kurtz

Yakima Regional Clean Air Agency

Regional Air Agencies

Judy Bardin

Washington State Dept. of Health

State Dept. of Health

Russ Bradford

Lucky Brush Chimney Sweep

Chimney Sweeps

Gary Smith

Independent Business Association

Related Industries

Ginny Eberhardt

Community Council of Tacoma


Mike Duval


Related Industries

Dave De Bruyn

American Lung Association of Washington

Non-Governmental Organization

Sam Pace

Housing Specialist

Seattle-King County Association of Realtors

Gina Bonifacino

Air Quality Division

Environmental Protection Agency

David Swink

Spokane Regional Health District

Local Health Dept.

John Crouch

Hearth, Patio, and Barbecue Association

Related Industries

Bill Evans

Tacoma City Council

Local Elected Official

Jerry Fisk

Manufacturer Representative


Members Absent


Introductions, Announcements__________________________________________________
The 3rd Meeting of the Wood Smoke Work Group was convened at 10 a.m. on Wednesday, August 1st, 2007. Bonnie Snedeker, the group facilitator, discussed the work plan, and recommended that the group not narrow the options discussed too soon in the process, suggesting that getting and keeping options out on the table for consideration is more important than narrowing the options down for now. Sam Pace suggested that the initial recommendations of the group should foreshadow the final recommendations for the 2009 budget. Gary Smith thought that 2008 would be “the year” for the wood smoke issue in the legislature, and that the legislature does not like to bring up the same issue two or three sessions in a row.
Julie Oliver of Ecology gave a short presentation about the timelines and consequences of National Ambient Air Quality Standards (NAAQS) Attainment/Non-Attainment issues.
Jim Nolan, Compliance Director of the Puget Sound Clean Air Agency (PSCAA), presented the group with information on how PSCAA administers its burn ban enforcement program as a part of curtailment events. During burn bans, PSCAA employs up to six two-person teams driving through neighborhoods looking for chimneys with emissions greater than 20% opacity. These teams issue tickets to property owners for violations. The tickets can be resolved by turning in or upgrading uncertified wood stoves, receiving remedial instruction on clean burning practices for those with certified wood stoves, or paying a $1000 fine for those who wish to do neither. Mr. Nolan suggests that, in PSCAA’s view, real meteorological stagnations always result in ambient air concentrations above the NAAQS in the Puget Sound area, and that with the lower NAAQS levels currently in place, the “Burn Ban” may have outlived its effectiveness as a strategy.
The group undertook to develop a list of possible Enforcement and Curtailment strategies from which they could then choose the most effective ones. The synthesized list is included in Attachment A.
John Crouch gave a presentation on the history and background of replacing uncertified woodstoves with cleaner home heating options. Some of the key concepts in performing changeouts are:

  • Joint industry/government partnership.

  • Capture and destroy the old stove.

  • Replace it with cleaner heat.

  • Offer best incentives possible.

  • Create a broad coalition of partners.

  • Different partners may prefer different options for replacement, but the key concept is that the old woodstove must go.

  • Use program to educate all wood burners.

Mr. Crouch discussed the changeout efforts which have been conducted recently in Libby, Montana. Libby serves as an example of what can be done with adequate money and the “backstop” of a date beyond which the use of uncertified woodstoves will be illegal.

In Libby, a town with just over 1000 uncertified woodstoves, the government and thearth industry decided to try a “whole-town” changeout. Over three years, and with about $1million of government grant money, $1million of industry contributions, and $1million of local input, over 1000 woodstoves were successfully traded out. The program was concluded in December of 2006, and enforcement is expected to be an important aspect this winter.
The group then developed a list of possible woodstove changeout options. This list will be culled down in subsequent meetings to form the recommendations of the group. The synthesized list is included in Attachment B.
Finally, the group decided to lengthen the next meeting, changing the times to a 9:30 AM start, and concluding at 3:00PM. This meeting with take place at Ecology’s Northwest Regional Office in Bellevue.
The meeting was concluded at 4:20 p.m.
Attachment A


Possible Recommendations
Two-Stage Curtailment:

  • Maintain two-stage curtailments – at least for the near-term – to continue to provide an incentive for changing to certified devices.

  • Solidify new (emission) trigger points at a lower level to conform to new standards. (e.g. 13.4 micrograms per cubic meter for 24-hour average = stage 1 curtailment; 25 = stage 2 curtailment.)

  • (Continue to) base curtailment decisions on both meteorology and emissions data or allow stage one curtailments based on meteorological conditions alone?

  • Explore ways to maximize flexibility for local areas on curtailment protocol and decision-making criteria (based on local conditions and variations) or establish consistent statewide protocols for calling and implementing curtailments?

  • Promote better research and analysis on which to base local flexibility.

  • Focus curtailment strategies most on targeted non-attainment or excedance areas or keep a whole-state focus/don’t fragment curtailment strategies.

Emissions Monitoring:

  • Make sure that adequate/effective monitoring is in place throughout the state.

  • Be sure to cover areas, not currently monitored, that may be on the border of non-compliance.

  • Increase dollars and tools for upgrading and aligning monitoring capabilities across the State.

Education & Outreach:

  • Include strong public education and outreach as a critical element making curtailment strategies work.

  • Use public-private partnerships to maximize education/outreach linked to curtailment.

  • Find ways to get the word out to small towns – educate broadly.

  • Focus on “prevention”/responsible use, because ability to enforce curtailment will always be limited.

  • Emphasize health issues/impacts. (Call for “health emergencies to curtail wood burning”, rather than “burn bans”.) Help people understand who is at risk or most affected and the link between people’s health and woodstove use.

  • Promote continuous education on proper clean-burning practices.


  • Recognize that enforcement (and the chance of being caught/sanctioned) is part of the message that makes curtailment strategies work.

  • Make sure that what we recommend on curtailment is enforceable.

  • Come up with some ways to strengthen/reinforce enforcement procedures.

  • Allow for local flexibility in enforcement strategies.

  • Include night time enforcement for opacity.

Tribal Coordination:

  • Ask the state to work with EPA/ BIA to mandate cooperation between tribal authorities and local agencies on curtailment and emissions compliance efforts.

Longer-term Strategies:

  • Recognize that curtailments (both two-stage and one-stage) are episodic in nature, difficult to enforce, will not work equally well in all areas, and alone will not be enough to alter wood burning loads and emission excedences. Look for permanent, enforceable and effective controls.

  • Focus on ways to remove non-certified stoves, reduce open fireplaces, and ensure destruction of uncertified stoves at removal.

  • Increase trade-outs to certified burning devices and non-wood burning options.

  • Exercise control/change-out at point of property sale or transfer of property.

  • New Construction: create incentives (like density bonuses?) for installing non-wood burning appliances.

  • Consider setting a “drop-dead” date after which no uncertified devices will be allowed – at least in local areas of non-compliance.

  • Create a state law to require registration/listing of sole source wood burners.

  • Be careful of laws that may bind us is ways we may want to avoid.

Attachment B


Possible Recommendations
Expand resources for change-out programs across the state:

  • Give wood smoke issues and reduction strategies top priority in allocating funding to clean air agencies.

  • Identify all potential funding sources and partners for change-out programs.

  • Find ways to effectively estimate and address staffing and other administrative needs for continuing and expanding support of change-out programs.

  • Ensure continuity of support over a multi-year program effort.

  • Identify realistic target goals for change-outs, estimate soft/hard costs and then seek funding support.

  • Increase the state fee for purchase of solid wood/pellet burning devices. (reopen provision for automatic increases) -- enabling more dollars to go out (through automatic appropriation) to local agencies and ecology offices for continuous support of local wood burning strategies.

Target change-out efforts:

  • Explore/support ways to effectively target change-out programs geographically and by potential impact (on reducing emissions).

  • Maintain environmental justice; ensure that we effectively address the needs and barriers of low-income, disabled and elderly wood burners.

  • Allocate dollars to clean air agencies for PM 2.5 reduction strategies based on “need” (e.g. extent of emissions/burning problem; income levels of population, etc.)

  • Direct strategies toward both home owners and rental housing.

Use a mix of incentives and sanctions:

  • Consider a permanent ban of uncertified devices – at least in non-attainment areas and possibly statewide. Time the ban to go into effect in the future. Time it to encourage change-outs and link it with change-out program support.

  • People could be exempted from the ban by waiver for special needs (but the waiver would not outlast their tenancy on the property.)

  • Continue to use curtailment (2-stage) to encourage change-outs – at least in the short-term.

  • Base financial incentives to change-out participants on income-level, time frame (i.e. sooner vs. later) & type of change-out (how much impact their change-out option will have on reducing emissions.)

  • Use low-interest loans to encourage/support change-outs. State could establish a revolving loan fund.

  • Tie low-interest loans to low-income home-buyers through Washington State Housing Finance Commission.

  • Tie incentives to geographic area needs/circumstances.

  • Offer tax deductions for wood stove change-outs.

  • Recognize and promote other non-cash incentives for changing out, such as: heating efficiency, better in-door air quality/healthier living environment, cleaner, easier, etc.

Improve access to/use of non-wood burning heating options:

  • Improve access to natural gas.

  • Consider renewable portfolio standards for utilities. Intersect with all-electric homes. Offer short-term credit in RPS.

  • Use fuel subsidies to effectively target and reach low-income burners who want to change-out to non-wood options.

  • Ask our congressional delegation to push for inclusion of non-certified upgrades in weatherization programs.

Increase & coordinate education efforts:

  • Provide continuous education on how to burn clean.

  • Use partnerships to promote understanding and support ongoing education campaigns – include industry, government and real estate.

  • Fit education and marketing strategies to specific groups and target populations.

  • Help people understand trade-offs (health, in-door air quality, long-term costs, convenience, heating efficiency, etc.) involved in wood burning/heating choices.

Improve information and tracking:

  • Stimulate the development of better information and better use of existing inventory data on which to base local area planning and program design.

  • Explore ways to inventory and track wood burning devices by property.

  • Consider ways we “capture” and track information on people who change-out wood burning devices without participating in a program or getting an incentive. (Could we give industry a payment for certifying and tracking these trade-outs – including fireplace inserts?)

Keep it simple/ensure flexibility:

  • Don’t have the legislature “designing” the change-out program.

  • Keep it simple and clear at the state level.

  • Promote flexibility to meet local needs and conditions.

Focus on Results:

  • Destruction of old stoves and uncertified devices is fundamental to the program.

Coordinate with other wood burning strategies:

  • Change-out programs are an important tool, but they are one element of a multi-faceted strategy for reducing PM 2.5 emissions, achieving compliance and alleviating health risks. They should be used in coordination with other tools.

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