Puget Sound Burn Ban Program

1. Puget SoundBurn BanProgram Jim Nolan – Mike Gilroy For the SHB 2261 Wood Smoke Work Group August 1, 2007

2. Where is Our Wood Smoke Coming From? 1.2 Million residences in our jurisdiction Over half have fireplaces or woodstoves We think there are over 350,000 fireplaces We may have over 250,000 wood stoves and fireplace inserts We are conducting a survey to determine the split between “certified” and “uncertified” devices What’s a “certified” stove? Oregon developed certification requirements in 1986 EPA developed more stringent standards in 1988 Washington developed more stringent requirements in 1991

3. Burn Ban Principles and Objectives Conducted in accordance with Washington State Law Based in existing EPA standards and air quality index Enforcement uses statutory tools In a Stage 1 ban, certified stove users have the right to use wood burning devices in a lawful manner Issue burn bans that will likely result in reduced PM 2.5 emissions Reduce health impacts and smoke complaints Public must have adequate notice Use multiple avenues for notice Why are we calling a ban What actions are required Credibility with public and media is important

4. Burn Ban Meteorological Considerations Meteorological conditions are the single greatest factor controlling PM 2.5 daily trends Detailed and reliable air quality and meteorological monitoring network is essential Careful consideration of mesoscale meteorological predictions (MM5 model) Recognize need to forecast meteorological conditionsandpublic behavior

5. Typical Stagnation Events 72-96 hours in length 3 to 4 times a season in Puget Sound No two stagnations are the same Depth and intensity of inversion varies Impact of other meteorological parameters Fog Above Normal Temperatures Off shore flow/ gap winds Stable conditions 12 to 72 hours not considered stagnations

6. Operational Protocol For Stage 1 Any monitor is above 35 ug/m3 and other monitors show an upward trend Wood smoke is likely to be a significant contributor to the PM levels Meteorological observations and forecast models indicate that stagnant conditions with a persistent temperature inversion are expected, and The dispersion is not expected to improve during the next 48 hours.

7. Operational Protocol for Stage 2 A Stage 1 burn ban has been in place for 24 hours Any monitor is at least 60 ug/m3 and other monitors show an upward trend Wood smoke is likely to be a significant contributor to the PM levels Meteorological observations and forecast models indicate that stagnant conditions with a persistent temperature inversion are expected, and The dispersion is not expected to improve during the next 48 hours.

8. Operational Protocol For Termination The dispersion will improve and cause the levels to be below 35 ug/m3 within the next 6 to 12 hours and concentrations will remain below the trigger for the next 48-72 hours Burn bans are not be called off when the lack of dispersion is expected to continue even if the levels are below 35 ug/m3.

9. Burn Ban Events and Days- 1997-2007 • Since 1997 the Agency has called 14 Stage One burn bans covering at total of 73 days • Shortest impacted a3 day period • Longest impacted a 10day period • Three years – 1998, 2004 and 2006 had0 Burn Bans • No Stage Two ban has been issued

10. Burn Ban Events - New PM2.5 Trigger • Since 2005 the Agency has called 4 Stage One burn bans covering at total of 26 days • Shortest impacted a 4 day period • Longest impacted a 10day period • 2006 had0 Burn Bans • No Stage Two ban has been issued

11. Unusual 2006 Event

12. Burn Ban Enforcement • Two-stage burn ban program • Stage 1 – No fireplaces or uncertified stoves • Stage 2 – No wood burning • Exempt if wood is the only source of adequate heat • Enforced using opacity standard • 6 teams of 2 inspectors each patrol areas known for wood smoke problems • Issue tickets to property owner for opacity violation • Offer to resolve by upgrading or removal of uncertified wood stove • If excess opacity is from an EPA certified stove, resident may receive remedial instruction from Hearth Products dealer • If neither option chosen, the penalty is $1,000

13. Common Burn Ban Violation

14. Experience and Lessons Learned • ~ 20 years experience in calling Burn Bans in accordance with State law • Meteorological changes often reduce PM 2.5 levels more effectively in the short term rather than calling a burn ban • Need to have both an operational protocol for calling it on/off and use professional judgment in evaluating data • Public is aware of the program and we get feedback during and after from multiple customers • Calling Burn Bans at levels consistent with air stagnation patterns is important for public credibility

15. Experience and Lessons Learned • Current two stage Burn Ban effectiveness is limited because certified devices are allowed during Stage 1 • We call it a burn ban, but we are not really banning burning • Certified devices can still be operated improperly • We cannot know if the device is certified unless we enter the home • We observe reductions in PM 2.5 concentrations during a burn ban but they are not consistent or lasting • Not effective control measure for remaining below PM2.5 NAAQS

16. Future Considerations • We are currently analyzing our monitoring network data to support potential refinements to RCW • Past and current program are based on meteorological episodes. • Real stagnations currently always result in concentrations over the NAAQS in our region • Seasonal increases in “base” PM 2.5 levels may create periods of inconsistency due to changing weather pattern • Selecting a lower concentration level for trigger diminishes the importance of meteorology and decreases our confidence that wood smoke is the main contributor. • With lower NAAQS the Burn Ban as a strategy has probably outlived it’s effectiveness