ACAT et al. Comments on ADEC wood smoke regulations (January 24, 2014) Exhibits
SUGGESTED COMMENTS ON ADEC’s PROPOSED WOOD-FIRED HEATING DEVICE REGULATIONS
Comments due: Friday, January 24, 2014 @ 5 PM
Email comments to: [email protected]
Dear Mr. Sloane:
I am writing to encourage the Alaska Department of Environmental Conservation (ADEC) to adopt meaningful new air quality regulations to address fine particle (PM-2.5) pollution in the Fairbanks North Star Borough.
Improved regulations are necessary because wintertime PM-2.5 pollution in Fairbanks is a major health problem that urgently needs to be addressed. Scientific studies have linked PM-2.5 pollution to numerous health problems ranging from asthma to premature death in people with heart or lung disease. PM-2.5 is particularly dangerous to the children in our community. Recently, a new study demonstrated that early childhood exposure to PM-2.5 diminishes the development of a child’s lungs and immune system.
I support the common sense measures proposed by ADEC: outdoor open burning should be restricted in wintertime; only the fuel(s) for which a given heating device was designed should be burned; and new stoves sold or installed in Fairbanks should meet the proposed lower emissions standard. Clean-burning heating devices are readily available in Fairbanks and they are no more expensive than the dirty models. Efficient devices actually save their owners money over time with lower fuel use.
Unfortunately, the measures proposed by ADEC do not go far enough to provide relief from dangerous air quality. More can and should be done. This is an urgent public health concern. For example, ADEC should adopt a requirement that old, dirty stoves must be replaced with new, clean-burning models upon the resale of a home. The State of Oregon has instituted this effective requirement, as have communities in California and Nevada.
ADEC also should revise its vague and flawed curtailment provision. The provision should require that episodic burn bans will be imposed to prevent PM-2.5 pollution levels that exceed the national ambient air quality standard, not imposed after a violation occurs. The provision also must include a clear exemption for burning that is an owner’s sole source of heat or in financial hardship situations.
In addition to improving ADEC’s air regulations, I encourage ADEC and local authorities to continue the voluntary stove change out program and public education efforts. I also recommend a subsidy program for fuel oil.
Written comments should be submitted to Scott Sloane, Division of Air Quality, DEC, 410 Willoughby Avenue, Suite 303, P.O. Box 111800, Juneau, Alaska 99811-1800; or by email to [email protected]; or by facsimile at (907) 465-5129. Comments may also be submitted through the Air Quality Division’s electronic comment submission web page at: https://dec.alaska.gov/