Comment Log Display

Wood to wood stove conversions should not be included in
California’s Short-Lived Climate Pollutant Reduction Strategy. 

The reductions in black carbon emissions that are assumed to come
from newer wood stoves are based on faulty assumptions that are not
borne out by research. As stated in the Revised Proposed
Short-Lived Climate Pollutant Reduction Strategy, “While certified
wood-burning devices reduce fine particulate emissions,
certification values may not correlate well with in-home
performance of wood heaters, and emission reductions are not as
large as for non-wood technologies” (p.54). In fact, research has
shown that real-world emissions of newer wood stoves can be
approximately 15 to 16 times higher than their certification values
suggest. In addition, certification tests, which bear little
resemblance to actual in-home usage, also ignore the emissions
released during the start-up period, which are substantial.
[1,2,3]. 

If wood to wood stove changeouts worked, Libby, Montana would have
decent air quality. But it doesn’t. Even after replacing almost
every wood stove in the community with a new EPA-certified one,
Libby is still not in attainment of either the EPA’s PM2.5 or PM10
standards[4] and approximately 81% of the area’s particulate
pollution still comes from residential wood burning. Post-changeout
levels of elemental carbon emissions from residential wood burning
have remained the same.[5] 

Higher combustion temperatures, which new wood stoves have, may
actually raise the ratio of light-absorbing carbon, affecting
climate balance. For example, one study found the relative
fractions of black carbon in PM emissions rose by as much as
12-fold higher wih an “eco-labeled” stove.[6] The premise that
newer stoves reduce black carbon emissions is simply incorrect.

It has also been shown that the brown carbon in wood smoke is
highly absorbing in the near-UV spectrum, with further implications
for our climate. For example, a California study found that the
light-absorbing properties of organic carbon “in atmospheres
burdened with residential wood smoke” are significant.[7]

The Revised Proposed Short-Lived Climate Pollutant Reduction
Strategy states, “Reducing annual wood consumption from 1.5 to 1
cord per year would save the average resident $145 per year.
Approximately 379,000 wood to wood conversions would result in
savings of approximately 44 million dollars per year to consumers
receiving incentives to replace their inefficient wood stove.” This
assumes that the efficiency claims for newer stoves are actually
valid, which is questionable, and does not take into account that,
as with emissions, efficiency can vary considerably in real-world
usage, depending upon the kind of wood used and the technique used
by the consumer.[8,9]

As for the assumed financial savings, this does not take into
account the well-documented increases in medical costs, both to
individuals and society, that result from residential wood burning,
which add millions of dollars in expenses due to excess illnesses
and premature deaths. For example, a 2001–2003 study by the San
Joaquin Valley Air Pollution Control District estimated that
residential wood burning, even after implementation of some limited
restrictions on wood burning, resulted in an added $11 million in
increased health costs in the Fresno/Clovis area alone, and
expenses related to excess deaths cost $367.5 million.[10] 

Even with newer stoves, the added expenses from excess illnesses,
loss of productivity and premature death will still far exceed any
potential savings in buying wood, and are borne by the entire
community and state. (For more health costs examples, see source
below.)[11]

In the U.S., residential wood burning also accounts for over 45% of
of methane emissions from stationary combustion. There is no reason
to assume that newer stoves will emit less methane.[12,13]

On page 50 of the Revised Proposed Short-Lived Climate Pollutant
Reduction Strategy it is stated that “A number of local air
districts have residential wood combustion rules, and are working
to make further progress in this category to meet air quality
standards and protect public health.” Unfortunately, this is not
true of some of the air districts that are most seriously affected
by wood smoke pollution, including the district I reside in, the
North Coast Unified Air Quality Management District. When the
district’s PM monitor in Willow Creek recently was recording high
levels of wood smoke from neighboring wood stoves, the NCUAQMD
simply dealt with this issue by deciding to move the monitor to a
neighborhood with fewer wood stoves.[14] They steadfastly refuse to
implement any curtailment programs such as Spare the Air, even
during inversion conditions when levels of wood smoke can become
suffocating in some district neighborhoods. They actively encourage
wood burning. A considerable portion of the District’s annual
budget also comes from selling open burning permits, so they have
little incentive to limit open burning.[15] Last year, 300 out of
366 days were permissive open burn days, including the summer
months when burning was banned due to fire danger.[16] If the state
is to tackle SLCPs, it must also tackle open burning, which is an
environmental and health catastrophe for those who live nearby, and
a climate concern for all of us. 

For the sake of our climate and public health, it is clear that
wood to wood stove exchanges are not an appropriate solution. Only
a move to cleaner, non-wood combustion technologies should be
promoted and encouraged. And all air districts in California,
including rural ones, must begin to take the problem of residential
wood burning seriously. 


1. Fisher, L., Houck, J., Tiegs, P., McGaughey, J. (2000). Long -
Term Performance of EPA-Certified Phase 2 Woodstoves, Klamath Falls
and Portland, Oregon. U.S. Environmental Protection Agency.

2. Scott, A.J. , (2005). Real-Life Emissions from Residential Wood
Burning Appliances in New Zealand. Ministry for the Environment
Sustainable Management Fund.

3. Houck, J.E., Pitzman, L.Y., Tiegs, P. (2008). Emission Factors
for New Certified Residential Wood Heaters. Presented at the 17th
International Emission Inventory Conference, U.S. Environmental
Protection Agency.

4. Montana Department of Environmental Quality. Montana Air Quality
Nonattainment Status.

5. Ward, T. , Palmer, C. , Bergauff, M. , Jayanty, R. , & Noonan,
C. (2011). Organic/Elemental Carbon and Woodsmoke Tracer
Concentrations Following a Community Wide Woodstove Changeout
Program. Atmospheric Environment, 45(31), 5554–5560.

6. Alves, C., Gonçalves, C., Fernandes, A.P., Tarelho, L., Pio, C.
(2011). Fireplace and Woodstove Fine Particle Emissions from
Combustion of Western Mediterranean Wood Types. Atmospheric
Research, 101(3), 692–700. 

7. Kirchstetter, T.W. and Thatcher, T.L. (2012). Contribution of
Organic Carbon to Wood Smoke Particulate Matter Absorption of Solar
Radiation. Atmospheric Chemistry and Physics, 12, 6067–6072.

8. Houck, J.E., Pitzman, L.Y., Tiegs, P. (2008). Emission Factors
for New Certified Residential Wood Heaters. Presented at the 17th
International Emission Inventory Conference, U.S. Environmental
Protection Agency.

9. Houck, J.E. (2009). Pick a Number, Any Number: No one really
knows how efficient many cordwood and pellet heater are. Hearth &
Home, 148.

10. Lighthall, D., Nunes, D., Tyner, T. (2009). Environmental
Health Evaluation of Rule 4901: Domestic Wood Burning, A Case Study
of the Fresno/Clovis and Bakersfield Metropolitan Areas. The San
Joaquin Valley Air Pollution Control District.

11. Real Costs of Wood Burning. Retrieved from
http://woodsmokepollution.org/real-costs-of-wood-burning.html.

12. Ahlers, C.D. (2016). Wood Burning, Biomass, Air Pollution, and
Climate Change. Environmental Law, Vol 46; Vermont Law School
Research Paper No. 4–16.

13. Wood Burning and Our Climate. Retrieved from
http://woodsmokepollution.org/climate.html.

14. North Coast Unified Air Quality Management District. Regular
Meeting of the Governing Board of Directors October 13, 2016 Agenda
packet, p. 97. Retrieved from
http://www.ncuaqmd.org/files/Governing%20Board/2016/October%202016%20NCUAQMD%20Board%20Packet.pdf.

15. North Coast Unified Air Quality Management District Adopted FY
2016–2017 Budget. Retrieved from
http://www.ncuaqmd.org/files/Public%20Notice/Budget/16-17%20Adopted%20Budget.pdf

16. North Coast Unified Air Quality Management District. Regular
Meeting of the Governing Board of Directors January 12, 2017 Agenda
packet, p. 15. Retrieved from
http://ncuaqmd.org/files/Governing%20Board/2017/January%202017%20Board%20Packet%20.pdf.