Comment Log Display

Comments on draft Cap and Trade Auction Proceeds Investment Plan 
 
350 Bay Area is a 7,500 member climate activist organization
working for deep reductions in carbon pollution in the nine San
Francisco Bay Area counties and beyond.  We applaud the draft Cap
and Trade Auction Proceeds Investment Plan for addressing wood
smoke pollution, but strongly suggest that GHG Reduction funds
should only be used to replace wood-burning stoves and fireplaces 
with clean alternatives that are efficient and zero-emission on
site, such as electric heat pumps.  Programs should not be funded
if they replace wood-burning devices by other carbon-producing or
greenhouse gas emitting devices.

Page 15 of the draft investment plan describes the target of
reducing residential wood smoke from home heating.   We agree with
the importance of this target: According to the Bay Area Air
Quality Management District’s data, wood smoke from fireplaces and
wood stoves is the major source of particulate matter pollution in
the Bay Area in the winter months, causing significant public
health impacts, especially to children, the elderly, and the one in
seven residents who suffer from respiratory illnesses, such as
asthma and bronchitis. These impacts are the most apparent to
disadvantaged communities as they live in areas without natural gas
service and in areas where generalized wood smoke pollution is
augmented by localized industrial and transportation emissions,
increasing the likelihood that residents of these communities will
develop a respiratory illness.

The current investment plan suggests (p  15) “there are climate and
air quality benefits to be gained by aiding the replacement of
inefficient fireplaces and wood stoves with natural gas heating (if
available) or the most efficient lowest polluting wood stoves."
 We urge that the investment plan require that wood-burning stoves
and fireplaces are replaced with clean alternatives that are
efficient and zero-emission on site, such as electric heat pumps.

While EPA-certified wood-burning devices generate lower particulate
emissions than non-certified devices, laboratory performance of
EPA-certified devices do not mirror real-world performance because
testing procedures do not mirror in-home conditions. Moreover,
EPA-certified devices still emit significant levels of particulate
pollution, consume large amounts of wood fuel, and have not been
shown to effectively reduce emissions of toxics, such as dioxins
and furans.

Using EPA-certified wood-burning devices as the replacement would
also run counter to efforts, such as the Marin Carbon Project, to
accelerate carbon sequestration, as burning wood can actually
result in higher carbon emissions than burning coal as it takes
much longer to regrow a large tree than to burn it.

Natural gas may burn cleaner than wood, but it still emits a
significant amount of carbon dioxide and is a major contributor to
climate change. As a fossil fuel, natural gas has significant
climate-disruption impacts due to the methane and carbon dioxide
that is emitted during its extraction, transport, and burning.