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Comment 93 for Proposed Short-Lived Climate Pollutant Strategy (slcp2016) - Non-Reg.

First NameE.
Last NameGolla
Email Addressegolla@zebracrossing.org
Affiliation
SubjectClimate Reduction Strategy Recommendations
Comment
Over twenty years ago, the North Coast Unified Air Quality
Management District in Humboldt County published a draft report on
particulate emissions in the district. It was reported that half of
Eureka’s wintertime particulate matter was from residential wood
burning. For several years, the NCUAQMD has been running a wood
stove exchange program,  exchanging older stoves for newer ones. 

Over the course of twenty years, the air has only become worse,
depending upon the neighborhood one happens to live in. Some areas
have pollution levels that literally must rival that of Beijing.
The air is visible and even being outside for minutes is enough to
cause an asthma attack. It is always a physical shock to drive up
US 101 in the winter from the Bay Area. Almost as soon as one
crosses the county line, the car fills with woodsmoke so noxious it
is difficult to breathe, and it can remain that way as one travels
the length of the county. Our local air management district’s
unwillingness to do anything about this situation for over twenty
years is unconscionable. 

The World Health Organization has recommended that log-burning
stoves be phased out in developed countries in order to protect
human health and our climate. Nothing short of eliminating
log-burning stoves is going to improve our air and limit emissions.
Humboldt County’s current wood stove exchange program has been an
absolute failure and has done nothing to improve our air. 

Research from the well-known Libby, Montana wood stove exchange
program, where most stoves were replaced with newer EPA-certified
wood stoves, demonstrated that organic carbon levels decreased, but
elemental carbon emissions did not. In fact, there was evidence
that elemental carbon emissions might even have slightly increased
after the wood stove changeout. (The paper is available here:
http://www.sciencedirect.com/science/article/pii/S1352231011004778.)


The EPA estimates that the particulate emissions from a catalytic
stove may reach the level of an older, uncertified conventional
wood stove in as little as 2 to 5 years of use. In fact, Libby,
Montana still violated the federal fine particulate matter standard
at the end of the changeout program
(https://yosemite.epa.gov/opa/admpress.nsf/6427a6b7538955c585257359003f0230/1227df2e9a4c43d6852574aa00651283!OpenDocument&Start=1&Count=5&Expand=2).
Any changeout in California must not allow the exchange of wood
stoves for newer wood-burning stoves. We must accept the WHO's
recommendation and move away from this form of heat that is so
damaging to both our climate and our health. 

Another serious issue in Humboldt County are current plans to
increase woody biomass energy production, which would be seriously
detrimental to our air and to our climate. One of the plants that
may be restarted is the Blue Lake biomass plant. It is currently
offline, and it should stay that way. The level of emissions from
it when it went back online in 2010 were shocking — it blanketed
the town of Blue Lake in thick brown smoke for days. It was so bad,
it was the subject of an exposé in the Wall Street Journal. It is
an old, highly polluting plant that has caused significant harm to
the people of Blue Lake and beyond. 

But it is not the only biomass polluter here. Even with it offline,
by the California Air Resources Board’s calculations (attached),
wood/bark waste boilers emit more than 4 tons of CO a day, and more
PM2.5 and PM10 than any other source of electric generation locally
by orders of magnitude. Mr. Dan Noble of Noble Resources Group has
submitted a slick packet promoting, in part, the increase of
biomass incineration in Humboldt, but that is because his company
is a subcontractor to a company that is about to be awarded a large
contract by the Redwood Coast Energy Authority, who are planning to
implement a new community choice aggregation program, which they’ve
designed to support the local timber interests to the detriment of
the rest of our community and our climate. Dan Noble has a serious
financial stake in this. 

The state of California could be a real leader in GHG reductions by
promoting wind, wave and solar options, rather than encouraging an
antiquated form of electric production that emits the most carbon
of all. While carbon monoxide is itself a weak direct greenhouse
gas, it has important indirect effects on global warming. It reacts
with hydroxyl radicals in the atmosphere, reducing their abundance.
OH radicals help to reduce the lifetimes of other GHGs such as
methane. The presence of carbon monoxide indirectly increases the
global warming potential of these other gases. Biomass burning is a
major source of carbon monoxide and should not be promoted at the
expense of other, non-emitting forms of energy production.

It should also be noted that residential wood combustion emits more
CO and particulate matter than any other form of heating, by orders
of magnitude. If wood-burning stoves were phased out, it would also
have a tremendous benefit in reducing these emissions (see attached
statistics for Humboldt County and the state of California). 

Attachment www.arb.ca.gov/lists/com-attach/app-zip/101-slcp2016-UjdcNwRsWHgDdgVs.zip
Original File Nameemissions-data.zip
Date and Time Comment Was Submitted 2016-05-26 16:09:14

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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