Comment Log Display

As the Board chairman of an international coalition, Doctors and
Scientists Against Wood Smoke Pollution (DSAWSP), I urge the CARB
to reject the concept of subsidizing any program to change out old
wood stoves for “EPA certified” stoves.  Much like the recent
Volkswagen diesel emissions scandal, something comparable is taking
place with wood stoves.  EPA stoves do not perform in the real
world like they do in the EPA lab for a long list of reasons.  But
their performance also degrades quickly over time, in fact in as
little as two years.

http://uphe.org/wp-content/uploads/2016/01/UPHE-wood-smoke-report-2016-update-PDF.pdf

It is a common misconception that burning wood is carbon neutral. 
A 2010 study concluded that the amount of carbon released per unit
of energy produced is actually greater for wood than it is for
fossil fuels. Considering the entire carbon life cycle of wood,
burning releases carbon now when we can least afford to do
so—carbon that would otherwise have been stored for decades or
perhaps centuries. While sustainable forestry practices can help
repay that “carbon debt,” those benefits do not accrue until the
distant future, too late to be of much help. Furthermore, the
overall impact of wood burning is that some of our forest mass is
being cut down for wood burning, and the loss of trees as carbon
reservoirs further aggravates the climate crisis.  For purposes of
climate considerations, CARB should be adopting policies to
eliminate wood burning, not temporarily reducing wood burning
through state subsidy.

Whatever CARB does for climate protection should also consider
secondary benefits.   In many cities, wood smoke is responsible for
as much community particulate pollution as vehicle traffic. 
Therefore, eliminating wood burning would reap tremendous public
health benefits.  This consideration is amplified further because
wood smoke is likely the most toxic type of pollution that the
average person is ever exposed to, much more toxic than second hand
cigarette smoke on an equal volume basis.  But because residential
wood smoke highly concentrates near its sources, neighbors of wood
burners suffer extraordinarily high levels of particulate matter,
PAHs, and dioxins, as documented by numerous studies, many of them
from California.  This is a greatly under appreciated  issue of
environmental justice—some members of the community are victimized
far more disproportionately than others.  In fact our organization,
DSAWSP, has been besieged for help by such victims throughout the
country.

We consider change out programs with “EPA certified stoves”
essentially a misguided capitulation to the wood burning industry
that only serves their interest, at the expense of the public
interest. 

Sincerely,

Dr. Brian Moench
Board Chairman, Doctors and Scientists Against Wood Smoke Pollution