Instead, they are proposing restrictions on days where the impact of smoke would be most detrimental to the health of some very sensitive residents, but also impact the health of all residents because the atmospheric conditions would hold the smoke in rather than blow the smoke out and disperse it throughout the valley.
I happen to live with someone who is very sensitive to smoke. On cool summer mornings, we often open our windows. Some mornings our neighbor will stand outside and smoke cigarettes. At levels that I cannot even detect, my wife will start hacking and if we do not close the window fast enough, she needs to use her inhalers.
For people who are sensitive to smoke, cold winter days and the smell of wood burning is enough to send them to ER for breathing treatments. Is it so unreasonable that the city act to restrict on the 15 to 20 worst days of the year?
People have acted as though this were an ordinance that would ban such wood burning, when in fact, it is a very modest ordinance that will only impact the city on days where it has the potential to be a health hazard – and not just for sensitive people. Studies have shown that wood-burned smoke is just as harmful as cigarette smoke – the difference is that people do not inhale it at the same level of concentration.
In September, the NRC recommended that the City Council implement a pilot program with respect to posting the allowable burn days on the city website and as resources allow, they “recommend that an additional educational program be implemented to instruct the public on proper fire-starting and fire-burning methods.”
They write, “The NRC recognizes that while many Davis residences find fireplaces and wood burning appliances a desirable amenity, wood smoke consists of fine particles which are regarded as a health hazard by both national and state health professionals.”
“Regional air quality standards have been promulgated identifying maximum ambient levels of particulates in the air tolerable to the general population without adverse health effects,” they continue. “Unfortunately, use of wood burning appliances under certain weather conditions can result in wood smoke concentrations that significantly exceed these particulate air quality standards and adversely affect residents. The operation of wood burning appliances therefore needs to be regulated so as not to cause significant health risks to susceptible citizens.”
One of the more amusing points that Mr. Dunning makes in his column is the hot September and early October we have had. There is irony there because by tomorrow, it is quite likely that people will be heating their homes.
Bob Dunning makes much of the urgency ordinance to the point of mocking derision. But the urgency ordinance allows the ordinance to go into effect immediately. Without it, the city would not be able to adopt a regular ordinance until December 13 – probably a month or more into the burning season.
A regular ordinance requires a second reading and a 30-day period before it goes into effect. “The regular ordinance is being pursued in the event that the urgency ordinance findings are challenged and found to be invalid,” staff writes.
As we noted in the previous article – there have been a number of complaints and concerns about both the enforcement process and hardship cases. This ordinance attempts to address both of those concerns.
The exemptions include the operation “of a U.S. EPA Phase II certified wood burning device or a pellet fueled wood burning heater, provided that the devices do not emit visible emissions, except for one period of not more than twenty minutes within any consecutive four hour period during the start up of a new fire.”
It would also not take effect for “the use of a wood burning device when no gas or electrical service heating system is installed in the structure and the wood burning device is the sole source of interior heat for the structure” or “the use of a wood burning device when electrical power service is not available, during times of temporary service outages.”
In addition, a waiver may be issued if the “director determines that there are compelling economic reasons to grant the waiver that outweigh the adverse impacts to the environment.”
The final point that Mr. Dunning makes bears addressing.
He attempts to downplay the scope of the problem by using the wrong statistical marker.
He writes: “Of the 120 days in the 2009-10 winter burn season, the city of Davis logged 16 complaints concerning wood smoke on ‘no-burn’ days. That’s not much in a city of approximately 15,000 homes. Even more telling, no one from the city has determined the source of the wood smoke for any of the complaints, which would seem to be an elementary question to ask before crafting a wood-smoke ordinance.”
“In the 2010-11 season, there were 61 complaints on ‘no-burn’ days, an increase to be sure, but still very, very low in the great scheme of things,” he writes. “We also don’t know from the data if there were actually 61 separate individuals filing single complaints or a handful of individuals filing multiple complaints each time the ‘nearest neighbor’ fired up his old wood stove.”
There are several different types of problems with his analysis.
First, he plays a statistical sleight of hand by citing that there were 120 days in the winter burn season, but only 16 complaints.
In fact, 120 days is not the operative statistic. The critical statistic is not the number of days in the burn season. That implies that every day had burn restrictions, but in fact, the key statistic was 15 no burn days in 2009-10 and 19 no burn days in 2010-11.
Still a low number of complaints? Perhaps, but the number of complaints nearly quadrupled between 2009-10 and 2010-11.
How do we interpret that statistic? We the NRC argues, “The higher percentage of complaints received on No-Burn Days indicates that there was relatively little compliance with the voluntary ‘Don’t Light Tonight’ advisory alerts issued by the YSAQMD in 2010 – 2011.”
But the bigger issue may be that the number of complaints in 2009-10 was understated and that as more people became aware of the problem and the ability to do something about the problem, they lodged more complaints.
The question then becomes is 61 the actual number of complaints or is that too understated? Bob Dunning asks whether it’s 61 separate individuals filing complaints or a few individuals filing multiple complaints.
Perhaps he can ask himself if that really matters the next time he has to take his daughter to ER because she had an asthma attack brought on by wood burn smoke.
Is it worth inflicting this kind of discomfort on your neighbor so you can burn your fireplace an additional 15 to 20 times a year? And why is it so unreasonable for the city to protect the health of even a small number of people by putting restrictions on wood burning a few times a year?
—David M. Greenwald reporting