Appendix: Evaluation Tool Notes
D. Major Solution D: Increase Enforcement Capability during Burn Bans
(NOTE: This was the base case presented to the task force at the Sept 7 meeting. Several assumptions
have been changed based on suggestions by task force members. They are highlighted below.)
Solution Description: May need more staff or others to increase number of enforcement officers/
Enlarge enforcement personnel to carry out burn bans (consider contracting out for private
enforcement personnel).
General Assumptions:
The main assumption of this scenario that results in pollution reduction is that a major percentage
of people who receive a burn ban civil penalty never burn again during a ban. The scenario to make
this idea quantifiable is to increase staff from our current 12 inspectors to 60 (likely using a
subcontractor). This scenario assumes no other changes in the way the Puget Sound Clean Air
Agency enforces burn bans.
Assumptions:
1. We assumed calling 10 burn bans days per year in Pierce County. This was based on the calculated
average number of days over 35 micrograms per cubic meter over the last 5 years.
2. 60 Field Workers.
3. 2 Workers per Field Team – current practice for safety.
4. 7 Hours of Enforcement on weekends and weekdays during daylight hours (daytime enforcement
only).
5. 0.3 Notices of Violation (NOV) per Hour per Worker – a rate estimated from compliance staff at
PSCAA. This means 0.6 NOVs per team per hour.
6. 80% Rate of NOV to Civil Penalty – a rate estimated from compliance staff at PSCAA of the
percentage of NOVs that result in a civil penalty.
7. 0% Word of Mouth Percent to Neighbors about Civil Penalty – Unknown and took conservative
assumption as we do not know if anyone tells their neighbors they got an NOV or paid a fine.
8. 25% Repeat Offender Percent – This means that 25% of the people who receive a civil penalty from
PSCAA continue to burn during burn bans. This percentage is highlighted as it was increased from
when we first presented this to the task force. We originally presented 10%, but there was some
consensus from the Clean Air Task Force that compliance with burn bans was worse and should be
lowered. Our system is not set up to track if people are repeatedly receiving notices of violation, so
there is a high level of uncertainty in this assumption.
9. 25% Percent Burners during the Day – This means 25% of the people who have a wood burning
device and use it will be burning during the day. This is based on recent surveys of Pierce County and
Puget Sound residents. This figure puts a maximum number of burners that could be burning during
the day if none were complying with the burn ban.
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10. 80% Percent of All Devices Burning During Burn Ban -- This means 80% of the people do NOT comply
with the burn bans, and 20% do comply. This is based on surveys in the nonattainment area on burn
ban compliance. Additionally, it factors in people simply not burning (busy, on vacation, etc.). This
assumption sets another upper bound on how many devices can be enforced and are burning during
a burn ban.
11. The scenario assumes enforcement is only based on smoke density (opacity), as is currently done.
Cost Assumptions:
12.
13.
14.
15.
16.
Cost of Field Staff per year including all costs: $318,000.
Cost of Legal Staff per year including all costs: $32,000.
Cost of Smoke School training for all field staff per year: $24,200.
Vehicle Costs for 10 burn ban days per year: $8,300.
1 Hours to Process 1 NOV – a rate estimated from compliance staff at PSCAA, includes
administrative staff time, interaction with individuals, paperwork, etc.
17. 0 Number of Night Goggle Devices to Purchase
Agency Evaluation of Each Criterion with Rationale:
Reduction
By 2014: 0.3 micrograms per cubic meter (about 3% of the minimum reduction needed)
By 2019: 1.4 micrograms per cubic meter (about 16% of the minimum reduction needed)
Economic Feasibility
$3.2M per microgram per cubic meter
Maintainable:
Not Well = Does not improve air quality over time significantly as it has relatively small impact
overtime (0.5 micrograms per cubic meter per year). By 2014, there would be no obvious
impact. It also does not address some of the underlying causes (such as wood is still a source of
heat and the potential is there if enforcement funding ended).
Implementation:
Not Well = May be hard to find 60 staff to work 0-2 weeks on-call each winter. There is,
however, a commitment to enforce burn bans as the program is already established through
PSCAA and adequate authority already exists in Washington State law.
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Unintended Consequences:
Somewhat/Mixed = May be public backlash that endangers the burn ban program, unexpected
staff time burden processing notices of violation, unexpected staff time and costs to run
program, unexpected financial burden on the public.
Funding Availability:
Somewhat/Mixed = Funding could potentially be secured based on prior commitments from the
legislature focusing on wood smoke. There is a lot unknown with the current budget, but this is
a judgment call.
Technically Feasible/Sound:
Very Well = We have been enforcing burn bans in Washington for over 20 years. With increased
enforcement that would curtail future burning, we can make estimates of what the future
emission reductions would be.
Timing/Timely:
Very Well = Can implement before 2014 if a contractor could be lined up and trained for
enforcement. A lot of knowledge and infrastructure is already established from our experience.
Enforceable:
Very Well = Is already in Washington State law and would qualify with EPA’s criteria as
enforceable.
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D-S1. Major Solution D Combined with Supplemental Solutions – Enhanced Burn Ban Enforcement
Supplemental Solutions Combined with the Base Case:
1.
2.
3.
4.
5.
6.
Permit Program
Smoke/No Smoke Enforcement
Single Stage Burn Ban
Night Enforcement
Increased Enforcement
Large Advertising Campaign
Pollution Reduction Assumptions that Differ from the Base Case of Major Solution D Assumptions:
1. Notices of violation increase from 4 per field team per day to 10. This is based on increased rate
of issuing NOVs because enforcing based on whether or not the inspector sees smoke is quicker
than reading smoke density as in current practices.
2. Percentage of people potentially burning (and potentially enforceable) increases from 25% to
100%. This is because we now include enforcing those who burn at night. Still assumed that
20% of all the potential burners comply with the burn ban and are not burning.
3. Enforcement personnel increased from 60 to 100.
4. Increased the percentage of people reached by the outreach message from 0% to 50%, and 10%
of those change their behavior. We have not been able to locate any specific behavior change
information to inform this assumption, so there is a very high level of uncertainty in this
estimate.
Cost Assumptions that Differ from the Base Case of Major Solution D Assumptions:
1.
2.
3.
4.
Permit program administrative costs are an additional $100K per year.
Assumes no revenue from permits so there is less barrier (no permit cost to resident) to comply.
Using half volunteers results in $250K savings per year.
Increased outreach advertising would cost about $200K per year during burn bans.
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Agency Evaluation of Each Criterion with Rationale (only the ratings that changed are included from the
original baseline case of enhanced enforcement):
Reduction
By 2014: 2.2 micrograms per cubic meter (about 24% of the minimum reduction needed)
By 2019: 6.4 micrograms per cubic meter (about 71% of the minimum reduction needed)
Economic Feasibility
$1.2M per microgram per cubic meter
Maintainable:
Somewhat/Mixed = Was rated “Not Well” in the base case of just increased enforcement. Now,
with supplementary solutions added, air quality does improve more significantly over time.
Technically Feasible/Sound:
Somewhat/Mixed = Was rated “Very Well” in the baseline case of enhanced burn ban
enforcement. Although we have experience administering this type of program, we have never
enforced at night. Currently, this is an untested approach for PSCAA.
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D-S2. Major Solution D Combined with Supplemental Solutions – Enhanced Burn Ban Enforcement –
with Two-Stage Burn Ban
This solution changes the “Single Stage Burn Ban” assumption (presented in D-S1 above) to a “TwoStage Burn Ban” program. To review, a Two-Stage burn ban allows certified devices to be used during
Stage 1. All burners are prohibited from burning in a single stage burn ban.
All the assumptions are the same as D-S1 except for the following changes:
1. A permit database exists to be able to identify certified wood burning devices.
2. In a Two-Stage Burn Ban, inspectors lose time establishing who certified device owners are,
looking up addresses in a permit database, then discovering that certified devices should not be
issued notices of violation.
a. A 2007 survey identifies 28% of burning devices are certified.
b. Additionally, our historical record shows Pierce County is under Stage 1 burn bans 43%
of the time.
c. In summary, we expect a 12% reduction in total notices of violation.
i. From 10 notices of violation per day per field team.
ii. To 8.8 notices of violation per day per field team.
Resulting emission reduction changes:
1. The combined enhanced enforcement solution, with all the supplemental solutions was:
a. By 2014: 2.2 micrograms per cubic meter
b. By 2019: 6.4 micrograms per cubic meter
2. With a two-stage burn ban:
a. By 2014: 2.1 micrograms per cubic meter
b. By 2019: 5.9 micrograms per cubic meter
Cost remained the same ($1.2 M/microgram per cubic meter).
Not factored in: potential lost compliance with more confusing messaging.
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D-S3. Major Solution D Combined with Supplemental Solutions – Enhanced Burn Ban Enforcement –
with Lower Penalty for NOV and Optional Waiver for Taking Training
This solution assumes lowering the penalty to $50 (just as an example) for burning during a burn ban,
with an option to waive the penalty with good burning behavior training.
All the assumptions are the same as D-S1 except for the following changes:
1. Civil penalties start lower: at $50 for a first offense. Penalty can be waived if burner opts for
good wood burning behavior training. Second offense is $1000 with no option to mitigate
penalty.
2. As first-time penalties are significantly lower than in the D-S1 solution (they averaged
$400/violation based on PSCAA enforcement records), the assumed compliance rate of 75%
after a civil penalty would lower to 50% (high uncertainty).
3. 50% pay the violation, 50% take the training course (high uncertainty).
4. Assumes $50 administrative cost to pay for good burning behavior class.
5. Assumes an additional hour of staff time per citation processing for setting up class and
processing records.
Resulting emission reduction changes:
1. The combined enhanced enforcement solution, with all the supplemental solutions was:
a. By 2014: 2.2 micrograms per cubic meter
b. By 2019: 6.4 micrograms per cubic meter
2. With the lower penalty for NOV and optional waiver for taking training:
a. By 2014: 1.5 micrograms per cubic meter
b. By 2019: 3.4 micrograms per cubic meter
Resulting cost changes:
1. The combined enhanced enforcement solution, with all the supplemental solutions was:
a. $1.2M per microgram per cubic meter
2. With the lower penalty and optional outreach with citation:
a. $0.9M per microgram per cubic meter
The cost reduction is primarily based on lower penalties to households.
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D-S4. Major Solution D Combined with Supplemental Solutions – Enhanced Burn Ban Enforcement –
with Exemption for Income Qualified Households
This solution assumes allowing income qualified households to continue to burn during burn bans and
have violations waived.
All the assumptions are the same as D-S1 except for the following changes:
1. We are defining low income to be 150% of the federal poverty level.
a. That puts 18% of Pierce County into this category according to the 2005-2009 Census
ACS Data.
b. This assumption results in an 18% reduction in citations.
Resulting emission reduction changes:
1. The combined enhanced enforcement solution, with all the supplemental solutions was:
a. By 2014: 2.2 micrograms per cubic meter
b. By 2019: 6.4 micrograms per cubic meter
2. With exemptions for income qualified households:
a. By 2014: 2.0 micrograms per cubic meter
b. By 2019: 5.4 micrograms per cubic meter
Resulting cost changes:
1. The combined enhanced enforcement solution, with all the supplemental solutions was:
a. $1.2M per microgram per cubic meter
2. With the lower penalty and optional outreach with citation:
a. $1.4M per microgram per cubic meter
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C. Major Solution C: Time of Sale Removal of Uncertified Devices
(NOTE: This was the base case presented to the task force at the Sept 7 meeting. Several assumptions
have been changed based on suggestions by task force members. They are highlighted below.)
Solution Description: At the time of sale of a house, require the removal, (decommissioning,) or
changeout of uncertified stove or fireplace insert.
General Assumptions: Legislation is adopted that requires the removal, decommissioning, or changeout
of all uncertified devices at the time of sale.
Specific Assumptions:
1. Based on Oregon’s existing program
2. Homes that are sold have the same likelihood of having an uncertified device as all homes
3. Some houses which have had their device removed may be resold. These will not be (double)
counted.
4. Home sales rates are 2-3% annually (from Pierce County Assessor-Treasurer’s reports for 20082010) – This was changed from the initial scenario which had 3-5% annually.
5. 60% houses sold will comply - This was changed from the initial scenario which had 75%
compliance. The initial scenario (75%) was based on an upper-end expectation of compliance
from Oregon’s program – we have slightly decreased here. There is high uncertainty around this
number.
6. 1.2-1.8% removal rate each year
7. The total number of devices available to be removed will decrease each year.
Cost Assumptions:
Agency costs:
1.
2.
3.
4.
5.
Labor need based on Oregon’s experience
0.25 FTE to setup (for one year)
0.1 FTE to support with administration/IT
0.5 FTE ongoing to manage and administer
Initial outreach materials $30k - This was changed from the initial scenario which had $20k for
startup.
6. Ongoing outreach materials $10k/year - This was changed from the initial scenario which had
$5k annually.
7. The above staffing level is only to administer
8. A small fraction will have this device as their only adequate source of heat and would need a
replacement or upgrade to their heating capabilities. Assume high range of our estimates of
1.7% of all houses.
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Home buyer/seller costs:
1. Remove device, piping/venting, etc., and cosmetic repairs to house: $350/house for
freestanding, $1200/house for insert - This was changed from the initial scenario which had
$200/house for freestanding.
2. For houses that had uncertified device as only adequate source of heat, upgrade furnace, or
switch to gas or other non-wood heat source, $5000/house
Agency Evaluation of Each Criterion with Rationale:
Concentration Reductions:
- About 0.35 micrograms per cubic meter by 2014 (about 3% of the minimum reduction needed).
- About 1.2 micrograms per cubic meter by 2019 (about 13% of the minimum reduction needed).
Economically Feasible:
- By 2014 total cost per micrograms per cubic meter is $1.8-2.1 M
- By 2019 total cost per micrograms per cubic meter is $1.7-1.9 M
Implementation:
Somewhat/Mixed = PSCAA has experience managing this type of program. Assuming it is
legislated, there is commitment and authority to implement.
Maintainable:
Somewhat/Mixed = Will not improve air quality quickly (about 0.4 micrograms per cubic meter
by 2014), but has modest gain by 2019 (about 1.2 micrograms per cubic meter), and does
address an underlying cause by removing uncertified woodstoves.
Funding Availability:
Somewhat/Mixed = Funding could potentially be secured based on prior funding focused on
wood smoke reductions.
Technically Feasible/Sound:
Very Well = Relies on the simple and sound principle of removing the device. Reduction in
emissions and improvement in air quality can be calculated directly.
Timing/Timely:
Somewhat/Mixed = would require legislation so couldn’t begin until 2013; won’t make large
reduction by 2014, but will be by 2019
Enforceable:
Somewhat/Mixed = With legislative backing, would be enforceable. But with assumed staff
level, could not be done directly case-by-case.
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Unintended Consequences:
Somewhat/Mixed = Public backlash may reduce compliance. May be unexpected time dealing
with questions and complaints. Potential impact on home sales.
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C-S1. Major Solution C Combined with Supplemental Solutions – Inspection or incentive
Supplemental Solutions Combined with the Base Case:
1. Inspection to directly verify individual compliance and raise overall compliance rate
2. Incentives to homeowners
General Assumptions:
Inspections details and costs:
1. Have 1 FTE inspector who makes full-time visits and completes documentation
2. Assume not all can be directly inspected: with 5/day about 1000/year is about 20% of sales
3. Also include transportation costs and 0.1 FTE additional administration
4. Agency additional cost about $110k /year
5. Incentive to homeowners of $150
6. Assume compliance would increase to 90%
Agency Evaluation of Each Criterion with Rationale (only the ratings that changed are included from the
original baseline case of enhanced enforcement):
Concentration Reductions:
- About 0.5 ug/m3 by 2014 (about 5% of the minimum reduction needed).
- About 1.7 ug/m3 by 2019 (about 19% of the minimum reduction needed).
Economically Feasible:
- By 2014 total cost per ug/m3 is $2.1-2.4 M
- By 2019 total cost per ug/m3 is $2.0-2.3 M
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C-S2. Major Solution C Combined with Supplemental Solutions – Baseline scenario with fireplace
requirement, inspections, and incentive
Supplemental Solution Combined with the Base Case: Time of sale including removal or
decommissioning of uncertified devices, fireplaces, and inspections and incentives
General Assumptions:
1.
2.
3.
4.
5.
Use same administration program as Time of Sale uncertified
Assume same sales and compliance rates as for uncertified devices
Use same inspector (no additional) as Time of Sale uncertified
Must either cap or plug chimney ($200/house) for 30% who don’t use their fireplaces
Install a log set (gas or electric) for owners who previously used their fireplaces and would like
functionality
o Some individuals will choose to not keep functionality
o Those who want some functionality will choose among a range of devices from basic
electric log sets to high end gas log sets
o Would average about $600 per house
Agency Evaluation of Each Criterion with Rationale (only the ratings that changed are included from the
original baseline case of enhanced enforcement):
Concentration Reductions:
- About 0.7 micrograms per cubic meter by 2014 (about 8% of the minimum reduction needed).
- About 2.4 micrograms per cubic meter by 2019 (about 27% of the minimum reduction needed).
Economically Feasible:
- By 2014 total cost per micrograms per cubic meter is $2.2-2.4 M
- By 2019 total cost per micrograms per cubic meter is $2.1-2.3 M
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Major Solution B: Major Solutions Combined with Supplemental Solutions: Date Certain Removal of
Uncertified Devices
Solution Description:
1. Create a mandatory permit program for wood burning devices (with fee based on
efficiency, more efficient lower fee).
2. Require uncertified stoves to be removed by a certain date.
3. Require weatherization.
4. If a replacement is necessary, replace with other source of heat (wood or nonwood).
Supplemental Solutions Combined with the Base Case:
1. Use incentives.
2. Have gas lines extended to customers within 50 feet of a main gas line, with the cost
spread across the rate payers either in the nonattainment area or Puget Sound, or
paid for by government.
Emission Key Assumptions
1. At rate of 3,000 uncertified devices removed per year.
2. Expect actual compliance/disclosure rate of 60% (13,000 uncertified devices
removed out of 22,000).
3. Assumes 50% of households that remove uncertified devices purchase their own
certified device on their own money. This is based on PSCAA agency records of
change-out programs where 50% chose a certified wood burning device when given
the option to replace with another heat option, even when the incentive was
smaller. Also includes 2% growth of certified devices each year with new
construction.
4. Actual date of removals and weatherization start January 2013.
5. Required final removal date of December 2017.
Cost Key Assumptions
1. Free removal for all uncertified devices. Costs about $6M over the life of the
program.
2. Free weatherizing to all income qualified households as this scenario potentially
removes a cheaper source of heat and makes household more reliant on utility. 12%
of Pierce County is below the poverty level (2005-2009 data). Used 150% of the
poverty level or 18%. Weatherization assumptions from PSE’s 2010 Integrated
Resource Plan. Includes percentage of single family residence estimates where
weatherization is possible. Also includes cost estimates for each type
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3.
4.
5.
6.
7.
8.
(weatherstripping, floor, wall, and attic insulation). Costs about $8M over the life of
the program.
If only adequate source of heat, program will provide subsidy to purchase and
install a new sources of heat. About 1,000 devices will be replaced by other nonwood heating sources for low income residents (0.20% to 28.3% of wood device
owners could be primary burners based on wood stove change-out data).
Conservatively, used ratio of uncertified devices to get total from primary burners
(34%). Costs of replacement devices from experience with our change out programs
($2500 for certified stove, $6500 for natural gas stove/insert, $4500 for heat pump,
$9500 for whole house heat pump, $4500 for propane). Costs about $4M over life
of program.
Free gas line extensions for households within 50 feet of a main line. Costs are
covered by the nonattainment area rate payers, Puget Sound rate payers, or
government. Assumes the costs that may be incurred by Puget Sound Energy are
not included in the total societal costs. Total cost to customers is $6M.
$500 reward if uncertified device is removed within the first year (up to 3,000
devices). Costs $1.5M over life of program.
Random enforcement of households. Trained personnel will give “audits” to verify
if devices are certified or uncertified when homeowner applies for permit; also
determines if other source of heat is “adequate”. All device inspector costs are
$100K/yr.
Free permit the first year. Staff costs for permit program ($200K/yr). Annual
permit revenue of $500K/yr.
Expanded outreach to ensure that the message gets out to all communities and
ample efforts are made to communicate to low income and other groups regarding
heat/weatherization/etc. Assumes 5% of program costs ($1.5M).
Agency Evaluation of Each Criterion with Rationale:
Reduction
By 2014: 2.3 micrograms per cubic meter (about 3% of the minimum reduction needed)
By 2019: 5.7 micrograms per cubic meter (about 16% of the minimum reduction needed)
Economic Feasibility
$5.4M per microgram per cubic meter.
Maintainable:
Very Well = Will improve air quality (2.3 micrograms per cubic meter by 2014), does address
some underlying causes.
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Implementation:
Not Well = May be difficult to enforce required removals. No current commitment nor authority
to do so.
Unintended Consequences:
Somewhat/Mixed = May be public backlash that endangers the burn ban program, unexpected
staff time burden processing notices of violation, unexpected staff time and costs to run
program, unexpected financial burden on the public.
Funding Availability:
Somewhat/Mixed = All funding would not likely be secured by 2014, possibly beyond. This
criterion is highly dependent on which program options are chosen and how it drives the costs.
Technically Feasible/Sound:
Very Well = Emission reductions would be easily measured.
Timing/Timely:
Very Well = Good reductions before 2014, and fully phased in by 2017.
Enforceable:
Very Well = Qualifies as an enforceable measure in EPA criteria.
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Major Solution A: Major Solutions Combined with Supplemental Solutions: Date Certain Removal of
Uncertified Devices – Certified Devices Restricted
Differences from Solution B:
Certified devices are now restricted from being put back into homes where uncertified device was
removed.
Key Assumption Changes
In Solution B, we assumed 50% of homes purchased a certified device after the uncertified device
removal. Now we are assuming 0% install a certified device.
The cost assumption that changes is no homes purchase a certified device, lowering the over societal
cost. Uncertified fireplace inserts that were removed are assumed to go to a natural gas insert if they
had natural gas in their home at a rate of 50%.
Agency Evaluation of Each Criterion with Rationale:
Reduction
By 2014: 3.3 micrograms per cubic meter (about 3% of the minimum reduction needed)
By 2019: 8.2 micrograms per cubic meter (about 16% of the minimum reduction needed)
Economic Feasibility
$3.6M per microgram per cubic meter.
No other criteria were changed.
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