The Northern Alaska Environmental Center supports the draft Serious State Implementation Plan (Serious SIP) prepared by the Alaska Department of Environmental Conservation (DEC). The Serious SIP is in response to the Environmental Protection Agency (EPA)’s June 2017 reclassification of the Fairbanks PM2.5 area as a serious nonattainment area due to continued wintertime PM2.5 levels above the national air quality standards. Northern Center supports the DEC and EPA in spurring action to reduce persistent and dangerous levels of PM2.5 that occur in the Fairbanks North Star Borough (FNSB) area in the winter months. In putting forth the Serious SIP, DEC recognizes the serious and growing health impacts of PM2.5 while protecting the ability of FNSB area residents to use a renewable energy resource, wood, to heat their homes.
The Northern Center supports measures that directly reduce PM2.5 by focusing on practices, individuals, and businesses that produce the heaviest concentration of PM2.5 pollution. The PM2.5 reductions proposed in the Serious SIP will not completely remove air pollution or the resulting health impacts that affect us. But it’s an essential step in the right direction because the Serious SIP lays out actionable measures that we as a community must build on to clean our air, protect our families, and leave a healthy environment and sustainable economy for the next generation.
You can comment on the proposed regulation changes until July 26 by submitting written comments to Cindy Heil, Division of Air Quality, ADEC, 555 Cordova St, Anchorage AK 99501; or by facsimile at (907) 269-7508; or by e-mail to email@example.com; or by the electronic comment form here.
Our wintertime air quality is the worst in the nation due to high concentrations PM2.5.[i] Wintertime air pollution is made worse by our climate, long-heating season, lack of affordable alternatives to heating with wood and heating oil, and temperature inversions. Fairbanks frequently experiences temperature inversions that are among the strongest in the United States.[ii] Taken together, these factors have produced 24-hour average wintertime PM2.5 values of 85 micrograms/cubic meter—the highest of the five other serious nonattainment areas, and 2.4 times higher than the EPA’s 24-hour PM2.5 standard of 35 micrograms/cubic meter.[iii]
- We must do more because the air we breathe affects our health more than the food we eat or the water we drink. Study after scientific study report on the dangerous health effects from both short- and long-term exposure to PM2.5, which are associated with increased hospital admissions, increased cancer risk, and risk of premature death.[iv][v] Due to their small size, PM2.5 particles are inhaled deeply into the lungs and can pass into the bloodstream, increasing the risk of cardiovascular and respiratory health problems.[vi],[vii]
- Those most at risk from PM2.5 are our children, our elders, and any of our family or friends with asthma, influenza, lung disease or heart disease.[viii]
Focus on the Fixes
We, as a community, can fix our wintertime PM2.5 problem. We must do this by focusing our energy on the worst offenders for PM2.5 pollution. The Serious SIP offers several critical steps to do that. The measures that stand out as most impactful and that we strongly support are
- Registration requirements for wood-fired heating devices. Being able to locate and monitor wood-fired devices is essential to change behavior, such as burning during times of poor air quality, that pushes PM2.5 pollution above national air quality standards. Focusing this change on “hot-spots” or areas with PM2.5 levels that are consistently high is critical to using our limited resources in an efficient and effective manner. The Serious SIP calls for registration of new devices and for devices attached to buildings that are sold, given burn waivers, or enrolled in programs such as the wood-stove change out program or the State of Alaska’s planned Burn Right program. We recommend an areawide registration requirement for existing and new wood-fired heating devices.
- An areawide mandate to shift from #2 fuel oil to #1 fuel oil for home heating and some stationary engines. This transition will result in a significant reduction in sulfur air pollutants and does so with full consideration for the costs that would be faced by individual home owners.[ix]
- Strengthening the existing requirement that dry wood be burned. Specifically, requiring that wood has been properly seasoned, dried, or harvested in a way to ensure it has a moisture content of less than 20%. We encourage the DEC to consider additional measures to support this transition such as a publicly-supported and privately-operated kilns for wood drying.
- Measures that tie reduction of PM2.5 to individual homeowner cost savings on a communitywide basis. We encourage the State of Alaska or FNSB to implement a voluntary program to improve residential energy efficiency and prioritize action in wood-burning homes in air quality hot spots. We also recommend a Borough-wide requirement for home energy audits at the time of sale. Though not included in the Serious SIP, both measures are important to reducing unnecessary energy use community-wide.
- Removal of all EPA uncertified heating devices and outdoor hydronic heaters except for those fueled by pellets by December 2024. We encourage the State of Alaska to request funding for a 2-year $40 million wood stove change out program to be operated by the DEC or FNSB to support the homeowners that must replace wood-fired devices under this requirement.
- Limiting the use of solid fuel burning appliances (SFBAs) so they are a secondary source of heat for new construction and rental units with an exception for certain dry cabins and qualified rental units. These appliances must be professionally sized and installed to reduce indoor and outdoor pollution.
Measures to reduce PM2.5 levels are worthless unless resources to educate residents on their value and to compel everyone to follow them are put in place. NORTHERN CENTER strongly recommends that the State of Alaska
- Provide necessary funding to the DEC to develop and operate the voluntary Burn Right program to provide acknowledgement and recognition to those who ensure limited emissions from wood-burning. This program will allow individuals to voluntarily provide device registration information on existing wood-fired heating devices.
- Adopt legislation giving the DEC citation authority for violations of the measures included in the Serious SIP and increase funding for enforcement.
- Fully support the DEC’s implementation of the Serious SIP as a recognition of the unacceptable cost that inaction will impose on the health of all FNSB area residents.
NORTHERN CENTER strongly recommends that the State of Alaska and the Fairbanks North Star Borough
- Develop an outreach campaign that promotes public action on air quality with a clear message that agreeing to not burn during times of = inversions and poor air quality is the only way for us to achieve our goal, the preservation of our ability to heat with wood.
[ii] Wendler, Gerd, et al, “Low Level Temperature Inversions in Fairbanks, Central Alaska,” Monthly Weather Review, January 1975.
[iii] EPA. “Designated PM-2.5 (1997, 2006, 2012) Nonattainment Areas,” current as of June 2019. EPA Green Book. https://www3.epa.gov/airquality/greenbook/rncl2.html
[iv] U.S. EPA (U.S. Environmental Protection Agency). 2009. Integrated Science Assessment (ISA) For Particulate Matter (Final Report). EPA/600/R-08/139F. Washington, DC:U.S. EPA
[vi] Pope, C. A. III & Dockery D. W. (2012). Health Effects of Fine Particulate Air Pollution: Lines that Connect
Journal of the Air & Waste Management Association 56(6): 709-742. https://doi.org/10.1080/10473289.2006.10464485
[vii] U.S. Environmental Protection Agency). 2009. Integrated Science Assessment (ISA) For Particulate Matter (Final Report). EPA/600/R-08/139F. Washington, DC:U.S. EPA]
[viii]State Air Quality Control Plan, Vol. II: III.D.7.2, Background and Overview of PM2.5 Rule, Public Notice Draft, May 10, 2019
[ix] State Air Quality Control Plan, Vol. II: III.D.7.7, Control Strategies, Public Notice Draft, May 10, 2019