California permits wood burners in mobile home parks
by laurelight » Fri Jul 31, 2009 10:36 am
Many thanks to burningissues.org for giving us the means to access the scientific research on wood smoke’s health dangers! Even though this is an uphill battle and they are apparently refusing to respond, I will persevere. Next round of letters is to elected officials and CA state public health officers.
July 16, 2009
Office of the Mobile Home Ombudsman
California Dept. of Housing and Community Development
1800 Third Street
Sacramento, CA 95811-6942
Dear Ombudsman,
I am a senior citizen suffering from the effects of a serious environmental health hazard in the mobile home park where I live. I am surrounded by neighbors who are using an antiquated invention in their living rooms that continuously spews mercury, dioxin, arsenic, lead, formaldehyde, carbon monoxide, methane, benzene, fine particulate matter, black carbon, and many other dangerous toxicants into the yards, homes and lungs of everyone in the neighborhood for over half the year. As unimaginable as it may seem, I have found out that this deadly activity is sanctioned and permitted by the California State agency responsible for health and safety in mobile home parks — the HCD.
My neighbors are using wood-burning appliances — and most of the wood stoves in the neighborhood are old, high emission models. To make matters worse, a chimney from one of these old stoves is located a mere 30 ft. away from my bedroom window. This is more than a "nuisance" — it is a severe health hazard.
I reside in the ironically named Mountain Air Mobile Park, a Senior mobile home park in Grass Valley. Because of the terrain, a neighbor’s home is situated on the terrace below our space, causing her chimney outlet to be at the same level as our living space. Her smoke and ash trespass into our home and yard every time she burns, which is usually 14+ hours a day in the winter time. But she is not alone. There are at least 75 wood burning appliances installed and operated in this small, 7± acre mobile home park with 89 residences. All of the mobile homes in this park are equipped with cleaner burning heating systems, but people choose to use wood burners because they are supplied free firewood by a community group. Park Management claims they can do nothing because wood burning is allowed by HCD.
By permitting the installation and use of wood burning appliances, HCD is allowing people in mobile home parks to severely pollute the air and poison their neighbors. According to research, heating with a wood stove for one season generates as much pollution as driving a car 130,000 miles. This means that in one burn season, Mt. Air Mobile Park generates as much air pollution as driving a car 9,750,000 miles.1
The California Air Resources Board calls wood smoke "a serious threat to public health".2 The association of fine particulate matter with adverse health effects has long been recognized, especially in relation to respiratory and cardio-vascular disease. Numerous studies have demonstrated that particulate air pollution is associated with increased mortality, primarily in the elderly. 90% of wood smoke is in the most harmful PM2.5 range. These dangerous microscopic particles penetrate into the deepest recesses of human lungs and cause the same variety of illnesses that are associated with second hand tobacco smoke, including asthma, COPD, heart attacks, cancer, and premature death. Studies show that 70% of smoke from chimneys actually reenters the home and neighborhood dwellings3 and it is impossible to keep the microscopic particles from entering your home if you live in a neighborhood where there is a lot of wood burning.
The effects of wood smoke are exacerbated by the "close knit" environment of a mobile home park, where chimneys are very likely to be 30 feet or less from neighboring homes. Berkeley’s Community Environmental Advisory Commission calculated that, at a distance of 40 feet, the particulate levels from non-compliant wood burning appliances exceed the 24-hour CARB Air Quality Standard in 30 minutes.4 Imagine the particulate levels from 14 hours of burning at a distance of 30 feet, day after day. This intensive, long term exposure to wood smoke cannot be anything less than a severe threat to the health and safety of residents in this and many other mobile home parks in California.
The State of California recognizes environmental tobacco smoke as a toxic air contaminant and bans tobacco smoking in virtually all public situations because of its threat to public health. Wood smoke and tobacco smoke are very similar in chemical composition — in fact, wood smoke is even more deadly. The EPA estimates that wood smoke is 12 times more carcinogenic than equal amounts of tobacco smoke5 and attacks our body cells 40 times longer than tobacco smoke.6
A single fireplace operating for one hour and burning 10 pounds of wood will generate
4,300 times more carcinogenic PAHs than 30 cigarettes. 7
The State recognizes my right to breathe clean air inside a restaurant, but HCD’s policies deprive me of the right to breathe clean air inside my own home. No one would argue with my right to forbid tobacco smoking inside my home, but I don’t have similar rights concerning the chemical trespass of my neighbors’ dirty wood smoke into my home because HCD policies permit this toxic, 19th century heating method that turns mobile home parks into "Death Camps for Seniors".
With an abundance of scientific research conclusively showing the health dangers and toxicity of wood smoke, why does HCD allow the installation and use of wood burning appliances in densely populated mobile home parks? Even if these appliances were installed many years ago, allowing their continued use in dense residential situations cannot be justified in light of modern, scientific evidence. How can HCD permit this obvious health hazard to exist in 21st century California?
New Health and Safety Codes which ban wood burning are needed
to protect mobile home park residents from toxic wood smoke emissions.
In its 2005 report to the California Legislature, CARB designates wood stoves and fireplaces as "high priority [pollution sources] for mitigation," stating that the smoke pollution from these sources "causes substantial, avoidable illness and health effects – ranging from irritant effects to asthma, cancer, and premature death – and costs Californians billions of dollars each year." 8 It has been estimated that each pound of wood burned costs the entire community $2 in increased medical costs and lost work days, equivalent to a community cost of $40 for an average fire burning 20 lbs of wood. That means that Mt. Air Mobile Park costs the community at least $90,000 a month during the winter burn season.9
It would cost the State virtually nothing to implement a health and safety ban on wood burning
in mobile home parks and would actually save the State billions of precious health care dollars
by reducing the medical costs of smoke-related chronic illness and hospitalizations for which the
State and Counties often become responsible. There would be no enforcement costs because,
as with current health and safety codes, Park Management would provide enforcement. In addition,
there are state and federal energy assistance programs already in place to help offset energy costs
for low-income households.
HCD has a stated goal of "improving the safety of mobile home parks."10 One of the best ways to do this is to create a health and safety code which bans hazardous and deadly wood burning in mobile home parks. Please study the scientific evidence readily available at http://www.burningissues.org, and realistically evaluate the serious health hazards of wood burning in mobile home parks and other high-density residential situations.
HCD should act responsibly and ban wood burning in mobile home parks.
It is truly a matter of life and death.
Thank you for your time and consideration. I look forward to your response.
Sincerely,
Laurel Kenner
CITATIONS
See http://www.burningissues.org for a comprehensive bibliography of scientific research on the health hazards of wood burning and particulate pollution.
1. Dr. Joellen Lewtas, "Contribution of Source Emissions of the Mutagenicity of Ambient Urban Air Particles," U.S. EPA, #91-131.6, 1991.
Calculation for Mt. Air Mobile Park Emissions
1 wood burning appliance = pollution from 1 car driving 130,000 miles
75 wood burning appliances x 130,000 miles = pollution from 1 car driving 9,750,000 miles
2. California Air Resources Board, News Release (January 2009). See enclosed copy of news release.
3. Anuszewski, J., T.V. Larson, and J.Q. Koenig, "Simultaneous Indoor and Outdoor Particle Light-Scattering Measurements at Nine Homes Using a Portable Nephelometer", University of Washington, Department of Civil Engineering and Department of Environmental Health, 1992.
4. Jason Kibbey, Chair, Community Environmental Advisory Committee, City of Berkeley, "Advisory Memo to City Council on Wood Smoke Nuisance Ordinance", Sept 23, 2008.
5. Lewtas, J., R.B. Zweidinger, and L. Cupitt. "Mutagenicity, Tumorigenicity and Estimation of Cancer Risk from Ambient Aerosol and Source Emissions from Woodsmoke and Motor Vehicles", Air and Waste Management Association, 84th Annual Meeting and Exhibition, Vancouver, BC, June 16-21, 1991. 1991: US EPA.
6. Wm. A Pryor, "Persistent Free Radicals in Woodsmoke: An ESR Spin Trapping Study", Free Radical Biology and Medicine 1989, 7(1): 17-21.
7. Lewis, C.W., et al., "Contribution of Woodsmoke and Motor Vehicle Emissions to Ambient Aerosol Mutagencity", Environmental Science and Technology, 22(8):968-971 (1988).
8. California Air Resources Board, "Report to the California Legislature 2005: Indoor Air Pollution in California", 2005.
9. Jane Hall, Kleinman, Fairley, Brajer, "The Economic Value of Quantifiable Ozone and PM10 Related Health Effects in the San Francisco Bay Area", The Institute for Economic and Environmental Studies, California State University, Fullerton, CA 92634, October 1994.
Calculation for Mt. Air Mobile Park Monthly Cost to Community
$40 per fire average cost to community x 75 appliances = $3,000 per day cost to community
$3,000 daily cost x 30 days = $90,000 monthly cost to community
10. California Department of Housing and Community Development, "Strategic Plan 2007-2010".
woodsmokenuisance 