Most of the controversy at the EPA’s public hearing on their new residential wood heater regulations was not about outdoor wood boilers or other unregulated heaters but about the traditional wood stove.
The largest bloc of speakers was from industry that appeared to have a well-coordinated, consistent message that these rules are ill-conceived and counter-productive. Most of the industry speakers made the point that the rules would likely raise the cost of stoves considerably, thereby slowing the switch from old, more polluting stoves to new, cleaner ones. They said that the solution to wood smoke should focus on changing out older stoves, not trying to squeeze another gram per hour or two out of newer ones.
More than a dozen air quality officials and advocates spoke just as passionately about the need for cleaner stoves, expressing general support for the proposed regulations and arguing for a short timetable for them to take effect. State officials from New Hampshire, Vermont, Massachusetts, Connecticut, Minnesota and Washington argued for the regulations while one state, Maine, sided much more with industry. Patricia Aho, Commissioner from the Maine Department of Environmental Protection expressed many reservations about the proposed rule, including strong reservations about a move toward more catalytic stoves. Several state officials called for Phase 1 standards, which take effect right away, to be stricter.
An assistant for Senator Patrick Leahy from Vermont said the Senator was generally supportive and would be providing formal written comments. He, like many of the speakers, talked about the importance of wood stoves for middle and lower-income consumers. A legislator from Missouri on the opposite side of the political spectrum said it is clear that the “EPA is trying to outlaw wood stoves” and that the EPA should not allow “environmental groups to be involved in the rulemaking.”
One notable difference between the EPA and most state officials is that the latter all talked about the importance of wood and pellets as a local, affordable and renewable energy source, themes that are largely absent in the EPA proposal or website.
One consistent talking point echoed by many industry presenters was that catalytic stoves performed well only in the laboratory and that consumers did not operate them well in their homes, leading to excess pollution. Many in industry called on the EPA to allow non-catalytic stoves to meet a more lenient emission standard while holding cat stoves to a more stringent one. Tom Morrissey, owner of Woodstock Soapstone vigorously defended catalytic stoves and called into question a report funded by US and Canadian non-cat producers.
While most of industry speakers supported change-outs over tighter emission standards for new stoves, one manufacturer who makes the exempt, uncertified stoves seemed to be advocating for the continued ability to sell these stoves. The EPA estimates that about 20,000 new exempt, uncertified stoves are sold and installed each year.
Many of the manufacturers argued for the need for sell-through periods and more lead-time to comply with the new standards. Other stakeholders called for an end of the sale of unqualified outdoor wood boilers as soon as possible, with no sell-through period.
An importer of European boilers urged the EPA to also accept the Brookhaven test method for boilers with thermal storage and set an achievable emission target for that method which includes start-up emissions. A retailer of Central Boiler outdoor boilers from New Hampshire talked about his lower-income consumers who could not afford a qualified unit, and urged the EPA to allow him to a reasonable sell-through period for his qualified units.
A manufacturer of fireplaces called on the EPA to regulate fireplaces, instead of exempting them again, as the EPA proposes. The American Lung Association strongly supported this, also urging that fireplaces be regulated. Several representatives of masonry stove builders urged the EPA to further work with them to ensure that their units could be certified.
The CEO of US Stoves noted that the SBA and OMB had serious problems with the EPA’s proposed rules and stressed how many of their customers were from low-income homes that are very sensitive to even small price increases. US Stoves and others currently sell quite a few EPA certified models in the $600 - $900 range, comparable to the price of stoves in the 1970s when adjusted for inflation.
Several organizations, including the Alliance for Green Heat, spoke of the benefits of consumers having access to third-party verified efficiency numbers using a consistent efficiency measurement and having that number prominently displayed on a hang-tag on the showroom floor. The EPA proposed to eliminate the hangtag with no explanation as to why.