Open Letter to Rhode Island House Environment Committee Members

April 2, 20122

Dear Rhode Island House Environment Committee members,

We write in support of the property set back and seasonal use restrictions in HB 5783.  The Alliance for Green Heat is a national independent non-profit that supports wood heat.  We, like many in the wood heat community and industry, feel that long past time to strictly regulate outdoor wood boilers.  They have given the wood heat industry a bad name for too long. 

1. Set back requirements for newly installed units, even the EPA qualified Phase 2 units, are essential because if owners use wet wood, they can still be very polluting, despite their more advanced technology.  All states that require Phase 2 units (except Maryland) have property set back regulations and Rhode Island should too.  The 100 foot set back in HB 5783 is entirely reasonable. Pennsylvania, the last eastern state to regulate outdoor boilers, now requires a 150 foot set back from the property line.  Even the outdoor wood boiler manufacturers support state-wide set backs and have publicly stated so on many occasions.

2. The seasonal use restriction, banning the use of outdoor wood boilers in warmer months is also essential, particularly for the non-EPA qualified units.  Many outdoor wood boilers are already over sized to heat the house they are attached too, and are absolutely inappropriate  to heat small amounts of hot water for summertime domestic water needs.  The way to save money on summer time hot water use is through energy efficiency measures, which are effective and readily available to Rhode Island residents, not a huge wood boiler with antiquated emissions technology. 

3. State-wide stack height regulations are also essential.  Dispersion modelling for outdoor wood boilers confirms that low stack heights are one of the greatest contributors to the lack of dispersion of wood smoke.  The provisions in HB 5783 are entirely reasonable and consistent with other states.

4. Rhode Island Air Pollution Control Regulation 48 goes part way to addressing outdoor wood boilers issues by banning the installation of the old, ultra-polluting models, but it fails to provide key protections and pollution control measures.  State-wide set back limits, stack heights and seasonal use restrictions are all essential.

Thank you for your efforts to promote reasonable regulations to protect air quality and human health.

Sincerely,

John Ackerly
President
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Alliance for Green Heat
6930 Carroll Ave, Suite 407
Takoma Park, MD 20912
301-841-7755
jackerly@forgreenheat.org
www.forgreenheat.org