Monday, January 9, 2012

EPA Delays NSPS Again

Alliance for Green Heat, Jan. 6, 2012 - The long awaited proposed New Source Performance Standards (NSPS) for residential wood heaters is being delayed yet again. EPA claims that it will be out this summer for the 90-day public comment period, and noted in a PowerPoint presentation that since this NSPS is not court ordered, such delays are possible.

The Alliance for Green Heat believes the multiple delays in this proposed NSPS, which now add up to several years, have allowed tens of thousands of polluting outdoor wood boilers to be installed. It has also deprived consumers of being able to select more efficient, money saving wood and pellet stoves. Until real efficiency numbers are published, the consumer is left without one of the most important pieces of information in their purchase.

“Even before the recent belt-tightening at the EPA, the agency has not provided the resources that would allow it to efficiently carry out this NSPS,” said John Ackerly, President of the Alliance.  “Given the millions of low and middle-income families that rely on wood heaters, wood heaters should have more priority within the EPA.”

The EPA has publicly released a draft summary of the new NSPS, which will establish mandatory and stricter emissions thresholds for almost all wood heating appliances. (Fireplaces, pizza ovens, chimneys, etc. are still exempt.)

The new non-cat wood stove standards are one of the mildest, going from 7.5 to 4.5 grams an hour, a standard the EPA acknowledges is already met by 85% of wood stoves. However, in addition to particulates, a minimum 70% efficiency standard is being added (high heat value) to reduce carbon monoxide (CO). Real efficiency numbers will be disclosed for each stove for the first time.

Catalytic stoves are being held to a tighter standard (2.5 grams an hour), potentially giving them the reputation of being the cleanest stoves on the market. EPA noted that the catalytic hearth coalition is arguing that all wood stoves be held to the same standard. In the EPA’s PowerPoint presentation, the EPA said they are requesting “comments and data to support other options for promulgation, e.g., establishing one limit of 2.5 g/hr for both non-catalytic and catalytic stoves.”

In the boiler arena, there is a similar discrepancy as there is for wood stoves: indoor boilers are being held to a less strict standard than outdoor boilers, and the EPA is likely working to make the case that they should be. Boilers will have to meet one threshold in 2014/2015 and a stricter, Level 2 threshold in 2017. In this arena, the EPA is requesting “comments and data to support additional options for promulgation, such as co-proposal of Level 2 immediately”.

For pellet stoves, the EPA has set an emission level far above what most pellet stoves produce – 4.5 grams an hour, the same as wood stoves. If this occurs, the United States would be the only developed country that does not hold pellet stoves to a stricter standard than wood stoves. It may also undermine the ability of consumers to use pellet stoves on bad air quality days, when wood stoves can’t be used. The Alliance believes the pellet stove industry should be positioning itself as a cleaner alternative to wood stoves and suitable for densely inhabited areas. The EPA may be willing to lower that standard and says they are requesting “data and comments to support additional options for promulgation, e.g., tighten the level in “2015” to 2.5 g/hr.”

The EPA’s draft recommendation for single-burn-rate stoves is 3 grams an hour, and also a minimum of 70% efficiency, and they are requesting “comments and data to support additional options for promulgation, e.g., 2.5 g/hr.” The EPA also notes that single-burn-rate stoves have been the “largest exemption for wood stoves in existing NSPS in terms of number of units sold (>40,000 units/year).”

The EPA’s request for “comments and data” on all these appliances classes is laudable but there appear to be few data sets that the EPA doesn’t already have that are professional and substantial enough to make a difference. EPA has had to rely on industry to fund and produce various studies because EPA does not have the resources. This has put a financial strain on industry, which is essentially made up of a few dozen small manufacturers, but also given industry a more powerful position in the process.

Partly because of lack of resources, EPA was not able to undertake a number of initiatives that it considered in this NSPS. Also, as EPA noted in the PowerPoint, “Some states are disappointed that we are not proposing carbon monoxide (CO) emission limits, visible emission limits, and requirements for energy audits, proper sizing, heat storage, and certified installers.”

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