Thursday, February 27, 2014

The EPA Publishes Trove of Documents that Influenced the NSPS

Along with proposed regulations, the EPA published 367 documents that are now available for public review and scrutiny.  Many are available to the public for the first time.  Many of the documents are long, substantive studies, test data and formal presentations to the EPA by various stakeholders.  But other documents are email threads that the EPA considered significant. 
The trove of documents can be found here at serves as EPA’s electronic public docket and on-line comment system.
The documents range span two decades of research, reports and studies about wood heat emissions, health impacts, testing issues and regulatory issues.   Included are all substantive correspondence between states, air quality agencies, industry and others.  Lawyers will be sifting through the documents to see whether the EPA has a “reasonable basis” to propose the emission limits and other requirements that it chose. 
The documents also bring to light major controversies within the hearth community regarding the NSPS.  Besides the issues surrounding test methods for outdoor boilers, documents show that non-catalytic stove manufacturers engaged in a concerted effort to discredit catalytic stoves. A group of manufacturers paid for a firm to conduct a study that showed catalytic stoves work well in the laboratory, but not in the hands of consumers who don’t operate them correctly.  They concluded that catalytic stoves should be held to a 2.5 g/hr standard and non-cat stoves held only to a 4.5 g/hr.
This internecine battle, and maybe others, could undermine the ability of the HPBA to present a unified voice to EPA and is likely to be raised during the February 26 public hearing in Boston.

This is also the site where the public can see the comments made since the regulations were posted on the Federal Register on Monday, February 5.  As of Tuesday, February 27, 153 comments have been posted, many of which are anonymous, short, impassioned statements telling the EPA that the regulations are unnecessary or counterproductive.  Some are from manufacturers and others that address the details and implications of various aspects of the proposed rule.


  1. John, you are wrong.

    There are many things in this blog that are modestly inaccurate, but this is just plain wrong and needs to be retracted.

    HPBA DID NOT provide any funds to either side in the catalytic vs. non-catalytic discussion. Both groups have organized on their own and raised their own funds. This is, in some respects, a side issue in the NSPS. Though important, it is not the main event. The key is that EPA can’t have it both ways on Step two for woodstoves; i.e. they can’t use a database compiled with an artificial fuel load, to derive a passing grade, and then alter, 1) the fuel, 2) the test method, 3) and the method of calculating the results!

    Even if they didn’t propose to change the fuel, the change in the calculation method alone invalidates all but five of the existing woodstoves currently certified on the artificial crib - both catalytic, and non-catalytic. And none of this is demonstrated to improve how EPA certified stoves operate in the field, in people’s homes, which is what the focus should be. Unfortunately, EPA has no data to support any of these proposed changes.

    But make no mistake, HPBA did NOT provide funds to either the catalytic or non-catalytic coalition. If, in the future you are unclear about any of this, you know how to get in touch with me. I hope you will print a retraction of this erroneous statement.
    John Crouch, HPBA

  2. In the blog above, we had said that the HPBA who had paid for the study showing cat stoves performed poorly. We were wrong and edited the article to say that a group of manufacturers paid for that study.

  3. A treasure to read through for those who have time. Thanks John for pointing this out. To me it shows so many details of a past technology that should be long gone for any crowded place. Only in the rural places would steam locomotives, outhouses, iceboxes, horses and wood stoves still be acceptable, unless the new EPA regulations are followed.