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 Regulations.gov. Regulations.gov 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.
John, you are wrong.
ReplyDeleteThere 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.
Sincerely,
John Crouch, HPBA
crouch@hpba.org
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.
ReplyDeleteA 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.
ReplyDelete