The deadline for submitting comments on the EPA proposed new wood heater regulations is in one week, on Monday May 5. Listed below are some of the key recommendations that the Alliance believes are necessary to promote cleaner and more efficient wood and pellet heating in the United States.
The Alliance welcomes any input about these recommendations prior to the Monday submittal deadline. Here are more extensive comments here for your review and input.
• Closing loopholes so that federal emission standards apply to all wood heating appliances – wood and pellet stoves, boilers, furnaces and masonry heaters.
• Following the 5-year implementation period, instead of the alternative 8-year period.
• Requiring wood stoves to meet a 4.5 gram an hour standard and pellet stoves a 2.5 standard from 2015 to 2020.
• Not grandfathering any device that does not meet Step One standards in 2015 and Step Two standards in 2020.
• Requiring manufacturers to disclose the efficiency of their heaters within 6 months of finalizing the rule. Access to accurate wood and pellet heater efficiency numbers is particularly important for low-income households.
• Requiring a consumer hangtag that includes emissions, efficiency and BTU output as measured by an independent 3rd party test lab.
• Strengthening the capacity of OECA (Office of Enforcement and Compliance Assurance) to expeditiously make more testing and other data transparent to the public and to states.
• Supporting the EPA to build a database of emission data using cord wood tests prior to finalizing the emission standard for cordwood in the rule.
Because this NSPS includes so many variables for both industry and the EPA, the Alliance urges the EPA to defer some regulations until the next NSPS, 8 years from now. This includes regulating fireplaces and treating the installation of pre-1988, uncertified stoves as “new sources” and only allowing the installation of certified stoves made after 1988.
To submit comments to the EPA, click here for details.