At
a wood smoke conference at the University of Montana last month, the EPA did a presentation of
the status of the NSPS that included one slide that summarized
stakeholder comments on the NSPS. This
summary is the first one, to our knowledge, that gives some insight into how
the EPA views comments from stakeholders and which topics it regards as some of the
most important.The conference was a major gathering of wood smoke experts, air pollution agencies and a few representatives of wood stove manufacturers.
The
frequent reference to states infers that their views are playing a significant
role, along with industry. The multiple
references to “some manufacturers” indicate that they are paying attention to issues where industry is not united. The
reference to “electronic reporting” is about the move from paper to electronic
submissions of test and compliance data from the EPA approved test labs to the
EPA.
Larry
Brockman, who represents the EPA's voluntary wood heat programs, was at the Montana
conference and gave the presentation:
“*
Environmental/health organizations, almost all states, most of the public and
some manufacturers are very supportive.
* States oppose allowing the full 5 years for current certifications
at 1988 NSPS levels.
* Industry wants grandfathering plus sell-through of inventory.
* States want standards for visible emissions, right-sizing (energy
audits), hangtags and proper installation and operation.
* Industry and states want electronic reporting.
* Stakeholders agree that compliance test methods should use real
world conditions, e.g., cord wood but some manufacturers question the adequacy
of the current database.”
The
full EPA presentation and the other presentations at the conference can be
found on the EPA
website. For our summary of stakeholder comments to the NSPS, click here.
The conference sponsors included the University of Montana
Student Chapter of Air & Waste Management Association, Montana Department
of Environmental Quality, American Lung Association of the Mountain Pacific,
Missoula City-County Health Department, and the Center for Environmental Health
Sciences. For more about the conference.
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