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.
