Clean Air Council Comments on Proposed Regulations for OWBs

On May 5, 2014, Clean Air Council submitted joint comments with Environmental Defense Fund and Hoosier Environmental Council on EPA’s rule proposing new source performance standards for residential wood heaters.  Current EPA standards for new wood heaters were issued in 1988 and have remained unchanged despite the Clean Air Act requirement that EPA review, and if appropriate, revise standards every 8 years.  More protective standards are more than 18 years overdue.  The current outdated standards do not cover hydronic heaters and furnaces (also known as outdoor wood-fired boilers and furnaces) as well as many other types of wood stoves.  Modern wood stoves, furnaces, and hydronic heaters are capable of achieving much lower emissions and higher efficiencies than current standards require, meaning new stoves can provide significant health and economic benefits to families across the nation.  The Council’s comments requested, generally, that EPA finalize more protective standards.  More specifically, the comments:

  • Examine the harmful impact of wood smoke on communities across the nation;
  • Highlight the tremendous health and economic benefits of the proposed rule;
  • Support the broad application of health-protective standards to furnaces, hydronic heaters and previously unregulated wood stoves;
  • Request that the proposed 2015 “Step 1” emission standards for wood stoves be made more protective by ensuring that certification extensions are not granted to high-polluting wood stoves;
  • Urge EPA to finalize the more protective proposed “Step 2” standards for new wood stoves, and require earlier compliance with those standards;
  • Urge EPA to finalize proposed Step 1 and Step 2 standards for new  hydronic heaters and forced-air furnaces, but require earlier compliance with Step 2 and include time-based emission standards for Step 2 units;
  • Support many of the improvements EPA has proposed in the test methods for these devises;
  • Recommend additional steps to ensure the integrity of compliance certification procedures;
  • Request EPA continue to require temporary hangtags for all new devices covered by this rule to help consumers make informed decisions about energy savings and public health; and
  • Respond to EPA’s request for comment on visible emission limitation

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