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  The current outdated standards do not cover hydronic heaters and furnaces (also known as outdoor wood-fired boilers and furnaces) as well as many other types of wood stoves.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

Biomass Facilities

Excerpt

“Biomass energy is growing in importance because of a desire to move away from fossil fuels and toward renewable sources of energy and energy independence. Also, alternative energy portfolio standards requiring energy companies to use alternative sources for a percentage of the energy they sell are encouraging industry to invest in biomass. Biomass energy is listed as a Tier I alternative energy source in Pennsylvania.1 The other Tier I alternative energy sources in the Alternative Energy Portfolio Standards Act (AEPS) are solar photo-voltaic and solar thermal energy, wind power, low-impact hydro-power, geothermal energy, biologically derived methane gas, fuel cells, and coal mine methane.2 The act requires that at least 8 percent of the electric energy sold by an electric distribution company or electric generation supplier to retail electric customers in the Commonwealth must be generated from Tier I alternative energy sources by 2020.

“Biomass is enticing because of the promise of carbon neutrality. The idea is that carbon emissions from biomass are offset by the prior absorption of carbon through photosynthesis, and the carbon will be reabsorbed when new biomass is grown. However, this carbon cycle would take place over many years because of the time needed to plant and grow new sources. It is also possible that biomass might be harvested at unsustainable rates and produce air pollution and net greenhouse gas emissions.”

Click here or on the image below to download the entire paper on biomass facilities and their potential impact.

ISeeSmoke.BiomassImpact

Health Impacts of Wood Smoke

Many people don’t think of wood smoke as a major health or environmental concern, but the truth is quite the opposite.  Wood smoke contains many harmful carcinogens in addition to sulfur, mercury, nitrogen-oxides, and carbon-dioxide.  Soot and ash are additional problems as they can work their way deep into lung tissue.  All totaled, one wood stove or boiler can have thousands of times the emissions of one using natural gas – contributing greatly to health and environmental degradation.

One of the principal problems with wood-burning is that the impacts are often local.  Wood smoke is released close to the ground from low chimneys or smoke stacks, where the soot and toxins mix with the ambient air.  This are is then breathed in by local residents, causing new medical conditions and aggravating existing ones.

Washington State has put together an informational booklet about wood-smoke, available here, that goes into greater detail about its impacts on health and the environment, best practices, and what you can do in your community.  Also check out our resource page for more information on biomass and the impacts of wood-smoke.