The Alliance for Inexperienced Warmth is sharing its draft summary responses with all stakeholders to advertise transparency and dialogue and to solicit input on how we can enhance our feedback.  We also urge stakeholders to consider incorporating the points that you concur with, into your feedback.  Please truly feel cost-free to leave input or suggestions for the Alliance on this site or if you want them to continue to be personal, ship to firstname.lastname@example.org.  Comments have to be despatched to the EPA by Monday, Might five.
Alliance for Environmentally friendly Warmth
EPA’s Proposed Requirements of Overall performance for New Household Wood Heaters, New Household Hydronic Heaters and Pressured-Air Furnaces, and New Residential Masonry Heaters
Docket ID No. EPA-HQ-OAR-2009-0734
April 30, 2014
SUMMARY OF Remarks
The Alliance for Inexperienced Heat (Alliance), appreciates the possibility to remark on EPA’s proposed New Source Efficiency Standards (NSPS) for wooden heating devices.  The Alliance is an unbiased non-income business that operates with environmental and forestry corporations, air quality experts, the wood and pellet stove market, and other individuals in the wood burning community to market substantial-efficiency wood combustion as a low-carbon, sustainable, nearby and cost-effective heating resolution.  The Clear Air Act demands EPA to overview and revise, if suitable, the NSPS at least every 8 several years.  The Alliance strongly supports EPA’s decision to update the standards for wooden stoves and to require a number of formerly unregulated wood heating devices to reduce their emissions.  We also imagine that the new requirements, which replicate important advancements in wood heating technological innovation, are the two acceptable and extended-overdue.
We have numerous suggestions for bettering the proposed NSPS, which we outline below.
In our responses on the NSPS, we make the pursuing points:
Very first, it is important to understand that wood heating is renewable heating and should be acknowledged as this kind of by EPA.
·      2nd, the Alliance strongly supports EPA’s decision to problem revised overall performance requirements for wooden stoves and other wood and pellet heating appliances.
o   The Alliance supports EPA’s determination to shut existing loopholes and to include all main types of wooden-fired heating gadgets in the new performance expectations.  Beforehand exempted gadgets and units earlier mentioned Action One particular emission restrictions should not be “grandfathered.”
o   The Alliance supports a nine-month promote by way of for qualified stoves that emit greater than Step 1 emission expectations and a two-calendar year market by means of for boilers or furnaces that are EN303-5 accredited or EPA competent.
o   In the following NSPS, the Alliance urges the EPA to control uncertified, pre-1988 stoves as new resources if they are installed in a new spot.  Performing so will help to hasten the removal of the oldest, most polluting stoves from our airsheds.
o   In the up coming NSPS, the Alliance also urges EPA to control fireplaces.
·      3rd, the Alliance thinks that the proposed emission limitations, however affordable, could be more stringent for specific gadgets:
o   Data from at the moment licensed stoves look to justify a a lot more technologies-forcing, lower Action 1 performance normal for wooden stoves.
o   Pellet stoves are plainly able of conference a lower restrict for Stage One particular.  The bulk of pellet stoves accredited by EPA are currently emitting much less than 2.five grams for each hour (g/hr).
o   Forced air furnaces could attain a Step 1 emission restrict of .forty eight pounds per million BTUs (lbs/MMBTU), as an alternative of the proposed .93 lbs/MMBTU. A .forty eight common corresponds to the lbs ./MMBTU of a typical Washington accredited wooden stove.
o   In addition, despite the fact that we feel a .06 lbs/MMBTU Step Two standard for pellet boilers is justifiable, this limit may not be appropriate for wire wooden boilers, based on the take a look at technique.
·      Fourth, the Alliance strongly supports a shorter, 5-12 months implementation period of time for the NSPS.  This deadline is the two achievable and reasonable given the state of wooden heating technology these days.
·      Fifth, the Alliance believes that credible testing and enforcement are important parts of any New Resource Functionality Standard below the Clean Air Act (CAA).
o   The Alliance supports the proposed changeover to wire wooden screening, and phone calls on EPA to increase its cord wood tests software to get further information on the overall performance of present wooden stove versions making use of cord wooden prior to promulgation of the ultimate rule.  Alternatively, we urge the EPA to dedicate to re-analyzing the achievability of the Phase Two standards for stoves that have to be accredited on wire wood just before people requirements turn into successful.
o   The Alliance urges EPA to create a clearer route to certification for sophisticated systems like automatic stoves.  The Alliance is also inspired by ClearStak’s responses and urges EPA to consider some of the ahead-contemplating ideas put forth in those comments.
o   The Alliance supports EPA’s proposal to delegate some oversight and enforcement authority to the states, and urges EPA to increase the capacity of the Business office of Enforcement and Compliance Assurance (OECA) to aid make sure that point out enforcement packages are successful and that companies and merchants comply with the NSPS.
·      Sixth and last but not least, the Alliance believes that mandatory effectiveness expectations are needed. Better performance is specifically import to minimal-income wooden stove customers since it can decrease their heating expenses by demanding less fuel to warmth their houses.  Even so, the Alliance supports EPA’s decision to get much more data on wood stove effectiveness, with the knowing that future NSPS would set obligatory effectiveness standards.
o   The Alliance strongly supports a necessity to put up B415.one HHV effectiveness quantities on all wooden heating appliances on the marketplace inside of six months of the rule’s promulgation.  Versions that are EN 303-5 certified or certified by an EPA voluntary plan must be permitted to use HHV quantities till they turn into EPA accredited.
o   The Alliance opposes the elimination of the hangtag prerequisite and urges EPA to take into account extra consumer details resources this sort of as a Inexperienced Label and state incentives for shifting out old stoves and putting in the most effective new stoves.
o   The Alliance agrees that the two particulate subject (PM) and carbon monoxide (CO) emissions information, as properly as efficiency information, need to not be considered Confidential Business Info (CBI), and urges EPA to make emissions and effectiveness data about all four burn rates community on its site.
o   The Alliance urges EPA to right away start requiring producers and labs to scan and electronically post all paper info submissions, even as the company works to build a much more streamlined Electronic Reporting Tool (ERT).
o   Lastly, to stay away from deceptive shoppers further, EPA need to also remove the “default” emission element column from its posted listing of certified wooden stoves, and demand producers and merchants to stop employing these default factors in their promoting materials.
We appreciate your interest to our responses and appear ahead to operating with EPA to efficiently employ this crucial rule.  The full text of our comments is under.
Standards of Efficiency for New Residential Wood Heaters, New Residential Hydronic Heaters and Compelled-Air Furnaces, and New Residential Masonry Heaters, seventy nine Fed. Reg. 6,329 (Feb. 3, 2014) [hereinafter “Proposed Rule”].