Alliance for Inexperienced Heat
Feedback on the
July 1, 2014 Discover of Data Availability
Concerning EPA’s Proposed Expectations of Overall performance for New Residential Wood Heaters, New Residential Hydronic Heaters and Pressured-Air Furnaces, and New Household Masonry Heaters
Docket ID No. EPA-HQ-OAR-2009-0734
July 31, 2014
The Alliance for Inexperienced Heat (Alliance), appreciates the opportunity to comment on EPA’s July 1, 2014 Notice of Information Availability (NODA) concerning the agency’s proposed New Source Performance Standards (NSPS) for wood heating gadgets.[one]  The Alliance is an impartial non-earnings group that works with environmental and forestry corporations, air good quality experts, the wood and pellet stove sector, and other individuals in the wooden burning neighborhood to market high-efficiency wooden combustion as a reduced-carbon, sustainable, nearby and affordable heating solution.  The Clean Air Act needs EPA to assessment and revise, if appropriate, the NSPS at minimum each 8 a long time.  As we explain in the original comments we submitted on the Proposed Rule, the Alliance strongly supports EPA’s decision to update the expectations for wooden stoves and to need a variety of beforehand unregulated wooden heating units to decrease their emissions.  We also feel that the new expectations, which replicate considerable enhancements in wood heating technologies, are each acceptable and long overdue.  We offer the subsequent extra remarks in reaction to EPA’s July 1, 2014 NODA.
1st and most importantly, it is essential that, heading ahead, all stoves be essential to comprehensive a take a look at at the most affordable achievable burn up fee placing.  The knowledge released in the NODA supplied a vital perception that couple of people know: 80% of non-catalytic stoves can’t be effectively tested at the Class one melt away charge (.8 kg/h or less).  Under the present EPA check approach, Approach 28, these stoves have been authorized to take a look at at the increased Category 2 burn off price, as extended as they can successfully full a take a look at at one. kg/h or less in Category 2.
The possibility of staying away from testing a stove at the least expensive melt away rate—which is when emissions of PM and other toxics are usually the highest—has seemingly developed a loophole that has incentivized some companies to style their stoves so that they fail to hold a flame for a enough volume of time in Class 1, so that they can be tested at the less difficult-to-meet 1. kg/h burn up rate in Class two.
If EPA finalizes its proposal to certify stoves based on only the optimum and least expensive burn off charges[two], this prospective loophole could turn into even more critical.  EPA should make clear in the ultimate rule that all stoves qualified underneath the new NSPS must be capable of being analyzed at their lowest burn charge, and that stoves that are not able to successfully complete a check melt away at their least expensive charge will no for a longer time be eligible for certification.
This will still permit stoves to be analyzed at one kg/h but assures that the consumer can’t work the stove at a decrease burn up price.  We are not opposed to permitting stoves to use a bare minimum burn off price of up to 1.fifteen for cordwood screening, but yet again, they must be productively analyzed at their cheapest melt away price.  Normally, the proposal to increase the minimum to 1.fifteen kg/h could just enlarge the loophole of stoves tests at higher burn costs than shoppers could run them.
Second, it has turn out to be abundantly distinct in recent months that more and far more producers are using the K listing to make minimal changes in their stoves to ensure five much more several years of sales daily life prior to retesting.  While the K checklist supplies an critical perform, it is now currently being utilized to drastically hold off retesting of what could be a greater part of EPA certified stoves.  1 of the final results of this is that manufacturers can keep away from testing at their least expensive melt away charge and avoid releasing their efficiency data till 2019 for a lot of or most or in some cases, all of their stoves. For this reason, we yet again urge the EPA to demand that B415.one effectiveness numbers using HHV be submitted to the EPA inside of six months of promulgation.
The information released in the NODA confirmed prior info sets, that the performance range of pellet stoves is considerably broader than wooden stoves.  These certified pellet stoves ranged from 62 to eighty% effective with a common deviation of eight.5, double the common deviation of non-cats and four instances the deviation of cat stoves.  Since of this extensive variation of efficiencies, it is in the general public curiosity to demand efficiencies be introduced as shortly as practicable.  Manufacturers presently have performance info for most or all of their stoves so there would not be any substantial stress to them.
In addition, we be aware that the information presented in the NODA seems to set up that an emission charge of one.three g/h is currently being attained by some resources in the source group employing twine wooden.  The Alliance proceeds to assist EPA’s proposed strategy of permitting stoves to be licensed with possibly crib wooden or wire wooden throughout the first phase of the NSPS, and to need certification with cordwood thereafter.  In addition, the Alliance suggests that EPA keep on to gather take a look at info on wire wood emission prices for non-catalytic stoves more than the following five several years and think about revisiting the emission limitations in the NSPS if extra info propose that the NSPS need to be adjusted for non-catalytic stoves.
Lastly, the Alliance has published a blog publish that addresses a variety of troubles related to the data introduced in the NODA.  We have appended this submit to these responses and request that EPA think about it together with our other responses as it finalizes the Proposed Rule.
/s/ John Ackerly
Alliance for Green Heat
Expectations of Efficiency for New Household Wooden Heaters, New Household Hydronic Heaters and Compelled-Air Furnaces, and New Household Masonry Heaters, Observe of Data Availability, 79 Fed. Reg. 37,259 (July 1, 2014) [hereinafter “NODA”].
[two]See Proposed Rule, seventy nine Fed. Reg. 6,329, six,367 (Feb. three, 2014).