Summary and Location of Requests for Comments and Data in Proposed Standards of Performance for New Residential 

Wood Heaters, New Residential Hydronic Heaters and Forced-Air Furnaces, and New Residential Masonry Heaters

Category Section of 

Preamble

Request for comments and data on... FR 

Page

1 Everything All all aspects of the proposal, including those not requested specifically. All

Executive Summary

2 Certification 

Program, Quality

Assurance and 

Audits 

I.A.2, 

III.A

use of a certification program that tests a representative heater per model line, a 

quality assurance program to ensure that all heaters within the model line conform 

to the certified design and meet the applicable emission limits, and EPA audits to 

ensure compliance.

6332, 

6340

3 Emission and Sales 

Data for Masonry

Heaters

I.A.2 emission and projected sales data per model to help us prepare emission reduction 

estimates and corresponding monetized benefits estimates for masonry heaters.

6333

Room Heaters (e.g., wood stoves, pellet stoves, single burn rates stoves)

4 Transition Period for 

Step 1 for Currently 

Certified Models

III.A the length of the proposed transition and the degree to which there would be any 

critical economic impacts on manufacturers who have heaters with current 

certifications if we were to not allow up to the full 5-year certification period for 

units manufactured after the effective date of the final rule. 

6339

5 Grandfathering of 

Step 1 Models 

Tested According to 

the Proposal

III.A allowing grandfathering of Step 1 models that are tested in good faith according to 

the proposed test methods and the proposed emission limits, even though the final 

test methods may differ from this proposal, and if so, for how long.

6339

6 Proposed Two-step 

Approach

III.A the proposed two-step approach that would require Step 1 upon the effective date of 

the final rule and Step 2 in 5 years... and the degree to which these dates could be 

sooner.

6339

7 Three-step Approach III.A a three-step approach that would require Step 1 upon the effective date, Step 2 in 5 

years and Step 3 in 8 years. [Step 2 of the two-step approach and Step 3 of the 

three-step approach would be the same emission level.] We specifically ask for data 

6339
and potential environmental and economic impacts, and the degree to which the

emission levels and dates could be considered best systems of emission reduction.

8 Compliance 

Extension for Lowvolume Single Burn 

Rate Heaters

III.A the possible need for a compliance extension for single burn rate wood heaters, 

which are not subject to the current subpart AAA requirements.

6340

9 Efficiency Standards III.A the need for efficiency standards and data to support the level. 6340

10 Cord Wood 

Emission Test Data

III.A emission test data to compare heater performance with crib wood and cord wood. 6340

11 CO Emissions III.A emission and cost data for systems that reduce CO emissions. 6340

12 CO Indoor Monitors III.A whether the rule should require indoor CO monitors as a critical safety component 

for heaters installed in occupied buildings or other buildings or enclosures in which 

the operator would enter to add fuel to the heater or conduct other normal operation 

and maintenance of the heater.

6340

13 Transition to 

Addition of 

Certifying Body

Process

III.A whether the rule should allow a transition period for adding the requirement for a 

certifying body process prior to the EPA Administrator approval for the first year 

following the effective date of the final rule.

6340

14 Truth in Marketing III.A how to best assure that manufacturers and retailers and online marketers of wood 

heaters explain the relative benefits of high-performing heaters versus lowerperforming wood heaters and only use valid certification test data and not 

exaggerated claims.

6340, 

6341

15 Temporary Labels III.A the potential impact that removing the requirement for temporary labels on certified 

heaters might have on a consumer’s ability to select wood heaters that meet the 

proposed standards and are the cleanest and most efficient versus obtaining that 

information at the EPA website: 

http://www.epa.gov/compliance/monitoring/programs/caa/woodheaters.html

6341

16 Voluntary Labeling 

Program for the 

Cleanest of the 

Clean

III.A whether we should consider developing a voluntary labeling program for the 

cleanest of the clean (in addition to the NSPS).

6341

17 Pellet Fuel 

Certification 

III.A (a) whether another high quality program exists other than the Pellet Fuels Institute 

(PFI) program. Details of the PFI program are available at 

6341
Program http://pelletheat.org/pfi-standards/pfi-standards-program/.

(b) how to determine equivalency for fuel pellets

18 Proper Operation III.A whether we should include additional best burn practices to help ensure proper 

operation, e.g., chimney height and draft specifications, moisture content and limits 

on visible emissions.

6342

19 Test Methods III.A substance of and additional potential improvements to ASTM test methods or other 

test methods.

6341, 

6342

20 ASTM Process III.A the ASTM Intellectual Property Policy and its hindrance to full consensus process 

and ways to ameliorate the process concerns.

6342

Central Heaters (e.g., forced-air furnaces and hydronic heaters, aka, indoor 

and outdoor wood boilers)

21 Proposed Two-step 

Approach

III.B the proposed two-step approach that would require Step 1 upon the effective date of 

the final rule and Step 2 in 5 years... and the degree to which these dates could be 

sooner.

6343

22 Three-step Approach III.B a three-step approach that would require Step 1 upon the effective date, Step 2 in 5 

years and Step 3 in 8 years. [Step 2 of the two-step approach and Step 3 of the 

three-step approach would be the same emission level.] We specifically ask for data 

and potential environmental and economic impacts, and the degree to which the

emission levels and dates could be considered best systems of emission reduction.

6343

23 Efficiency Standards III.B the need for efficiency standards and data to support the level. 6343

24 CO Emissions III.B emission and cost data for systems that reduce CO emissions. 6343

25 Visible Emissions, 

Heating Season, etc. 

III.B appropriateness of limits on visible emissions and limits on use in non-heating 

seasons and other requirements that should be included in this NSPS.

6343

26 Timing III.B the timing for implementation 6344

27 Prohibited Fuels III.B list of prohibited fuels because their use would cause poor combustion or even 

hazardous conditions... and data to support additional requirements, if warranted.

6344

28 Pellet Fuel 

Certification 

Program

III.B the use of the PFI program and the PFI specifications, especially the degree to 

which the PFI program will adequately ensure the absence of construction and 

demolition waste (and associated toxic contaminants) in the pellets.

6344

29 Permanent Label, III.B ways to improve the delivery of information on the permanent label and in the 6344
Owner’s Manual, 

Information for 

Consumers and 

Regulatory

Authorities

owner’s manual and whether different information might be useful to the consumer 

and to the regulatory authorities.

30 Certification and 

Quality Assurance 

Process

III.B changes or improvements that might be needed to address any special concerns 

related to the certification of hydronic heaters and forced-air furnaces.

6344

31 HH Test Methods III.B all aspects of the test methods, especially specific comments and data on the use of: 

(1) one or more of the draft versions of Appendix X2 being considered as part of 

ASTM work product WK26581; (2) the European Union test method EN303-05 as 

the Maine Department of Environmental Protection approved for certification of 

hydronic heaters in their state as equivalent to the EPA Method 28 WHH; (3) the 

partial thermal storage test method developed by Brookhaven National Laboratory; 

and/or (4) some other test method(s). Especially emission data that compares the 

results of the different test methods.

6345

32 Heat Storage Level III.B appropriateness of at least 60% or some other level. 6345

33 Moisture Content III.B moisture content limits, procedures for determining the moisture content and the 

typical variances due to the measurement procedures.

6346

34 Other HH Test 

Methods

III.B test methods for cribs, cord wood, real world, real-time, start-up, emission 

peaks/durations, field tests, less expensive methods for regulators and neighbors. 

6346

35 Forced-Air Furnace

Test Methods

III.B appropriateness of using of CSA B45.1-10 in its entirety, including use of cord 

wood.

6347 

Masonry Heaters

36 Masonry Heater Test 

Methods

III.B these methods and any changes that should be considered and supporting data for 

those changes. We request specific comments and supporting emission test data on 

the use of “Annex A1. Cordwood Fuel” and “Annex A2. Cribwood Fueling.” 

[ASTM is allowing public review, for no charge, of the ASTM test methods and 

draft work products relevant to this rule at www.astm.org/epa.]

6347

37 Masonry Heater QC 

& Certification 

III.B changes or improvements that might be needed to address special concerns related 

to certification of masonry heaters.

6347
Process 

Environmental, Cost, Economic, and Non-Air Health and Energy Impacts

38 Shipment 

Projections

IV.A data that would support improved projections. 6348

39 Masonry Heater 

Emission Estimates

IV.A to help us prepare emission estimates. 6348

40 Masonry Heater 

Emission Reductions 

and Benefits

IV.B emission and sales data per model that would help us prepare emission reduction 

estimates and corresponding monetized health benefits.

6349

41 Research and 

Development Costs

IV.C these estimates, including whether they should be reduced and thus allow greater 

emission reductions sooner.

6350

42 Unit Costs IV.C these estimates, which significantly affect the estimates of costs per model lines 

and per unit sold and potential changes in sales and, thus, affect decisions on the 

affordability of candidate BSER [Best Systems of Emission Reduction].

6351

Rationale for Proposed Amendments

43 Non-Wood Heaters, 

Non-Heaters 

V.A contributions to air quality, endangerment of public health and welfare, emissions, 

potential emission reductions, costs, prices, and sales of cook stoves, pizza ovens, 

chimineas, coal stoves and biomass (other than wood or wood pellet) 

stoves/furnaces (e.g., fueled with grass, corn, cherry pits). Data that might help us 

potentially develop national programs or standards for these devices in the future.

6353

44 Fireplaces V.A contributions to air quality, endangerment of public health and welfare, emissions, 

potential emission reductions, costs, prices, and sales of fireplaces. We request data 

that might help us potentially develop new or revised national programs or a source 

category listing and standards under section 111(b) for these devices in the future.

We are especially interested in data on current and projected sales of new woodburning fireplaces versus gas-fired fireplaces, current and projected usage patterns 

for new fireplaces versus existing fireplaces, current and projected quantities of 

wood burned per existing and new fireplaces, current and projected best systems of 

6353
emission reduction for new fireplaces versus existing fireplaces and costs of current 

and projected best systems versus current costs of fireplaces. Also, we are 

interested in national data and how these data vary by state and local areas.

45 Determination of 

Best Systems of 

Emission Reduction

[BSER] and 

Proposed Emission 

Levels

V.B analyses on which we base the proposed standards. Moreover, the EPA invites 

specific comments that provide additional data and analyses that would support a 

different standard. Interested persons should note that the EPA will consider 

promulgating a more stringent or less stringent standard than what we are 

proposing for any of these categories, if the record contains data or analyses that 

support a different standard.

6354

46 Cord Wood Level in 

AAA

V.B.1.a emission test data using cord wood to help us determine if the proposed emission 

levels should be adjusted for any differences between crib wood and cord wood 

[for adjustable burn rate stoves].

6355, 

6356

47 Backsliding for 

Catalytic Stoves

V.B.1.a whether we should maintain a separate, lower limit for catalytic heater models for 

the proposed Step 1 emission limits, based on the current state of Washington 

catalytic standard of 2.5 g/hr.

6356

48 Three-Step 

Approach for AAA

V.B.1.b whether we should allow a longer approach that is implemented in 3 steps over 8 

years instead of the preferred approach of 2 steps over 5 years. 

6357

49 Single Burn Rate 

Stove Research and 

Development 

V.B.1.c emissions and R&D assumptions. 6357

50 Two-Step Approach 

in QQQQ for HH 

V.B.2.a on this determination that this approach is reasonable and the degree to which other 

options would be appropriate.

6359

51 Cord Wood Level in 

QQQQ for HH

V.B.2.a emission test data using cord wood and different test methods to help us determine 

if the proposed emission levels should be adjusted for any differences in test 

methods and test fuels, e.g., crib wood and cord wood [for hydronic heaters].

6359

52 Three-Step 

Approach for HH

V.B.2.a whether we should allow a longer approach that is implemented in 3 steps over 8 

years instead of the preferred approach of 2 steps over 5 years.

6360

53 Emission Levels and 

Compliance 

Deadlines for 

Forced-air Furnaces

V.B.2.b the proposed emission levels and compliance deadlines, as well as the 

environmental impacts and market implications for setting emission limits that 

match what we are proposing for hydronic heaters.

6361

54 Three-Step 

Approach for 

V.B.2.b whether we should allow a longer approach that is implemented in 3 steps over 8 

years instead of the preferred approach of 2 steps over 5 years.

6361
Forced-Air Furnaces

55 Format of Standard 

for Masonry Heaters

V.B.3.c whether a g/kg format would be better than lbs/million BTU heat output 6361

56 Level of Standard 

for Masonry Heaters

V.B.3.c proposed BSER and whether there are additional alternatives. For example, if we 

were to develop a g/hr average format in addition to the lb/MMBtu heat output 

format, are there products that might meet a daily average over the heating period 

versus the averaging only over the combustion period, and if so, how would this 

affect levels of performance and impacts on the environment?

6362

57 Compliance

Deadline for 

Masonry Heaters

V.B.3.c the degree to which the dates could be sooner. 6362

58 Alternative 

Approach

V.B.4 whether the final rule should be our (preferred) proposed two-step approach or 

whether the final rule should be this alternative three-step approach. We do not 

intend for the final rule to allow a choice between the two approaches.

6362

59 Compliance 

Extension for SmallVolume Masonry

Heater 

Manufacturers

V.B.4 we did not develop a three-step approach for masonry heaters under subpart RRRR, 

since it is a one-emission-level standard, but we are seeking comments on our 

proposed 5-year compliance extension for small volume masonry heater 

manufacturers.

6362

60 Alternative 

Approach

V.B.4 potential justifications for implementing a three-step standard, instead of our 

proposed two-step standard for each of the appliances affected by this proposed 

rule, to provide additional flexibility for manufacturers that have different 

capabilities and resources to ultimately reach the most stringent BSER.

6362

61 Alternative 

Approach -- Step 2

V.B.4 data and potential environmental and economic justifications, on whether the 

described Alternative Approach Step 2 emission limits represent BSER within 3 

years of the effective date of the final rule. We also seek comment on whether an 

additional 5 years would be necessary to transition from the Alternative Approach 

Step 2 to the Alternative Approach Step 3 limit, or whether such a transition could 

be made in a shorter time period

6363

62 Alternative 

Approach – Step 1 

V.B.4 whether the alternative Step 1 limit should become effective upon the effective date 

of the final rule or after a 1-year “adjustment” period [for single burn rate wood 

heaters and forced-air furnaces].

6363

63 Alternative V.B.4 balancing industry’s R&D needs with timely and efficient standards. 6363
Approach

64 Efficiency V.B.5.a supporting data that would help inform the need for and level of a possible 

efficiency standard. Also, we ask for specific comments on how, in the meantime, 

to best ensure consumers have access to the best information on efficiency

performance, e.g., labels, owner’s manual, Burn Wise website and/or other means.

6363

65 Carbon Monoxide 

(CO) Standards

V.B.5.b supporting data on the need for and level of a possible CO emissions standard. 6363

66 CO Monitors V.B.5.b whether we should require CO monitors to help ensure proper operation of the 

heater and to reduce health and safety concerns for appliances that are installed in 

occupied areas

6363

67 Pellet Fuel

Requirements

V.B.5.c decision that the Pellet Fuel Institute (PFI) program is a good program that obviates 

the need for the EPA to develop our own program at this time. We ask for specific 

comments on this decision and the details of the PFI program.

6364

68 Proper Operation V.B.5.d whether we should include more specific requirements on proper operations, such 

as the moisture content of the wood and visible emission limits.

6364

69 Compliance 

Deadlines

V.C whether we should have a cap on the total units sold in the 5 years, perhaps 50 units 

[for small-volume masonry heater manufacturers].

6365

70 Compliance 

Deadlines

V.C the need for either a compliance date extension or a compliance date exemption for 

masonry heaters and the length of time that we should allow.

6365

71 Compliance 

Deadlines

V.C the need for a compliance date extension for small volume manufacturers of 

adjustable burn rate stoves, pellet stoves, or single burn rate stoves.

6365

72 Compliance 

Deadlines

V.C the need for a compliance date extension for small volume manufacturers of 

hydronic heaters or forced air furnaces, and if so, what number of appliances sold 

would constitute a small volume manufacturer.

6365

73 Compliance 

Deadlines

V.C need for logjam provisions in case ISO-accredited laboratories and ISO-accredited 

certifying bodies and EPA cannot process the large number of certification 

applications in a timely manner.

6366

74 Compliance 

Deadlines

V.C whether these compliance timelines strike the right balance between avoiding 

undue economic burdens and the need to get better performing models on the 

market as soon as possible to reduce emissions, and whether other compliance 

dates would be appropriate.

6366

75 Streamlining V.D The “k” list of design changes and tolerances which are presumed to affect 

emissions and thus trigger a new certification test. 

6366
76 Streamlining V.D exact event(s) that should be used as the trigger(s) to retest and whether the 

triggering event(s) should vary by appliance type.

6366

77 Test Methods V.E all test method related issues and any data supporting such issues or concerns. 6367

78 Administrative 

Requirements

V.F replacing the current subpart AAA hearing and appeal procedures with a 

streamlined Petition for Review process and also using this process in subparts 

QQQQ and RRRR. [This process would allow accredited laboratories and 

manufacturers to contest audit test findings, laboratory accreditations, certification 

denials, and certification revocations by submitting a written request and 

supporting documentation to the EPA. This process would allow for expedited 

review and resolution.] We request specific comments on this proposed process and 

other ways to improve or streamline procedures while preserving the integrity of 

the program.

6367

Statutory and Executive Order Reviews

79 Paperwork 

Reduction Act

VI.B need for this information, the accuracy of the provided burden estimates, and any

suggested methods for minimizing respondent burden. Commentors should submit 

their comments to both the EPA docket for this rulemaking [Docket ID number 

EPA-HQ-OAR-2009-0734] and to OMB at the Office of Information and 

Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Office for EPA.

6368

80 Regulatory

Flexibility Act

VI.C the Small Business Advocacy Review Panel final report [included in the docket for 

this proposed rule]. We invite comments on the report and on all aspects of the 

proposal and its impacts on small entities.

6371

81 Executive Order 

13175: Consultation 

and Coordination 

with Indian Tribal 

Governments 

VI.F The EPA specifically solicits additional comment on this proposed action from 

tribal officials.

6372

82 Executive Order 

13045, “Protection 

of Children from 

Environmental 

VI.G The public is invited to submit comments or identify peer-reviewed studies and 

data that assess effects of early life exposure to smoke from residential wood 

heaters.

6372
Health Risks and 

Safety Risks”

83 National Technology

Transfer and 

Advancement Act of 

1995 (NTTAA)

VI.I We invite the public to identify potentially applicable voluntary consensus 

standards and to explain why such standards, in whole or in part, should or should 

not be used in this regulation.

6373