### 6/8/10—For Preliminary Discussions with Small Entit y Representatives Only.

Do not distribute, quote or cite.

1 Revision of New Source Performance Standards for Wo od Stoves, other Residential Solid Biomass Combustion Devices, and Coal Stoves Under Section 1 11(b)(1)(B) of the Clean Air Act

Description of the Proposals under Consideration

• EPA intends to revise the “Standards of Performance for New Residential Wood Heaters” (codified at 40 CFR Part 60, Subpart AAA) that were promulgated on February 26, 1988. EPA intends to tighten the emission limits and add standards for additional de vices. EPA also intends to revise the source catego ry list and develop parallel standards in new subparts for clarity and to avoid unintended consequences.

• Like the 1988 rule, the revisions would require man ufacturers of new devices to design appliances to meet particulate matter emission limits (principall y PM 2.5 ), have representative model lines be tested by independent, accredited labs, and attach EPA labels and hangtags after EPA approval.

• Manufacturers of these devices would comply with th e standards by applying Best Demonstrated Technology (BDT), primarily by improving combustion and heat transfer efficiency. Some manufacturers may chose to utilize add-on control technology such as catalysts and electrostatic precipitators to supplement combustion improvements.
Types of Residential Combustion Devices for Proposa ls under Consideration

• Wood Stoves

• Pellet Stoves

• Cook stoves, camp stoves, single-burn-rate applianc es

• Other solid biomass stoves (e.g., stoves that burn shelled corn, switchgrass, cherry pits)

• Masonry heaters

• Masonry fireplaces constructed on site

• Factory-built fireplaces

• Outdoor stoves and fireplaces (e.g., bake ovens, ch imineas)

• Outdoor hydronic heaters (aka outdoor wood boilers)

• Indoor hydronic heaters

• Forced-air furnaces

• Coal stoves and heaters
Potential Requirements of Proposals under Considera tion

• Tighten emission limits to reflect today’s BDT

• Close “loopholes”, eliminate exemptions (e.g., cook stoves)

• Add pellet stoves explicitly

• Add wood hydronic heaters and furnaces

• Revise test methods, as appropriate

• Streamline certification process and incorporate In ternational Standards Organization (ISO) process pl us compliance affirmation

• Improve compliance assurance and enforceability

• Regulate fireplaces

• Regulate devices fueled by other solid biomass, e.g ., corn, various pelletized biomass

• Regulate coal-fired stoves and heaters to level the playing field

• Require compliance tests on “worst” grade of each t ype of pellet that manufacturer specifies for use

• Require Federal rules on pellet quality if adequate industry standards are not in place in time

### 6/8/10—For Preliminary Discussions with Small Entit y Representatives Only.

Do not distribute, quote or cite.

2 Regulatory Flexibility Options for Small Entities

• Since most companies are small businesses, EPA will carefully consider all options.

• Current NSPS gave additional time for initial compl iance for small volume manufacturers – we expect to do that again.

• Current NSPS allows manufacturers to show complianc e by model lines rather than testing each source – we expect to continue that approach to reduce costs

. • As EPA transitions to an ISO-accredited lab approac h, we expect to give additional time to small labs that have experience as EPA-accredited labs.

• For masonry heaters and site-built masonry fireplac es, we are working with the companies to consider a 2-prong NSPS that allows use of previously approved equipment standard options in lieu of testing each new model line.

• For single-burn appliances, we are working with the companies to consider appropriate modifications to the test method.

• For “traditional North American cook stoves” and “c amp stoves”, we are working with the companies to consider definitions/equipment standards to reduce impacts.

• For “traditional Native American bake ovens”, we ar e working with Tribes to develop a definition that will likely exclude such devices.

• For indoor and outdoor hydronic heaters and forced air furnaces, we are working with industry to consider appropriate modifications to the test meth od to consider more flexibility in heat storage opt ions and burn rate options.
Impacts of the Proposed Actions

• The potential benefits for reducing wood smoke emis sions are very large and are expected to be much larger than the costs of compliance with the propos ed actions.

• Impacts of the proposed action will be more specifi c after additional emissions data are analyzed and regulatory options are clearer.

• For perspective, the overall benefits for wood resi dential wood smoke emission reductions are approximately $500,000/ton of PM2.5 emissions reduc ed (actual values vary by location).

• For example, the benefits of changing out all the o ld wood stoves in the U.S. to current NSPS level appliances are $35 billion to $86 billion per year.

• This is based principally on reductions in mortalit y, non-fatal heart attacks, and chronic bronchitis.

• The vast majority of the manufacturers that would b e subject to this rule are small businesses with mu ch, much fewer than 500 employees.

• We estimate that ____ manufacturers of wood stoves and ____ manufacturers of pellet stoves would be subject to the proposed rule. ( information still pending )

• We estimate that ____ manufacturers of hydronic hea ters and ____ manufacturers of factory-built fireplaces would be subject to the proposed rule. ( information still pending )

• EPA believes that greater emissions reductions can be achieved by operating cleaner solid biomass combustion devices, which can help areas of the cou ntry attain or maintain the ambient PM2.5 national air quality standard.
Background

• The development of the wood heater regulations bega n in the mid-1980’s in response to the growing concern that wood smoke contributes to ambient air quality-related health problems.

• Wood smoke contains fine particulates (PM2.5) and a lso contains other criteria pollutants, persistent bioaccumulative air toxics, other air toxics, and g reenhouse gases. Organic carbon is emitted from thi s source category along with elemental carbon.

### 6/8/10—For Preliminary Discussions with Small Entit y Representatives Only.

Do not distribute, quote or cite.

3 • Section 111 of the Clean Air Act (CAA), "Standards of Performance for New Stationary Sources," requires EPA to establish federal standards of perf ormance for new sources for source categories which cause or contribute significantly to air pollution, and which may reasonably be anticipated to endange r public health or welfare.

• Section 111(b)(1)(B) of the CAA mandates that EPA r eview and, if appropriate, revise existing NSPS at least every 8 years. “Standards of Performance for New Residential Wood Heaters” (codified at 40 CFR Part 60, Subpart AAA) were promulgated on February 26, 1988.

• In response to numerous States’ concerns about the contribution of wood smoke emissions to high PM 2.5 ambient concentrations and their requests to update and develop regulations relating to a variety of w ood combustion devices, EPA conducted an extensive revi ew of the current NSPS.

• States, environmental groups, and the Hearth, Patio and Barbecue Association (HPBA) have also recommended changes to the NSPS. These stakeholder s suggested that more recent information and technologies justify that the review and revision o f the 1988 residential wood heater NSPS are needed to capture the improvements in performance of such uni ts. Also, many of these stakeholders have encouraged EPA to develop additional NSPS for regul ating other residential wood-combustion devices, as well as residential devices that burn other fuel s, which are in the U.S. market and/or available ab road and which are expected to be imported soon.

• Based on the review of the current NSPS, EPA conclu ded that revision of the standards is necessary to reflect improvements in methods for reducing emissi ons. In 2011 EPA anticipates proposing revisions t o the standards for new residential wood combustion d evices and additional regulations for new residenti al devices that burn other fuels.

Status and Proposal Schedule

• EPA is actively reviewing test methods, including e fficiency test methods and discussions with HPBA on emissions averaging (burn rate weighti ngs), low burn rate, number of runs, time for hot start, caps, degradation, etc.

• No court-ordered deadline applies to this proposal under consideration.

• Complete Regulatory Impacts Analysis by September 3 0, 2010.

• Conduct Options Selection with Assistant Administra tor by December 1, 2010.

• Conduct Final Agency Review—January 15-February 15, 2011.

• Publish proposed NSPS Revisions and Related New Sta ndards—June 15, 2011

• Publish final NSPS Revisions and Related New Standa rds—July 2012