October 30, 2012 

## LAKE MICHIGAN AIR 

## DIRECTORS CONSORTIUM 9501 W. Devon Avenue, Suite 701 Rosemont, IL 60018 Phone: 847-720-7880· Fax: 847-720-7891

Honorable Lisa P. Jackson, Administrator U.S. Environmental Protection Agency Mail Code: 6102T 1200 Pennsylvania Avenue, N.W. Washington, DC 20460

Re: New Source Performance Standard for Residential Wood Burning Devices

Dear Administrator Jackson: On behalfofthe Lake Michigan Air Directors Consortium (LADCO), we are writing to urge EPA to expeditiouslypromulgate an update to the New Source Performance Standard (NSPS) for Residential Wood Burning Devices. With EPA'srecent proposal to strengthenthe national ambient air quality standard for fine patiiculate matter, updatingthis performance standard to reflect best demonstrated emission controls and broadeningthe standard to address devices that
are not included inthe current NSPS is nowmore impOliant than ever.

Wood is a domestic renewable energy resource for home heating, and as such can be an impOliant pati ofa state's pOlifolio ofrenewable energy alternatives. With inadequate controls, however, wood burning can emit high levels offine patiiculate and air toxics, potentially endangering public health. Overthe 20-plus years since EPApromulgated the NSPS for Residential Wood Burning Devices, improved technologies to limit emissions from these devices have been developed and demonstrated. Many manufacturers have been building wood heaters with emissionrates far belowEPA's current standards, and have for many years. Consistentwith Section 111 ofthe Clean Air Act, we urge EPA to move forward with a revision to theNSPS that reflects the best system ofemission reduction that has been adequately demonstrated. Moreover, EPA should examine the testing methods used to determine compliance withthe standards, and revise the methods as appropriate and necessaryto accurately determine emissionperformance. Both strong emissions standards and an accurate emissions test method are essential to the continued credibility ofEPA's wood heater certification program.

In summary, an update to the NSPS for Residential Wood Burning Devices is long overdue. EPA's latestproposal for a more stringent fine particulate air quality standard effectively identifies the public health impacts from fine particulate matter at concentrations far lowerthanthe levels contemplated in 1988, whenthis NSPS was first promulgated. We will continue to work with EPA onthis important effort to update the NSPS inthe coming months knowing that the alternative is for state and local agencies to undetiake rulemaking ontheir own, faced with many ofthe same challenges that EPA faces but without'EPA's resources or expetiise. Accordingly, it is EPA'sresponsibility to expeditiously promulgate newperfOlmance standards for woodheaters that encompass the full range ofwood heating devices in use today, and that reflect the best demonstratedtechnologies.

Sincerely,

John J. Kim, Interim Director Illinois Environmental Protection Agency

Dan Wyant Director Michigan Department ofEnvironmental Quality

ScottJ. Nally Director Ohio Environmental Protection Agency Thomas Easterly Commissioner Indiana Depmiment ofEnvironmental Management

John Linc Stine Commissioner Minnesota Pollution Control Agency

Cathy Stepp Secretary Wisconsin DepmimentofNatural Resources