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 behalf of the Lake Michigan Air Directors Consortium (LADCO), we are writing to urge 

EPA to expeditiously promulgate an update to the New Source Performance Standard (NSPS) 

for Residential Wood Burning Devices. With EPA's recent proposal to strengthen the national 

ambient air quality standard for fine patiiculate matter, updating this performance standard to 

reflect best demonstrated emission controls and broadening the standard to address devices that 

are not included in the current NSPS is now more impOliant than ever. 

Wood is a domestic renewable energy resource for home heating, and as such can be an 

impOliant pati of a state's pOlifolio of renewable energy alternatives. With inadequate controls, 

however, wood burning can emit high levels of fine patiiculate and air toxics, potentially 

endangering public health. Over the 20-plus years since EPA promulgated 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 emission rates far below EPA's current standards, and have for many years. Consistent with 

Section 111 of the Clean Air Act, we urge EPA to move forward with a revision to the NSPS that 

reflects the best system of emission reduction that has been adequately demonstrated. Moreover, 

EP A should examine the testing methods used to determine compliance with the standards, and 

revise the methods as appropriate and necessary to accurately determine emission performance. 

Both strong emissions standards and an accurate emissions test method are essential to the 

continued credibility of EPA's wood heater certification program. 

In summary, an update to the NSPS for Residential Wood Burning Devices is long overdue. 

EPA's latest proposal for a more stringent fine particulate air quality standard effectively 

identifies the public health impacts from fine particulate matter at concentrations far lower than 
the levels contemplated in 1988, when this NSPS was first promulgated. We will continue to 

work with EPA on this important effort to update the NSPS in the coming months knowing that 

the alternative is for state and local agencies to undetiake rulemaking on their own, faced with 

many of the same challenges that EPA faces but without 'EPA's resources or expetiise. 

Accordingly, it is EPA's responsibility to expeditiously promulgate new perfOlmance standards 

for wood heaters that encompass the full range of wood heating devices in use today, and that 

reflect the best demonstrated technologies. 

Sincerely, 

John J. Kim, 

Interim Director 

Illinois Environmental Protection Agency 

Dan Wyant 

Director 

Michigan Department of Environmental Quality 

Scott J. Nally 

Director 

Ohio Environmental Protection Agency 

Thomas Easterly 

Commissioner 

Indiana Depmiment of Environmental Management 

John Linc Stine 

Commissioner 

Minnesota Pollution Control Agency 

Cathy Stepp 

Secretary 

Wisconsin Depmimentof Natural Resources