Residential Wood Heaters

New Source Performance Standards (NSPS)

Proposal

EPA Air Toxics Risk Assessors Call

February 13, 2014

This presentation is a good faith effort to represent the proposal as signed 1/3/14.

Any differences are unintentional and do not supersede the official 2/3/14 FR proposal.

Please email comments on the proposal to the official docket at:

a-and-r-docket@epa.gov,

Attention Docket ID No. EPA-HQ-OAR-2009-0734
Current Schedule

► Proposal was signed by EPA Administrator on January 3, 2014

► The full proposal and fact sheets are available on-line at 

http://www2.epa.gov/residential-wood-heaters

► The proposal was published in Federal Register on February 3.

http://www.gpo.gov/fdsys/pkg/FR-2014-02-03/pdf/2014-00409.pdf

► There is a 90-day public comment period until May 5

► Opportunity to submit comments and data for EPA to consider

► Information on how to comment is on the website

► A public hearing will be held in Boston on February 26, 2014.

► Information on how to register is on the website.

► We will consider all comments and issue the final rule in 2015.

► States and environmental groups have sued to put us on a schedule

• Negotiations are ongoing. Likely will be ~1yr from proposal to final.

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Scope of the Rules

We are proposing three subparts as follows:

► Subpart AAA (for “room heaters”) revision

– Adjustable burn rate stoves

– Single-burn rate stoves

– Pellet stoves

► Subpart QQQQ (“central heaters”) new rule

– Outdoor and indoor hydronic heaters

– Forced-air furnaces

► Subpart RRRR new rule

– Masonry Heaters

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Summary of Proposal

► The 1988 NSPS requires manufacturers to design new residential wood heaters to 

meet particulate emission (PM) limits, have representative heaters (per model line) 

tested by an EPA-accredited lab, and attach EPA label after EPA approval.

► The proposal will update the 1988 NSPS to reflect today’s best systems of emission 

reduction, considering costs. These systems are ~80% cleaner and more efficient.

► The rule will affect models manufactured and sold after the rule is final.

► The rule will also establish new emission limits for types of heaters that have become 

popular after the 1988 NSPS was issued

► Step 1 emission limits will be required when the rule is final and tighter Step 2 limits 

will be required 5 years after the rule is final.

► Test methods will be revised to improve precision and better reflect the real world, 

e.g., use cord wood and consider peak, shorter-term emissions.

► The rule will also require testing and reporting efficiency and carbon monoxide.

► The projected monetized health benefits are far greater than the costs (>100:1).

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Not Covered

► Existing heaters currently in use in people’s homes1

► Outdoor fireplaces, pizza ovens, barbecues, fire pits, chimineas, traditional 

Native American bake ovens, ceremonial fires 

► Heaters fueled solely by oil, gas or coal (or other non-wood materials) 

► Proposal by itself would not ban certified devices or restrict hours of use.

► New indoor fireplaces 

► Not effective heaters (this NSPS is for "residential wood heaters”)

► However, EPA is taking comment

► Fireplaces are included in an EPA voluntary program that encourages 

manufacturers to make cleaner-burning fireplaces and retrofits available for 

consumers.

1 We refer to “Strategies for Reducing Residential Wood Smoke” on EPA’s 

Burn Wise website and note that it includes ideas for local regulations, 

voluntary programs, funding mechanisms and best burn practices - all of 

which can help reduce particle pollution from existing wood-burning 

appliances.

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Outreach

► We conducted extensive outreach as we developed the proposal, seeking input 

from numerous wood heater manufacturers, state, local and tribal governments, 

regional air quality agencies, and citizen and environmental groups.

► We also participated in a Small Business Advocacy Review Panel to seek input 

and advice. The preamble discusses the changes made to the proposal in 

response to the panel’s recommendations to reduce small business impacts as 

much possible while still meeting the legal requirements in the Clean Air Act.

► We will continue to work to address environmental and small business potential 

impacts throughout the process to get to the final rule.

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Room Heaters (Subpart AAA Proposed Revisions) 

► Adjustable burn-rate wood stoves (focus of 1988 NSPS)

► Proposal would strengthen existing emission limits in two steps over a five-year 

period

• Step 1 – similar to Washington State’s 1995 limit for non-catalytic stoves (most 

adjustable rate EPA-certified stoves already meet today)

– EPA-certified stoves can continue manufacturing/sales until current 

certification expires, up to a maximum of five years

• Step 2 – meet strengthened limits (see table)

► Single burn-rate wood stoves (NOT covered by 1988 NSPS)

► Would have to meet the same emission limits as adjustable burn-rate stoves

► Pellet stoves

► Would be explicitly included

• Pellet stoves are inadvertently exempted from 1988 NSPS if their air-to-fuel ratio 

is >35:1. Exemption was intended only for typical open fireplaces with high 

excess combustion air.

► Would have to meet same emission limits as adjustable burn rate heaters

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Room Heaters -- Proposed Emission Limits

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Manufacturers must use 3rd-party, independent, ISO-accredited and EPA-approved test 

laboratories and certifying entities to demonstrate compliance with a representative appliance for 

a model line.

Subpart AAA Appliances Phases / Steps PM Emission Limits

Heaters with current EPA 

certification issued prior to the 

effective date of the Final Rule

Transition period from 1988 

rule through the later of the 

effective date of the final 

revised rule or expiration of 

current certification 

(maximum of 5 years 

certification and no renewal)

4.1 g/hr for catalytic 

heaters/stoves and 7.5 g/hr for 

noncatalytic heaters/stoves 

(1988 NSPS limits)

All other heaters (includes currently 

certified heaters after the 

certification expires) 

Step 1: upon the effective 

date of final rule (60 days 

after publication)

Step 2: 5 years after the 

effective date of the final rule

4.5 g/hr (weighted average)

1.3 g/hr for each burn rate 
Central Heaters (Subpart QQQQ Proposal )

► Would affect hydronic heaters and forced-air furnaces

► Not subject to 1988 NSPS

► Hydronic heaters are also known as indoor and outdoor wood boilers

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Hydronic Heaters (in Subpart QQQQ)

► In January 2007, EPA instituted a voluntary program and NESCAUM developed 

a model rule that several states subsequently used as a starting point for state 

regulations.

► Some manufacturers redesigned their models to be Phase 2 white tag “qualified” 

models >80% cleaner (in lab tests) than unqualified ones

► > 40 current qualified Phase 2 models

► > 30 manufacturers are signatory partners in the voluntary program

► 2-Step phase-in

► Step 1: test and certify to meet level similar to current Phase 2 white tag qualifying 

level for EPA voluntary “Hydronic Heater Program”

► Step 2: meet strengthened limits (see table) 5 years after effective date 

► Testing and certification process similar to revised subpart AAA

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Hydronic Heater – Proposed Emission Limits

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EPA also is seeking comment on a 3-Step approach over an 8-year period. This approach would 

include an interim limit of 0.15 pounds per million Btu heat output 3 years after the rule is published in 

the Federal Register.

Step PM Emission Limit Compliance Date

Step 1 0.32 pounds per million 

BTU heat output 

(weighted average) and 

a cap of 7.5 g/hr for any 

individual test run

60 days after publication of 

final rule

Step 2 0.06 pounds per million 

BTU heat output for each 

burn rate

5 years after publication of 

final rule
Forced-Air Furnaces (in Subpart QQQQ)

► Step 1 is based on the Canadian consensus standard.

► Step 1 is higher than HH because most FAF have not progressed as quickly, but 

all should catch up by Step 2

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EPA also is seeking comment on phasing in the limits in 3 steps over an 8-year period. This approach 

would include an interim emissions limit of 0.15 pounds per million Btu heat output 3 years after the rule 

is published in the Federal Register (the same interim limit as for hydronic heaters).

Step PM Emission Limit Compliance Date

Step 1 0.93 pounds per 

million BTU heat 

output (weighted 

average) and a cap 

of 7.5 g/hr for any 

individual test run 

60 days after publication of 

final rule

Step 2 0.06 pounds per 

million BTU heat 

output for each run

5 years after publication of 

final rule
Masonry Heaters (in Subpart RRRR)

► Currently not regulated

► Would require certification process similar to revised Subpart AAA

► Limit based on test data for typical masonry heaters that perform well.

► Asking for comments on alternatives to testing. Most heaters are custom built 

on-site, so testing each custom model could be difficult.

► Compliance deadlines based on production level

► Most companies make less than 15 heaters per year 

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Annual Production Level PM Emission Limit Compliance Deadline

15 heaters or more 0.32 pounds per million 

BTU heat output 

60 days after final 

rule is published

Fewer than 15 heaters 0.32 pounds per million 

BTU heat output 

5 years after final rule 

is published
Test Methods

► Peak, shorter-term particulate emissions

► We add multiple 1-hour filters for each test run to gather data regarding 

start-up and anticipated peaks.

► For Step 2, we require compliance with emission limits at the lowest burn 

rate (“Category 1”) and the maximum burn rate (“Category 4”) rather than 

the weighted average of the four burn rates in the current NSPS.

► Cordwood test method

► We add testing with cordwood to encourage best real-world performance. 

For Step 1, the manufacturer would submit 2 test reports, 1 with cribs 

(dimensional lumber) and 1 with cordwood and choose which results to use 

for certification. Step 2 tests would all be with cordwood. 

► We will continue to work with states, labs and industry on the details.

► Precision

► We propose improvements to the test methods to improve precision.

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Efficiency and Carbon Monoxide 

► Efficiency

► We require testing and reporting but not a minimum efficiency

► Carbon Monoxide

► We require testing and reporting of CO but not an emission limit

► Information would guide consumers’ decisions

► Model line performance testing by 3rd-party

• ISO-accredited labs and certifying bodies

► Reviewed/approved by EPA

► Model lines also subject to audit testing

• Sealed/stored units used for original performance test

• Original drawings compared to actual unit 

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Projected Impacts

► We expect the rule would reduce fine particle pollution from new

heaters by ~4,800 tons per year over the 2015-2022 timeframe; many 

reductions would be in areas with significant particle pollution problems. 

► We expect monetized health benefits would be >$4 billion per year.

► We expect costs would be ~$16 million per year.

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Comments

► We encourage email comments to the official docket at:

► a-and-r-docket@epa.gov,

► Attention Docket ID No. EPA-HQ-OAR-2009-0734

► Gil Wood

► wood.gil@epa.gov

► 919-541-5272

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