EPA’s Proposed Wood Stove / Wood Heater 

Regulations: Frequently Asked Questions 

James E. McCarthy 

Specialist in Environmental Policy 

April 29, 2014 

Congressional Research Service 

7-5700 

www.crs.gov 

R43489 
EPA’s Proposed Wood Stove / Wood Heater Regulations: Frequently Asked Questions 

Congressional Research Service 

Summary 

On January 3, 2014, the Environmental Protection Agency (EPA) released proposed emission 

standards for new residential wood heaters, the most common of which are wood stoves, pellet 

stoves, hydronic heaters, and forced air furnaces. The proposal, which would revise standards for 

wood stoves and pellet stoves and establish standards for other types of wood heaters for the first 

time, appeared in the Federal Register on February 3. This began a public comment period that is 

scheduled to run until May 5, 2014. 

According to EPA, smoke from wood heaters contributes “hundreds of thousands of tons” of fine 

particles to the air throughout the country each year, accounting for nearly 25% of all area source 

air toxics cancer risks and 15% of non-cancer respiratory effects. In many areas, in wintertime, 

wood heaters are the largest source of particulate air pollution; yet many heater types are not 

currently subject to any federal emission standard. 

The proposed rule would only gradually reduce this pollution, because it would apply only to new 

heaters (not those already in use) and it would give the industry a five-year grace period before its 

most stringent standards would take effect. Wood heaters can last for 40 years or more, so it will 

be decades before the full health benefits of the rule would be attained. 

Nevertheless, the rule would eliminate an estimated 210 to 470 premature deaths annually in the 

2014-2022 period, according to EPA, as well as reduce hospital admissions and lost work days 

due to respiratory illness. EPA quantifies these benefits at $1.8 billion to $4.2 billion per year 

during the 2014-2022 period, more than 100 times the agency’s estimate of the annualized cost to 

manufacturers, $15.7 million. 

Trade associations representing the affected industries and companies in the industry have mixed 

views of the proposed standards. While supporting revision of the current standards and the 

inclusion of additional heater types, they express concern that the standards as proposed will 

impose too great a cost. Facing higher costs for new units, homeowners will continue to use 

current, highly polluting equipment, rather than replace it, the industry maintains. Many have also 

expressed concerns regarding the process to be used in certifying compliance and the short period 

of time in which currently available units could be tested and certified. 

These concerns, as well as the widely acknowledged health effects, have generated substantial 

interest in the proposed rule in areas where wood stoves are used as heating sources, and 

Members of Congress from those areas have written EPA to express concerns regarding the 

proposed rule’s possible impacts. The subject has also been raised during hearings on EPA’s 

FY2015 appropriation request, and legislation (H.R. 4407) has been introduced to place limits on 

EPA’s authority to set the standards. 

This report addresses some of the most frequent questions raised concerning the proposal, in 

order to provide basic information about EPA’s action, its potential impacts, and industry and 

other reactions to the rule. 
EPA’s Proposed Wood Stove / Wood Heater Regulations: Frequently Asked Questions 

Congressional Research Service 

Contents 

Q: To what sources of emissions would this rule apply? ........................................................... 1

Q: Is this a final rule? ................................................................................................................ 2

Q: Would the proposed rule affect existing wood stoves and other wood heaters 

already purchased or in use? .................................................................................................. 2

Q: What would the proposed rule require? ................................................................................ 3

Q: What would the rule cost? .................................................................................................... 3

Q: Is there controversy over the agency’s proposed testing and certification 

requirements? ......................................................................................................................... 5

Q: Would the rule have any special provisions for small businesses? ....................................... 5

Q: What are the estimated benefits of the proposed rule? ......................................................... 6

Q: Would any of the rule’s provisions apply to the operators of residential wood 

heaters? ................................................................................................................................... 7

Q: What is the industry reaction to the proposed rule? ............................................................. 7

Figures 

Figure 1. Annualized Compliance Cost and Projected Industry Revenue, by Product Type, 

in 2018 .......................................................................................................................................... 4

Contacts 

Author Contact Information............................................................................................................. 8
EPA’s Proposed Wood Stove / Wood Heater Regulations: Frequently Asked Questions 

Congressional Research Service 1 

n January 3, 2014, the Environmental Protection Agency (EPA) issued proposed emission 

standards for new residential wood heaters, including wood stoves, pellet stoves, 

hydronic heaters, and forced air furnaces (defined below). The rule is the result of a 

regular review process that Section 111 of the Clean Air Act requires for all New Source 

Performance Standards (NSPS). Wood stoves and pellet stoves have been subject to NSPS since 

1988. The act requires a review of NSPS and, if appropriate, revision of the standards, at least 

every eight years. EPA has not reviewed the wood stove NSPS until now, so this review is 18 

years overdue. 

The proposal appeared in the Federal Register on February 3, 2014.1

 This began a public 

comment period that is scheduled to run until May 5. 

Release of the proposed rule has generated a substantial amount of interest, particularly in areas 

where wood is used as a heating fuel, and Members of Congress from those areas have written 

EPA to express concerns regarding the proposed rule’s possible impacts.2

 This report addresses 

questions posed to CRS by numerous requesters in order to provide basic information about 

EPA’s action, its potential impacts, and industry and other reactions to the rule. 

Here are 10 questions raised by the proposal. 

Q: To what sources of emissions would this rule apply? 

A: The rule would amend the current NSPS for Residential Wood Heaters (which applies to wood 

stoves and pellet stoves) and would, for the first time, set standards for new residential hydronic 

heaters, forced air furnaces, single burn rate stoves, and residential masonry heaters designed to 

burn wood.3

 

The rule would not apply to outdoor fireplaces, pizza ovens, barbecues or chimineas (freestanding outdoor chimneys), and it would not apply to new or existing heaters that are fueled 

solely by oil, gas, or coal. 

 

1

 U.S. EPA, “Standards of Performance for New Residential Wood Heaters, New Residential Hydronic Heaters and 

Forced-Air Furnaces, and New Residential Masonry Heaters; Proposed Rule,” 79 Federal Register 6329, February 3, 

2014. Hereinafter, “Proposed Rule.” 

2

 “EPA Proposed Standards for Wood Heaters Would Increase Heating Costs, Senators Say,” Daily Environment 

Report, March 31, 2014. A letter to EPA Administrator McCarthy from Sens. Collins and King of Maine is available at 

http://www.collins.senate.gov/public/index.cfm/press-releases?ID=c858ecaa-45a2-4953-bffe-edf035de3bd8. A letter to 

the EPA Administrator from Sen. Thune of South Dakota is available at http://www.thune.senate.gov/public/index.cfm/

press-releases?ID=008e36fa-35c2-42f0-a50c-6165fb33d982. 

3

 Hydronic heaters, which are typically located outside the buildings they heat in small sheds with short smokestacks, 

are appliances that burn wood to heat a liquid (water or a water-antifreeze mixture) that is piped to provide heat and hot 

water to occupied buildings, such as homes. Hydronic heaters may also be located indoors. The forced air furnaces that 

would be subject to these regulations are similar to natural gas-fired or oil-fired forced air furnaces used in millions of 

American homes, except that they are designed to burn wood. According to EPA, “Industry information suggests that 

there are three times more sales of wood-fired, forced-air furnaces each year compared to wood-fired hydronic heaters. 

These units are relatively easy to retrofit into existing structures, and their sales price is substantially less than hydronic

heaters but greater than gas or oil furnaces.” Proposed Rule, p. 6360. Masonry heater operation, according to EPA, 

involves one or two short high burn rate cycles where hot gases are generated during combustion of a fuel load in the 

firebox. The hot gases then pass through channels, saturating the masonry mass with heat. The masonry mass then 

radiates heat into the area around the masonry heater for 12 to 24 hours. 

O
EPA’s Proposed Wood Stove / Wood Heater Regulations: Frequently Asked Questions 

Congressional Research Service 2 

In addition, EPA did not include standards for indoor fireplaces in the proposed regulation, 

because, the agency stated, “Fireplaces are not effective heaters.”4 However, the agency is 

seeking additional data and comments on this issue. Fireplaces are included in an EPA voluntary 

program that encourages manufacturers to make cleaner-burning fireplaces and retrofits available 

for consumers,5

 and some industry representatives have asked EPA to include fireplaces in the 

final rule. 

Q: Is this a final rule? 

A: No. EPA is taking comment on a proposed rule and may modify it as a result. Under a consent 

decree issued April 28, 2014, by the U.S. District Court for the District of Columbia, EPA must 

issue a final rule by February 3, 2015. The final rule may be changed from the proposal, provided 

that there is an explanation of the reasons for any major changes. At the least, when the agency 

promulgates the final version of the rule, it must provide a response to each of the significant 

comments, criticisms, and new data submitted during the proposed rule’s public comment period. 

Q: Would the proposed rule affect existing wood stoves and other 

wood heaters already purchased or in use? 

A: No. The proposed standards would only apply to new wood stoves and heaters sold after the 

rule’s effective date. Compliance requirements would be phased in over a five-year period after 

that effective date. For most new wood stoves or pellet stoves, there would be little change in 

emission standards until 2020. Other wood heaters (notably, what are called hydronic heaters and 

wood-fired forced air furnaces) have not previously been subject to federal emission standards. 

These heaters would be subject to standards for the first time 60 days after a final rule is 

promulgated. As with wood stoves, however, far more stringent standards would affect new 

hydronic heaters and forced air furnaces beginning with models sold in 2020. 

The absence of standards for most wood heaters currently in use limits the effectiveness of EPA 

and state efforts to reduce wood smoke emissions. By general agreement, there are at least 6 

million wood stoves in operation that predate EPA’s 1988 standards. Annual sales of wood stoves 

are less than 3% of this amount, according to EPA’s Regulatory Impact Analysis (RIA),6

 and do 

not necessarily replace existing units, so it could be decades before older, highly polluting 

equipment is retired. Industry, EPA, and a number of states have initiated wood stove change-out 

programs, with subsidies for purchases that replace equipment that predates EPA standards, and at 

least one manufacturer has proposed banning the sale of replacement parts for non-EPAcompliant models. But the wood smoke issue is likely to remain for years to come no matter what 

action EPA takes. 

 

4

 U.S. EPA, “Overview of Proposed Updates to Air Emissions Requirements for New Residential Wood Heaters,” p. 2, 

at http://www2.epa.gov/sites/production/files/2013-12/documents/

proposed_wood_heater_nsps_overview_fact_sheet_1.pdf. 

5

 For information, see “Burn Wise,” U.S. EPA’s Voluntary Program for Wood-Burning Fireplaces, July 11, 2013, at 

http://www.epa.gov/burnwise/pdfs/fireplaceqa.pdf. 

6

 U.S. EPA, Regulatory Impact Analysis (RIA) for Proposed Residential Wood Heaters NSPS Revision, Final Report, 

January 2014, p. 3-24, at http://www2.epa.gov/sites/production/files/2013-12/documents/ria-20140103.pdf. The sales 

data cited in the RIA are for the year 2008. Elsewhere, the RIA states: “Since 2005, total industry shipments on average 

have declined annually by 24%” (p. 3-23), so the unit sales may be substantially lower now. 
EPA’s Proposed Wood Stove / Wood Heater Regulations: Frequently Asked Questions 

Congressional Research Service 3 

Q: What would the proposed rule require? 

A: As proposed, the rule’s standards would take effect in two phases: on the effective date of the 

rule (60 days after promulgation, presumably in 2015), new wood heaters would have to meet 

standards that EPA describes as “emission levels that almost all models can readily achieve now 

using today’s designs and technology.”7

 Many in industry dispute this characterization, but in the 

agency’s RIA, EPA states that the Step 1 limit for wood stoves and pellet stoves “is the 1995 

Washington State standard for non-catalytic stoves.”8

 In an attachment to the RIA, the agency 

provides a list of 130 wood and pellet stoves (out of 145 models on the market) that already meet 

the standard, using industry supplied data.9

 Of hydronic heaters, the agency states: “The Step 1 

limit is the EPA ‘Phase 2’ voluntary program limit already met by 36 hydronic heater models (27 

cord wood and 9 pellet models) built by 17 U.S. manufacturers.”10 The Step 1 standard for forced 

air furnaces is based on testing done in March 2010 for the Canadian standard for these units. 

The second phase, which would require a roughly 70% reduction from the Step 1 standards for 

wood stoves and pellet stoves, a roughly 80% reduction for hydronic heaters, and a 94% 

reduction in emissions from forced air furnaces, would take effect five years after the rule’s 

effective date (presumably in 2020). According to EPA, “... the proposed second step represents 

stronger emission levels achievable for all appliance types at reasonable cost, but allows 

appropriate lead times for manufacturers to redesign their model lines to accommodate the 

improved technology across multiple model lines and test, field evaluate, and certify the new 

model lines.”11 The agency’s RIA also provides data on numerous heaters that it states currently 

achieve emissions at or below the required Step 2 level.12

In addition to the proposed five-year phase-in, the agency has asked for comment on an 

alternative approach that would have three phases, instead of two. In the alternative approach, 

Step 1 standards would be the same and would be implemented on the effective date of the rule, 

presumably in 2015. The final standards would also be the same, but they would not be required 

until eight years after the rule’s effective date (presumably in 2023). In return for the longer 

implementation period, an intermediate step, requiring a 44% reduction in emissions from wood 

stoves and pellet stoves, a 53% reduction from hydronic heaters, and an 83% reduction from 

forced air furnaces, would take effect three years after the rule’s effective date (presumably in 

2018). 

Q: What would the rule cost? 

A. EPA estimates that the annualized cost of the rule in the 2014-2022 timeframe would be $15.7 

million.13 The rule would affect about 296,000 heaters sold annually during this period, according 

 

7

 Proposed Rule, p. 6353. 

8

 U.S. EPA, Regulatory Impact Analysis (RIA) for Proposed Residential Wood Heaters NSPS Revision, Final Report, 

January 2014, p. 9-16, at http://www2.epa.gov/sites/production/files/2013-12/documents/ria-20140103.pdf. NOTE: 

There are two pages in the RIA numbered “9-16”: the one referenced here is page 197 of the pdf. 

9

 RIA, p. 9-10, at http://www2.epa.gov/sites/production/files/2013-12/documents/ria-20140103.pdf. NOTE: There are 

two pages in the RIA numbered “9-10”; the list referenced here begins on p. 216 of the pdf file. 

10 RIA, p. 9-16 (p. 198 of the pdf file). 

11 Proposed Rule, p. 6353. 

12 RIA, pp. 9-15 to 9-17 (pp. 197-199 of pdf file). 

13 Detailed cost estimates, summarized in this paragraph, can be found in Section 5 of the agency’s RIA at 

(continued...) 
EPA’s Proposed Wood Stove / Wood Heater Regulations: Frequently Asked Questions 

Congressional Research Service 4 

to the agency. As shown below in Figure 1, EPA’s estimate of the cost impact of the rule varies 

by industry segment, but it is below $5 million for each segment. In percentage terms, EPA 

estimates that increased costs will range from a low of 2.3% of revenues for pellet stoves to a 

high of 6.4% of revenues for single burn rate stoves, which are currently not subject to emission 

standards. 

The cost of the alternative three-step regulation would be higher than that of the rule as proposed: 

a total of $28.3 million annually during the 2014-2022 timeframe, if the alternative three-step 

phase-in were to occur. 

The estimated costs—whether for the proposed rule or the alternative—are relatively small 

compared to other recent EPA rules that have stirred controversy. The Mercury and Air Toxics 

Standards, for example, which apply to electric generating units, were estimated to cost $9.5 

billion annually—more than 600 times as much as the proposed wood heater rule; but the 

revenues of the electric utilities, to which the MATS rule applies, are about 1,000 times those of 

the wood heater industry, so the estimated costs of this rule would impose a greater burden on this 

small segment of U.S. industry than MATS would impose on electric utilities. Most of the 

manufacturers of wood heaters are small businesses and do not have large revenues over which to 

spread research and development costs. As a result many fear that stringent standards will drive 

them out of business. 

Figure 1. Annualized Compliance Cost and Projected Industry Revenue, 

by Product Type, in 2018 

$152.8

$134.4

$98.1 $96.6

$3.5 $4.5 $4.2 $2.3

$0

$40

$80

$120

$160

Pellet Stoves Hydronic Heaters Wood Stoves Forced Air Furnaces

$Millions

Product Sales Compliance Cost

Source: Table 5-5a in the EPA Regulatory Impact Analysis 

Notes: Two other industry segments, masonry heaters and single burn rate stoves, account for less than 5% of 

industry sales combined, and are estimated to have compliance costs totaling $1.2 million. 

 

(...continued) 

http://www2.epa.gov/sites/production/files/2013-12/documents/ria-20140103.pdf. 
EPA’s Proposed Wood Stove / Wood Heater Regulations: Frequently Asked Questions 

Congressional Research Service 5 

Q: Is there controversy over the agency’s proposed testing and 

certification requirements? 

A: Yes. The heart of the controversy over EPA’s proposed rule has to do with the testing that 

would be required for certification of wood heating equipment under the proposal. In order to 

demonstrate compliance with the proposed standards, EPA would rely on testing and certification 

provided by independent labs—just as it does with the current standards for wood and pellet 

stoves. The labs use an EPA protocol, which specifies the type and amount of wood, moisture 

content, startup procedures, duration of the test, etc., to test whether or not a specific model meets 

the EPA standards. 

As noted above (in “What would the proposed rule require?”), EPA has stated that a large number 

of wood heaters (about 90% of current wood stove models, for example) already meet the 

proposed Step 1 standards. But EPA is proposing to alter the test method to better account for real 

world conditions. So, in reality, if the testing and certification process changes, none of these 

heaters can be said to meet the proposed standards until they are tested under the new protocol. 

Recertifying under a new testing protocol would impose costs on already certified equipment and 

could result in many of the heaters not being certified. 

One option that could resolve this concern would be to grandfather equipment that is certified at 

emission levels below the proposed standards under current test methods. But, in some cases 

(e.g., forced air furnaces), there are no current standards and no test method until EPA 

promulgates one. Manufacturers of these heaters would have only 60 days from promulgation of 

the final rule to get their full line of equipment tested, a daunting task, and one that has the 

potential to create “logjams” at testing facilities, according to manufacturers. 

Q: Would the rule have any special provisions for small 

businesses? 

A: As part of the regulatory process, in 2010, EPA created a Small Business Advocacy Review 

panel under the Regulatory Flexibility Act, as amended by the Small Business Regulatory 

Enforcement Fairness Act.14 The panel included representatives of the Office of Advocacy of the 

Small Business Administration, the Office of Information and Regulatory Affairs at the Office of 

Management and Budget, and 26 small businesses or organizations from the wood heating 

industry. 

The panel produced a number of recommendations, which are summarized in Chapter 6 of the 

RIA and in the preamble to the proposed rule. EPA states in the preamble that it collected 

additional information and refined its economic and technical analyses based on the panel’s input. 

The agency states that its stepped compliance approach is a response to the panel’s 

recommendation for delayed compliance dates for low volume producers. The panel 

recommended that EPA allow the use of International Standards Organization (ISO)-accredited 

labs and certifying bodies to expand the options for product testing and certification, which EPA 

has proposed to do. The panel recommended that EPA allow manufacturers to test a 

representative unit for a model line to determine compliance with the standards, rather than each 

 

14 5 U.S.C. §609. 
EPA’s Proposed Wood Stove / Wood Heater Regulations: Frequently Asked Questions 

Congressional Research Service 6 

individual unit, which EPA agreed to. The panel also recommended that EPA not move forward 

with proposed emission limits for 12 types of heaters, 8 of which EPA agreed to.15 

In general, however, the proposed emission standards would apply equally to manufacturers of all 

sizes with the same compliance deadlines for all. This may be because more than 90% of the 

manufacturers of wood heaters qualify as small businesses. 

Q: What are the estimated benefits of the proposed rule? 

A: EPA has found that wood smoke causes respiratory illness and even premature death in some 

people exposed to it. The agency estimates that the reductions in fine particulate (PM2.5) 

emissions that will result from the proposed standards will avoid 210 to 470 premature deaths per 

year in the years 2014-2022, as well as reduce nonfatal heart attacks, emergency room visits, and 

lost work days. Using its standard methods for monetizing health benefits, EPA states that the 

reduced health impacts resulting from the proposal would provide a benefit of $1.8 billion to $4.2 

billion per year over the period 2014-2022, or $118 to $267 in benefits for every dollar spent to 

comply. Given this ratio, the agency’s cost or benefit estimates could be off by two orders of 

magnitude and the benefits would still outweigh the costs.16 

The agency states that 98% of the monetized benefits of the proposed rule come from the 

reduction in premature mortality.17 In line with other executive branch agencies,18 and as 

reviewed by its outside Science Advisory Board, EPA values statistical lives saved at $8.0 million 

each in 2010 dollars.19 

The agency attributes more than 95% of the benefits to the standards for hydronic heaters, forced 

air furnaces, and single burn-rate stoves (none of which are currently subject to regulation).20 

The projected benefits do not include the value of the carbon monoxide, volatile organic 

compounds, air toxics, and black carbon emissions that would be reduced along with PM2.5

emissions.21 EPA also states, in a press release that accompanied announcement of the proposal, 

that consumers will see a monetary benefit from efficiency improvements in the new wood 

heaters, which use less wood to produce an equivalent amount of heat, although it did not 

quantify this benefit. This assertion is disputed by some in the industry, but it did not figure in 

EPA’s calculation of costs and benefits. 

Like many recent EPA Regulatory Impact Analyses, this proposed rule’s RIA derives virtually all 

of its monetized benefits from the reduction in PM2.5 emissions, and the resulting effect on 

premature mortality. In estimating the premature mortality, the agency relied on two peerreviewed epidemiological studies (the Harvard Six Cities study and the American Cancer Society 

 

15 Proposed Rule, pp. 6370-6371. 

16 The benefits of the rule are discussed in Section 7 of the RIA. 

17 RIA, p. 7-6. 

18 For a discussion of the value of a statistical life used by various federal agencies, see archived CRS Report R41140, 

How Agencies Monetize “Statistical Lives” Expected to Be Saved By Regulations.

19 RIA, pp. 7-6 and 7-7. 

20 CRS calculation, based on data in RIA, p. 8-6. 

21 RIA, pp. 7-15 to 7-30. 
EPA’s Proposed Wood Stove / Wood Heater Regulations: Frequently Asked Questions 

Congressional Research Service 7 

study), which have formed the backbone of the agency’s conclusions on the health effects of 

PM2.5 for the past two decades.22 

Q: Would any of the rule’s provisions apply to the operators of 

residential wood heaters? 

A: Yes. Although the rule mainly sets emission standards to be met by manufacturers, it also has 

some provisions applicable to the equipment’s operator. Specifically, it sets requirements for the 

type of fuel that may be used in hydronic heaters and forced air furnaces, and it prohibits the 

burning of garbage, yard waste, tires, plastic, waste petroleum products or paint, material 

containing asbestos, construction and demolition waste, paper products, railroad ties, pressuretreated wood, animal remains, unseasoned wood, and salt water driftwood in those heaters. 

Similar prohibitions apply to new masonry heaters.23 For pellet-fueled appliances, the proposal 

makes it clear that operation according to the owner’s manual includes operation only with pellet 

fuels that have been used in the certification test and have been graded and marked under a 

licensing agreement with the Pellet Fuels Institute, or an equivalent organization approved by 

EPA, to meet certain minimum requirements and procedures for quality assurance.24 For wood 

stoves, it would be against federal law to operate the equipment in a manner inconsistent with 

operating instructions in the owner’s manual, such as using treated wood, colored paper, 

cardboard, solvents, trash, and garbage.25

Q: What is the industry reaction to the proposed rule? 

A: There is a general consensus in the wood heat industry that new standards of some sort would 

be welcome. The prevalence of wood smoke and its health consequences, particularly in small 

towns and cities, has led some jurisdictions to ban the installation of new wood heaters or to 

instigate burn bans on days when air quality is poor. Several states have adopted emission 

standards more stringent than EPA’s. According to the Connecticut Department of Energy and 

Environmental Protection, local health districts in the state have issued cease and desist orders to 

individuals violating local bans on the use of hydronic heaters. In monitoring conducted over a 

two-year period, Connecticut found the monthly contribution of wood smoke to total 

concentrations of PM2.5 to be as high as 41.3%, with daily contributions as high as 74.3%.26 The 

existence of bans and the threat of future bans discourages sales of wood heating equipment; even 

if it didn’t, many in the industry want to see the pollution problem addressed. 

As represented by Hearth, Patio, & Barbecue Association (HPBA) and others, therefore, the wood 

heater industry has supported EPA’s decision to revise the NSPS and expand it to cover additional 

heater types. HPBA stated in one press account that it welcomed the “long overdue” standards.27

 

22 RIA, p. 7-5. 

23 Proposed Rule, pp. 6385, 6390. 

24 Proposed Rule, p. 6375. 

25 Proposed Rule, p. 6382. 

26 Statement of Richard Pirolli, Bureau of Air Management, Connecticut Department of Energy and Environmental 

Protection, at U.S. EPA Public Hearing on the Proposed New Source Performance Standards for Wood Heaters, 

Boston, Massachusetts, February 26, 2014, transcript, p. 191, at http://www.regulations.gov/

#!documentDetail;D=EPA-HQ-OAR-2009-0734-1037. 

27 “EPA proposes Revised Performance Standards for New Wood Stoves, Heaters,” Daily Environment Report, January 

(continued...) 
EPA’s Proposed Wood Stove / Wood Heater Regulations: Frequently Asked Questions 

Congressional Research Service 8 

In a more detailed statement prepared later, however, the association stated: “If the standards are 

promulgated as written, the increase in cost for new woodstoves will be significant, compelling 

consumers to keep their old stoves in use,” and thus, the rule would not achieve the emission 

reductions that EPA foresees. The association’s statement quoted its president: 

In addition to downplaying the effects on the consumer, EPA has failed to provide any data 

showing that any of our manufacturer members can meet the new regulations as proposed. 

The testing procedure to measure emissions is imprecise and does not reflect real world 

performance. Competing in this numbers game will cause smaller companies to go out of 

business. Innovation will suffer and consumers will bear the burden of the costs with no 

guarantee of cleaner air.28 

Most of the individual manufacturers who testified at EPA’s public hearing, February 26, 2014, 

made similar statements. 

The challenge, therefore, which the industry, EPA, and individual states all face, is to find the 

sweet spot, where emissions are significantly reduced, without needlessly harming the industry or 

unwittingly providing incentives for equipment owners to continue using old, inefficient, highly 

polluting equipment. This is not an easy task. No matter what levels EPA chooses for new 

standards, there are likely to be winners and losers. As a result, controversy over the EPA 

proposal is likely to continue. 

Author Contact Information 

James E. McCarthy 

Specialist in Environmental Policy 

jmccarthy@crs.loc.gov, 7-7225 

 

(...continued) 

4, 2014. 

28 Hearth, Patio & Barbecue Association, “HPBA Urges Thoughtful Review of Proposed NSPS Standards,” March 20, 

2014, at http://www.prweb.com/releases/2014/03/prweb11685330.htm.