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MEMORANDUM

To: Gil Wood, USEPA

David Cole, USEPA

From: Jill Mozier, EC/R Inc.

Date: November 30, 2012

Subject: Notes from the November 8, 2012 Q&A session of the National Educational

Forum on the Residential Wood Heater NSPS in Minneapolis, MN

____________________________________________________________________________________

The presentation documents and slides are available for download from the Basecamp website. 

Therefore presentation notes are not included in this memo, which focusses exclusively on the question 

and answer (Q&A) portion following each group of presentations.

Welcome, Overview and Goals of the Meeting

 David Thornton, MPCA

 Molly Mayo, Facilitator

Public Health and Environmental Impacts of Woodsmoke

 Dr. Ryan Allen, Simon Fraser University

 Dr. Philip Hopke, Clarkson University

 Judy Abbott, NY DOH

Question (Brian Toll, Connecticut Health Dept): What are the health effects under 24 hours? How do 

we set a reference number for shorter term exposures?

Answer: Judy Abbot responded that it’s a good question but that we’re not there yet, and further that 

county health dept staffs are being cut by 30%. Dr. Hopke commented that we are stuck with FRM 

measurements which only obtain a third of the data (i.e., only every 3rd day), with no time resolution. 

FEM continuous monitors are needed.

Question (Ed Miller, VP of American Lung Association of the Northeast): Commented that since there 

may never be enough monitors and because there appears to be no safe level of PM2.5, it may be more 

effective to approach this from a property rights perspective (e.g., smoke crossing property line for 

more than 12 minutes in an hour). Videotaping of such may hold up in court and the definition of the 

violation may be able to be extended beyond OWHH to other sources.

Answer: Judy Abbot responded that this is a legal question but her understanding is that this would be 

considered a private rather than a public nuisance in NY.

Question (Dick Valentinetti, Vermont Air Quality DEC): Are there different health effects based on 

different particle sizes?

Answer: Dr. Allen responded that a probable driver in toxicity is PM size (e.g., health effects from 

traffic linked to ultrafines), but attribution cannot yet be made definitively. Dr. Hopke commented that 

there aren’t enough measurements of particle size to know definitively. The 11-year study Dr. Hopke is 

involved with is the longest particle size study in the US and the second longest in the world, but there 

aren’t enough studies.
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Question (Molly Jacobs, UMASS Lowell Center for Sustainable Production): Regarding woodsmoke 

particle size, are the initial start-up particle size emissions in the nano to ultrafine range, and are there 

surrogates similar to diesel surrogates? What should be inferred from the extent of combustion and 

particle size?

Answer: Dr. Allen responded, regarding the first particle size question, that an epidemiological study

can’t be done without measurements (and ultrafines can’t be measured on a filter; optical equipment is 

necessary), so instead proximity to major roadway has been used. Related to diesel, there are no 

equivalent surrogates for woodsmoke. Regarding the extent-of-combustion question, Dr. Allen 

responded that low temperatures versus high temperatures and incomplete versus complete combustion 

produce different particle sizes and toxicities. In general, the toxicity decreases with higher 

temperatures and more complete combustion (based on in vitro cell structure studies rather than 

epidemiological studies). 

Question (Tomas Carbonell, Environmental Defense Fund): What do the studies say about indoor air 

quality related to woodsmoke?

Answer: Dr. Hopke responded that there have been indoor air quality studies on asthmatic children 

using personal filters, but most indoor air quality studies regard tobacco smoke; not much has been 

studied regarding the indoor effects of biomass burning. Dr. Allen responded that infiltration studies 

indicate that 30% to 70% of outdoor PM2.5 infiltrates the house – that the issue is generally not 

woodstoves emitting directly to the indoors but rather the woodsmoke going up the chimney and 

coming back indoors. He further noted that HEPA filters help. Dr. Abbott noted that a home’s typical 

running of the dryer and furnace creates a negative pressure (which draws outside air in).

Question (unidentified person): What are the established links between birth defects and woodsmoke?

Answer: Dr. Allen responded that exposure to PM2.5 from traffic during pregnancy has been linked to 

more pre-term births and low fetal birth weights. There are no studies pointing to woodsmoke in 

particular, although in general PM2.5 in urban areas is associated with certain pregnancy health 

outcomes. Dr. Hopke added that similar outcomes have been seen with tobacco smoke and cookstoves. 

Current and Emerging Technologies

 John Crouch, HPBA

 Chris Neufeld, Blaze King / Travis Industries

 Dr. Harry H. “Dutch” Dresser, Jr., Maine Energy Systems

 Nathan Russell, NYSERDA

Question (Arthur Marin, NESCAUM): Regarding retrofitting catalysts, what is the possibility for using 

this technology in an approach similar to the woodstove change-out effort?

Answer: Chris Neufeld responded that replacing old stoves with catalytic stoves would have limited 

success because of the higher cost of catalytic stoves, unless a strong incentive is attached (e.g., as in 

Fairbanks example, owner would need to be given something like $2,500 to exchange old woodstove for 

EPA-certified replacement). [Editor’s Note: Chris has said on other occasions that adding a catalyst to 

an old conventional wood stove is generally not as simple as just adding a catalyst but rather that the 

catalyst, bypass, and shielding to protect against flame impingement should be integrated into the design 

for best performance.]
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Question (Andy Ginsburg, Oregon Department of Environmental Quality): Compared to the NSPS, how 

important are issues like proper sizing, regular maintenance of catalysts, and thermal storage -- that is, 

how does industry see these compliance issues being implemented and improved in the field?

Answer: John Crouch responded that the NSPS is a small part of the process; the whole system includes 

aspects like dry and proper wood/fuel. Dutch Dresser commented that there should not be a one-sizefits-all NSPS, rather appliance-specific standards and differentiation are needed in the NSPS. Equipment 

should be tested for what it is, not for what it isn’t. Nate Russell commented that thermal storage plus 

the boiler should be considered the regulated unit. Chris Neufeld commented that all appliance types 

need to be maintained, not just catalytic parts. Regarding Andy Ginsburg’s follow-up question on how 

to get dealers to make maintenance happen, John Crouch commented that dealers don’t want to put an 

appliance on the market that causes lots of phone calls. For example, with drafts varying so much it’s 

difficult to design a system that works consistently in all settings – this is not a maintenance problem, 

rather it’s a warranty problem. Furthermore, regarding maintenance, who would enforce?

Question (Martin Lunde, Garn Inc.): Are there any studies regarding oversizing (i.e., replacing oversized 

equipment with proper sized equipment)?

Answer: John Crouch responded that there are no such studies, that the sizing decision is a function of 

vendor and consumer interaction/discussions. Martin Lunde further commented regarding an example of 

an oversized pellet stove rated for 200,000 BTU for a 3,000 sq.ft. house in area with only 30 degree 

lows, and another example regarding a unit which was oversized by 50% but was now oversized by

300% due to caulking and re-insulation of house. He also commented that in Minnesota it’s a code issue 

– a unit can’t be oversized past 8%. Chris Neufeld commented that for catalytic stoves the option of 

turning down and burning (a bigger unit) lower is better because it’s worse to operate a (too small) 

catalytic unit too hot. John Crouch commented that the weatherization programs are oblivious to wood 

stoves and that DOE should conduct stove change-outs in conjunction with improving weatherization of 

homes.

Question (Dick Valentinetti, Vermont Air Quality DEC): He agrees with John Crouch that federal 

regulations have unintended consequences. He commented that the new NSPS should include a process 

for allowing innovation, otherwise it’d be playing around the edges at the state level to improve upon 

good products. It’s a chicken versus egg dilemma – for example, Chris Neufeld talked about hybrid 

models, but how do we get European technology here? What is the driver if it’s not regulation?

Answer: Dutch Dresser responded that the Europeans have a stick/carrot/tambourine system. In Austria, 

the stick is the high tax on fossil fuel; the carrot is a government subsidy (30% of installed cost); and the 

tambourine is the bully pulpit of government officials talking up the latest technology. John Crouch 

commented that comparing Europe to the US is an apple to orange comparison.

Question (Dennis Brazier of Central Boiler Inc): Our customers want to save money, but old houses are 

hard to heat and on the opposite side of the sizing issue there are customers who have high heat load 

demands who don’t want their houses to stay at 60 degrees. It’s not acceptable for dealer to simply

answer that it’s windy today (so stove may not heat the house as well). Thus it’s a complex problem. 

Furthermore some pellet systems are expensive.

Answer: Nate Russell responded that one can look at the building size to quantify heat load and that 

dealers need to pick-up on model sizing practices.

Case Studies

 Lisa Herschberger, MPCA
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 Dr. Jim Conner, Fairbanks Alaska North Star Borough

 Dr. David C. Snyder, University of Wisconsin-Stevens Point

 Jim Hodina, Linn County Public Health Dept, Iowa

 Eric Merchant, Montana DEQ

Question (David Thornton, MPCA): What is the nature of the episodic control in Helena, Montana?

Answer: Eric Merchant responded that once 80% of the standard is reached in Helena, a call alert goes 

out stating that no one can burn solid fuel (unless they have a sole source of heat exception).

Question (Judy Abbott, NYS Department of Health): Did the installation of high tech indoor filters in 

the Fairbanks school improve asthma rates and/or other health issues? Also, is the public aware of the 

cost of heart attacks, etc (e.g., wondering about using BenMap perhaps)? Finally, is there CO monitoring 

(in Alaska)?

Answer: Dr. Jim Conner responded that the indoor filters did not make a big difference. There was a 

hospital admissions study but it was not broken down by area, and statistics broken down by local area 

would help because health costs motivate people. There is CO monitoring and Alaska is in compliance 

for CO, but CO is a nuisance complaint and needs to be addressed. 

Question (Christian Rakos, European Pellet Council): Top level products/appliances could solve 

Alaska’s problem. Did anyone consider subsidizing the top units? There would be a huge incentive to 

dealers.

Answer: Dr. Jim Conner responded that the change-out should have been limited to top 2% of units, but 

it wasn’t. Had it been limited to top units, Alaska wouldn’t have to ban burning on certain days.

Question (Dr. Ryan Allen, Simon Fraser University): There are real costs associated with health effects 

and almost invariably there is a net economic benefit [to lowering pollution levels].

Answer: Dr. Jim Conner responded that the public does not see dead bodies lying around the streets, so 

basically people are not motivated enough.

Question (Janis Denman, Michigan DEQ, Air Quality Division): Regarding the Iowa standard (“for heat 

inputs less than 10 million BTU, 0.6 lb/million BTUshall apply”), how does one get from input to 

output?

Answer: Jim Hodina responded that one would need to include the boiler efficiency and moisture 

content of the wood (and that they were working within the old standard).

Question (Tom Morrissey, Woodstock Soapstone): First, Tom Morrissey commented that he is stunned 

by the amount of wood burned outdoors for recreation in chimineas, and wondered if there was more 

data on this. Second, he noted the intersection of low income people with high fuel costs and wondered 

what the EPA and NSPS can do in this respect 

Answer: Lisa Herschberger commented that there is not much data around the country yet on outdoor 

recreational wood burning (e.g., chiminea use), but she is hoping Minnesota’s new survey will provide 

better estimates. Outdoor recreational wood burning is a problem and is trending with the increases in 

sales of equipment, but more accurate data is needed. Lisa Herschberger commented that she has been 

questioned before regarding whether the current estimates are real, but it is at the very least clear that the 

amount of wood burned outdoors for recreational use is trending upwards. 

Answer: Regarding Tom Morrissey’s second question, Dr. Jim Conner commented that Alaska wants 

EPA to get emission level down and also to address coal burning. Alaska needs to lean on federal 
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standards because there’s not enough political will locally. Eric Merchant commented that Montana 

needs a lower standard driving technology to address issues like elevations and inversions.

Market Impacts of Emission and Efficiency Standards

 Bob Ferguson, Consultant to HPBA

 John Ackerly, Alliance for Green Heat

 Christian Rakos, proPellets Austria

Question (Jack Goldman, HPBA): Did European governments subsidize higher cost units?

Answer: Christian Rakos responded that European governments such as Austria’s use a carrot and stick 

approach and that governments did subsidize higher performing units. He suggested that the US should 

also subsidize renewable energies.

Question (Chris Neufeld, Blaze King): What about woodstoves in Europe (e.g., catalytic stoves)?

Answer: Christian Rakos responded that Europe does have woodstoves (in addition to pellet models) but 

that he hasn’t seen many catalytic stoves, rather there are primarily ceramic tile masonry heaters in 

Europe (to the best of his knowledge).

Question (Tom Morrissey, Woodstock Soapstone): Will increased efficiency lead to decreased 

emissions?

Answer: Bob Ferguson responded that there is no guarantee of decreased emissions with increased 

efficiency because combustion efficiency and overall efficiency can work in opposite directions. 

Christian Rakos also responded that increased efficiency will not necessarily lead to decreased 

emissions because of the need to ensure that the combustion process has enough air – so both need to be 

pushed to work well together, for example with electric control of combustion. (John Ackerly agreed 

with this.)

Question (unidentified): What is the cost of fuel oil in Europe?

Answer: Christian Rakos responded that the cost of one European liter corresponds to a price of 

approximately $4 to $5 per gallon, and that 20% of cost is government tax.

Question (Lisa Rector, NESCAUM): Are there government subsidies for performance tiers?

Answer: Christian Rakos responded that there were different types of subsidies in each province and that 

provinces competed to have their subsidy make the largest effect. This competition among province 

subsidies drove the market.

Question (Dan Henry, 5G3 Consulting): What is the finished cost of the installed heat system (pellet 

boilers in Europe)?

Answer: Christian Rakos responded that the cost is approximately $18,000 Euro for pellet system and 

$12,000 Euros for gasified logwood (these numbers would be multiplied by approximately 1.3 to 

convert to US $ -- so $23,000 for pellet system and $16,000 for gasified logwood). Christian Rakos

further commented that these numbers nonetheless pay for themselves because of difference compared 

to fuel oil prices, and that this is especially true for larger homes where the payback takes about 3 to 4 

years.

Question (Judy Abbott, NYS Dept of Health): What is LHV versus HHV?
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Answer: Bob Ferguson explained that water is produced in wood burning and that this water can go up 

the chimney, or heat can be recovered from condensation of this water vapor. HHV assumes that this 

heat can be recovered and so is a higher number of available BTUs per kilogram of wood (heating 

value) than LHV. LHV assumes that one will not attempt to recover the heat from the water vapor but 

rather that it will always go up the chimney so the heat of condensation is not counted, hence the smaller 

(aka, lower) number for available heat per kilogram of wood. Combustion efficiency is not affected by

HHV or LHV, but overall efficiency is the heat output divided by the heat input – the smaller the 

denominator the larger the fraction – so LHV results in a larger calculated overall efficiency than HHV 

does. There is a 5% to 8% difference in the calculated overall efficiency based on whether LHV or HHV 

is used. John Ackerly further commented that European appliances are therefore not necessarily

better/more efficient than US appliances (boilers are, but not other appliances) because Europe typically 

uses LHV and U.S. typically uses HHV. Nonetheless, the marketplace sometimes perceives that 

European appliances are more efficient because of this difference (of using LHV, not HHV). Wood 

burning uses LHV in Europe while fossil fuel uses HHV in Europe. Dutch Dresser commented later that 

a condensing pellet boiler was introduced in 2004 which recovers water vapor (4 to 8 kilowatt, 12,000 to 

30,000 BTU small boiler versions which are good for low energy homes) and that demand for such 

small boilers is increasing. Thus, it is incorrect to say that condensing wood boilers are not in the 

marketplace. 

Question (Judy Abbott, NYS Dept of Health): Is there an issue with CO emissions from storage of 

pellets?

Answer: Christian Rakos responded that very large pellet piles can produce high concentrations of CO 

due to oxidation (e.g., people died in ship transport of bulk pellets) – consequently a cellar with a pellet 

pile needs to have good ventilation. But this is not an issue with bags of pellets, only with a pile on the 

order of magnitude of 100 tons.

Question (Jiggs Blackburn, Rising Stone Inc): What about CO as a surrogate for PM emissions– is 

Europe measuring CO constantly? 

Answer: Christian Rakos responded that Europe is measuring CO emissions constantly and has found 

that low CO values mean complete combustion with hardly-measurable hydrocarbons. Europe has also 

found that the fine dust composition of the ashes differ in complete versus incomplete combustion, with 

complete combustion forming white ash (water soluble salts which do not lodge permanently in lungs as 

black carbon does).

Question (Tomas Carbonell, Environmental Defense Fund): In Europe, how does in-field performance 

compare with tested performance (in lab)?

Answer: Christian Rakos responded that this discrepancy is very important as long as the consumer can 

interfere and effect performance of stove/boiler. If consumers cannot effect the performance (as in the 

case of automatic boilers with electronic controls), then there is a very low discrepancy.

Question (Roger Holland, Supreme Fireplace Products): Doesn’t the Burnwise program already educate 

consumers? What more is needed?

Answer: John Ackerly responded that better education is needed regarding the efficiency confusion and 

the differences in American HHV and European LHV usage.
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Question (Larry Sorrels, USEPA): Regarding HPBA’s 1% annual sales increase estimate, how far in the 

future does this apply and what assumptions regarding fuel oil (other fuel costs) are inherent to this 

estimate?

Answer: Bob Ferguson responded that the projection is based on ~10-year history and rolling averages 

(included fireplace inserts). The saw tooth graph Bob displayed indicates that the trend is hard to predict, 

so he just assumed the historical sales would continue for 5 to 7 years in the future. [Question about 

other fuel costs was not answered.]

Pellet Fuel Supply and Fuel Quality

 Chris Wiberg, Timber Products Inspection

 Christian Rakos, proPellets Austria

 Lisa Rector, NESCAUM

Question (unidentified person from a Minnesota county): The question regarded the BTU listed on the 

pellet bags being based on HHV (which includes the heat of condensation) and whether this was the 

standard basis for the listed BTU seen by consumers on all pellet bags.

Answer: Chris Wiberg responded that the reason the BTU is on the pellet bags is to help consumers 

compare (although the declared BTU is not necessarily dealing with the LHV versus HHV issue).

Question (Andy Ginsburg, Oregon DEQ): Is a better appliance needed for utility grade pellets? How can 

you stop consumers from using utility grade?

Answer: Chris Wiberg responded that the ash content can be as high as 6% (e.g., agricultural feed stock 

like switch grass pellets fall into utility grade). NSPS may rate stove as to whether it can burn utility

grade pellets but consumers cannot be stopped from using the lower grade since there are no pellet 

police. Manufacturers may void warranties however. Dan Henry of 5G3 Consulting commented that this 

problem is self-regulating because the pellet stove will stop operating if using utility grade pellets.

Question (Gil Wood, USEPA): Is the EN Plus standard for residential units only (not power/utility)?

Answer: Christian Rakos responded that yes, EN Plus is for residential units only.

Question (Gil Wood, USEPA): What is in the European standard to measure/analyze (e.g., metals)?

Answer: Christian Rakos responded that every element is tested for in the ISO standard, so it’s a 

complete system. Europe would like US to use the same standard system. Chris Wiberg commented that 

assuming the feedstock is clean, there would not be metals. Audit inspections rather than testing and 

analysis are the best chance of catching problems. Chris Wiberg further commented that he agrees the 

ISO standards are appropriate, but the limits may not be the same limits the US would have chosen – so 

while it’s a good basis for comparison, it is not necessarily a good match.

Question (Molly Jacobs, UMASS Lowell Center for Sustainable Production): Is the variability within a 

single manufacturer part of the sampling? Can you track where the contamination came from (e.g., 

through labeling scheme)?

Answer: Lisa Rector responded that de-barked hardwood produced a consistent product with no 

methodological contamination. However, another supplier had multiple feedstocks with some 

contamination which was hard to track/identify. For example, one bag tested high and then 3 more bags 

from different states during the heating season were all off-the-charts as well. So this is an ongoing 

problem which is of concern, based on elemental analysis. Lot numbers are needed.
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Question (Lisa Rector, NESCAUM): Is sampling of pellet manufacturers random or planned?

Answer: Christian Rakos responded that an EN Plus facility is informed of inspection several days 

before, so there is some warning, but the auditor would nonetheless catch a systematic use of waste/trash 

and serious contamination. Furthermore, serious contamination would cause the boiler to malfunction. 

Chris Wiberg responded that the first inspection (in the US) is planned but additional inspections are 

unannounced/random.

Question (Ben Myron, Myren Consulting Inc): Were there any split samples in data NESCAUM was 

referring to?

Answer: Lisa Rector responded that there were no split samples between labs, but 15% had duplicate 

samples analyzed.

Overview and Status of Current Draft of USEPA’s NSPS for Residential Wood Heating Devices

 Gil Wood, USEPA

Question (Jack Goldman, HPBA): If EPA has a goal of completing a draft proposal by the end of the 

year, what is the deadline for sending information to EPA?

Answer: Gil Wood responded that information should be sent as soon as possible – that is, within weeks 

not months.

Question (unidentified person): What about limitations on operational requirements? For example, a 

stove can work well in the laboratory but not in the field – so how can EPA address boiler operation 

once it’s installed and then operated poorly by a consumer?

Answer: Gil Wood responded that the current NSPS has a requirement that homeowners operate the 

appliance according to the owner’s manual – so that requirement is potentially federally enforceable, 

although it has never been used to date. Warranty requirements need to be reviewed more closely. In the 

draft proposal, pellet stoves must certify with fuel(s) they advertize for burning and include in warranty.

Question (Lisa Rector, NESCAUM): Can energy audit/tune-up be included, like in the area source boiler 

rules?

Answer: Gil Wood responded that legally yes, but he is not the EPA Administrator and she has not been 

briefed on the details of the draft proposal yet.

Question (Ed Miller of American Lung Association): Vehicle emission success story has gotten too little 

attention. Stoves have too long a shelf life (and he is concerned about legacy fleet).

Answer: Gil Wood responded that the CAA legal authority for motor vehicles is different than the CAA 

authority for stationary sources. The CAA authority (section 111) for new stationary sources requires 

EPA to base the standards on emission levels that reflect technology, that is best systems of emission 

reduction (BSER) considering costs and not health-based AQ levels. Looking over a longer lifetime (20 

years) of the heaters is appropriate.

Question (Ed Miller of American Lung Association): Is there a role for an advocacy group – that is, 

should we look at modifying CAA instead of working within it?

Answer: Gil Wood responded that EPA cannot legally tell people to speak to their Congressman.

Question (unidentified person): An inexpensive way to measure [ambient air] particulates is needed –

that is, a particle counter is needed for use in the residential setting to measure PM2.5 and other sizes 
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(rather than the timely and expensive EPA [Federal Reference Method for the NAAQS and the] metric 

of μg/m3). Laser type counters offer easy, continuous checking but it would help if EPA had guidelines 

on what constituted a health threat.

Answer: Gil Wood responded that Region 5 is looking at this, as well as USEPA’s ORD.

Question (David Menotti, Crowell & Moring): Woodstoves are being regulated under the NSPS because 

the NRDC proposed this as a settlement option in early 80’s (i.e., using Section 111 for PM instead of 

112 for PAHs since no one wanted a national standard to physically require removing all existing 

woodstoves from houses across the country). The challenge is to get existing non-certified appliances 

out of the inventory versus fooling around with tightening new source performance standards at the 

margins.

Answer: Gil Wood commented that Larry Brockman is the EPA lead for the Burn Wise program and 

leads EPA’s team that has been working on public education/outreach and promoting change-outs. Other 

areas of opportunity and success (which do not fall under the NSPS) include: PM Advance [a new EPA 

program that will encourage states and local authorities to institute additional measures in “advance” of 

the revisions to the PM NAAQS compliance deadlines]; tools for PM measurements; burn ban days;

promoting seasoned wood; energy audits; requiring change-out of stove when home is sold; etc. The 

Libby, Montana example points to improperly installed and unsafe stoves – so proper installation and 

DOE incentives are also being looked at.

Question (Chris Neufeld, Blaze King): In 1988 there were no Phase 1 and Phase 2 EPA stoves on the 

market, so original stoves were grandfathered in. But now Phase 1 and 2 stoves are available on (the 

secondary) market. Do original stoves still have to be grandfathered in, or can we promote secondary

market stoves? When does someone say that the original impetus is no longer there?

Answer: Gil Wood clarified with Chris Neufeld that he was referring to the re-selling of existing stoves, 

and then responded that having existing stoves in a new place is probably not enough to be considered a 

“new source” so it’s doubtful that EPA can address the issue this way under the NSPS. OGC has already 

commented that such a stove is not a new source. EPA could restrict the sale of replacement parts but 

this could be problematic. Dick Valentinetti (Vermont DEC Air Quality) further commented that both 

new source performance standards and change-outs are required – a requirement for new products (to 

keep industry going) is not all that’s required. State and local agencies need to do something as well, not 

just the USEPA.

Question (Tomas Carbonell, Environmental Defense Fund): EPA has lots of discretion with cost; he 

hopes that EPA considers that these [appliances] are unique since they are in residential areas and much 

of the emitted pollution is inhaled. Tomas Carbonell further commented that strict standards may

stimulate a robust market (as in international/European example).

Answer: Gil Wood commented that EPA does have discretion regarding what levels of cost 

effectiveness are appropriate. Regarding Tomas Carbonell’s robust market point, a representative from 

HPBA commented that Europe, unlike the US, is subsidized.

Question (unidentified person): Why not regulate based on cleanest available fuel – for example, why

consider allowing wood in a populated area if natural gas is cleaner?

Answer: Gil Wood responded that this approach may be appropriate for state and local agencies to 

consider, but the USEPA has to look at residential wood heaters as a new source category listed under 

Section 111 and determine the emission levels for standards based on demonstrated best systems of 

emission reductions for those new sources. Dan Henry commented that in reality people will choose 
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natural gas over wood because natural gas is cheaper – wood is not competing with natural gas but 

rather with more expensive forms of fuel.

Next Steps

 Dan Johnson, WESTAR

The Multi-Jurisdictional Organizations (MJOs) – representing 40 states – have a purpose at this twoday educational forum to become better informed. The MJOs have sent a letter to the USEPA 

requesting that EPA move forward with the NSPS, including BSER and cost, considering test methods

and costs, and in-home performance. The group has 4 weeks to continue the discussion on Basecamp. 

Please share ideas on Basecamp. EPA has to propose regulations with or without those shared ideas.