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August 18, 2010 

Questions for Small Entity Representatives (SERs)

Revision of New Source Performance Standards for New Residential Wood Heaters and 

Additional NSPS(s) for Other Residential Solid Biomass Combustion Devices

Additional information from the SERs will help inform EPA analyses of potential options.

Industry Profile

 How many manufacturers are there for each of the product categories?

[e.g., wood stoves, pellet stoves, other solid biomass stoves, masonry heaters, manufactured 

fireplaces, site-built fireplaces, fireplace inserts, outdoor stoves, indoor and outdoor hydronic 

heaters and boilers and forced air furnaces, coal burning stoves, cook stoves, single-burn-rate 

products, pellet fuels, etc.]

 How many technically different products or model lines does each manufacture produce? 

 What is the market share in the U.S. for each technically different product from each 

manufacturer?

 How many products on the EPA and/or WA certified lists are no longer manufactured? Do 

these tend to be higher emitting products and/or less marketable products?

 How many manufacturers are small businesses [per product categories]?

 How many manufactures are members of HPBA? BIA? MCAA? MHA? MHOP? PFI?

 How many foreign competitors are there [per product categories]?

 What is the best estimate of the percentage of new manufactured wood-burning fireplaces 

versus new site-built fireplaces? 

 Do you have in-house testing capability? If so, under what circumstances, if any, would you 

use an outside lab? If you don’t have in-house testing capability, at what NSPS level would 

you consider adding that capability, and what are the projected costs? Please be specific 

about cost elements.

Costs/Market/Economics 

 What are current and projected shipments per product category?

 What are average shipments per model line?

 What are current and projected revenues per product category?

 What percentage of total company revenues are the revenues per product category?

 How many products do you have per category? What business decisions drive how many

models are offered? What is the range of percentages of sales per model versus total sales per 

category? How would a more stringent or more inclusive NSPS affect your offerings? Will

your offerings change depending on how stringent the NSPS may be? If so, can you explain 

at what NSPS levels your offerings are expected to change?

 What is the average lifetime of a product line before you feel you need to make cosmetic 

changes? How often do you make changes that require recertification? How often do you 

make changes only to reduce emissions and/or improvements in efficiency?

 What percent of revenues do you spend on raw materials, labor, energy, other production 

costs, R&D, safety compliance testing, emission compliance testing, marketing, aesthetics

and design, service, warranty claims, or other costs (please specify)? Please give percentages 

for each.
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 What are typical costs to develop new models? How much of this cost is for new and 

improved features? How much is for product performance/durability? How much is for 

safety? How much is for efficiency improvements? How much is for emission reductions?

 If you have products qualified under the EPA voluntary programs for fireplaces or hydronic 

heaters? If so, what costs did you incur per model line to develop those units? Would these 

costs decrease with future units? What are the number of units in the model line?

 How did the 1988 wood stove standards affect the number of manufacturers in the wood 

stove marketplace? How many exited the business, compared to the number previously in 

business. How did this affect the number of models offered by each manufacturer? Explain 

the other economic effects of the 1988 NSPS.

 What would be the effect of NSPS on voluntary programs? What are the advantages and 

disadvantages of continuing the voluntary programs on certain product categories?

 How would an NSPS affect the effectiveness of the voluntary programs?

 Please comment on the accuracy of the emissions inventory listed in slide #4 of the June SER 

presentation.

 How would regulation of manufacturer-built fireplaces alone affect the stick-built market?

 How would a trade association design masonry fireplace designs and avoid antitrust concerns 

and competition concerns? Who would pay for testing these designs at test labs? How 

would these designs get incorporated into national model building code, and how long would 

this take (or can this happen without building code approval)?

 What is the cost to renew a certification under the NSPS? Please provide cost elements (e.g., 

testing, transportation to test lab to view test, cost of appliance, etc.)

 What licensing or partnership agreements are typical for manufacture or sale or branding of 

new products?

 What are the average price to manufacture and the price range per product category? 

 What can you say about the costs to produce lower emitting units compared to the costs to 

produce higher emitting units? 

 What is the price elasticity of demand for various product categories? [i.e., how does price 

affect customer demand] 

 What is the price elasticity of supply for various product categories? [i.e., how does price 

affect manufacturer supply]

 What are the market drivers for those of your typical substitute competitors [e.g., gas-fired 

stoves, electric stoves, etc.]?

 What are your typical “markups” and returns on investment?

 How do markups vary for different distribution channels, e.g., direct sales, internet, 

wholesalers, retailers, contractors, homebuilders, public?

 What local, regional or international market factors and key drivers are important?

 What are typical costs for installation, maintenance, and warranty claims per product?

 What are typical product lifetimes and warranties? 

 What percentages of sales are for replacements of similar or different product categories?

 What are the estimated impacts (costs, otherwise) for masons to comply with an NSPS for 

site-built fireplaces?
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Emissions/Technology

EPA is interested in all additional emissions and efficiency data that the SERs may have that 

they have not already supplied and that they believe would be useful. The following would be 

especially useful:

 Data that show comparisons between Method 5G and 5H

 Data that show comparisons of EPA Method 28 OWHH, EN 303-05, and CSA B415.1

 Data that show comparisons of emissions and efficiencies with various levels of heat storage 

 Data that show initial and long term emission and efficiency results for different 

technologies, e.g., performance over time of catalytic and noncatalytic wood stoves and 

pellet stoves 

 Data that show emissions at different burn rates, frequency of operation at different burn 

rates, quantity of fuel burned, and technologies/techniques to avoid operation at lower burn 

rates with typical lower efficiencies [per product categories]

 Data that show collateral benefits of reductions of other criteria pollutants, toxic pollutants 

[e.g., B(a)P, dioxin], greenhouse gases, and black carbon as PM emissions are reduced and as 

efficiencies are increased

 Data that show comparisons of emissions for different fuel quality or loading characteristics 

[e.g., ash content, ash fusion point, moisture, size, species, fuel density, load density, etc.]

 Data that show effects of different types/quality of wood pellets and other biomass pellets.

 Data that show emissions/efficiency of coal stoves, cookstoves, etc.

 Data that shows the variability of test results – both in lab variability and lab-to-lab 

variability.

Labels, Hangtags, and Educational Materials

EPA is interested in ideas that would make these materials easier for the consumer to understand 

and those ideas that would help respond to the interests of manufacturers, retailers, and 

consumers. A particularly challenging task is how to foster a common look and feel and brand 

for "EPA-certified" but also distinguish among different appliances and different emission levels, 

heat outputs, efficiencies, etc. EPA consider this to be an open slate on how the necessary

information is displayed and conveyed to the consumers and States that depend upon this 

information. 

 What suggestions do the SERs have on how to improve the requirements for labels, hangtags, 

owner’s manuals, and certification list?

 What suggestions do the SERs have for improving our BurnWise website

(www.epa.gov/burnwise) and associated outreach materials?

 How can the hangtags be made more appealing?

 How can we get the BurnWise messaging more successfully received by consumers?