1 **August 1 8**  **, 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 analy**  **ses of potential options**  **.** Industry Profile  H ow man y manufacturers are there for each of the product categories ? [e.g., wood stoves, pellet stoves, other solid biomass stoves, masonry heaters, manufactured fireplaces, site
- bu ilt 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 man y technically different products or model li nes does each manufacture produce?  What is the market share in the U.S. for each technically different product from each manufacturer?  How man y 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 man y manufacturers are small businesses [per product categories] ?  How man y manufactures are members of HPBA? BIA? MCAA? MHA? MHOP? PFI ?  How man y 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? I f so, under what circumstances, if an y, would you use an outside lab? If yo u don’ t have in
- house t esting capability , at what NSPS level would yo u 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 ave rage shipments per model line?  What are current and projected revenues per product category?  What percentage of total compan y revenue s are the revenues per product category?  How man y products do you have per category? What business decision s drive how man y 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 yo ur offerings change depending on how stringent the NSPS may be ? I f s o, 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 m ake changes only

to reduce emissions and/or improvements in efficiency?  What percent of r evenues do you spend on raw materials, labor, energy , other production costs, R&D, safet y compliance testing, emission compliance testing , marketing , aesthetics and de sign, service, warranty claims , or other costs (please specify) ? Please give percentages for each.2

 What are ty

pical 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 safet y? How much is for efficiency improvements ? How much is for emission reductions?  If you have products qualified under the EPA voluntary program s for fireplaces or h ydronic heaters ? I f 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 previousl y in business. How did this affect the number of models offered b y 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 r egulation 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? Ho w 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., testi ng, 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 n ew products?  What are the average price to manufacture and the price range per product catego ry?  What can you say

about the costs to produce lower emitting units compared to the costs to produce higher emitting units?  What i s the price elasticity of demand for various product categorie s ? [i.e., how does price affect customer demand]  What is the price elasticity of suppl y for various product categories? [i.e., how does price affect manufacturer supply]  What are the market drivers for those of your t ypi cal substitute competito rs [e.g., gas - fired stoves, electric stoves, etc.] ?  What are your t ypi cal “markups” and return s 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 ty

pical costs for installation , maintenanc e , and warrant y c laims per product?  What are ty

pical product lifetimes and warranties?  What percentage s of sales are for replacement s of similar or different product categories?  What are the estimated impacts (costs, otherwise) for masons to comply with an NSPS for site
- built fireplaces?3

Emissions/Technology EPA is interested in all additional emissions and efficiency data th at the SERs may have that they have not already

supplied and that they

believe would be useful
. The following would be especiall y 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 efficienc ies 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 noncatal yt ic wood stoves and pellet stoves  Data that show emissions at d ifferent burn rates, frequency of operation at different burn rates, quantit y of fuel burned, and technologies /techniques to avoid operation at lower burn rates with ty

pical 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 und erstand 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 applianc es and different emission levels, heat outputs, efficiencies, etc. EPA c onsider 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 S ERs 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 associat ed outreach materials?  How can the hangtags be made more appealing?  How can we get the BurnWise messaging more successfull y received b y consumers?