Residential Wood Heaters

New Source Performance Standards (NSPS)

Draft Proposal Update

National Tribal Air Association 

EPA Air Policy Call

May 30, 2013

5/28/13 Working DRAFT– Subject to change. Does NOT represent final EPA decisions.
EPA Point of Contact

Gil Wood, Project Lead

919-541-5272

wood.gil@epa.gov
Current Schedule

► Draft* NSPS proposal package being reviewed internally

► Draft should be ready to start normal 90-day review by other federal 

agencies in June 2013

► Anticipated schedule:

► Summer 2013 – Proposed rule to be signed by EPA Administrator 

and published in Federal Register and on-line

► 90-day public comment period – Opportunity for people to submit 

information for EPA to consider as we develop the final rule. 

Information on how to comment will be on the website when we 

propose the rule. 

► If requested, a public hearing will be held during the comment period

► Summer 2014 – Final rule to be signed by EPA Administrator and 

published in Federal Register and on-line

* Proposal is still draft and subject to change pending EPA Administrator’s review and 

signature on rulemaking proposal in Federal Register for public comment

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Today’s Update

► Key Changes from Previous Updates

► Wood Stoves (and single-burn-rate stoves and pellet stoves)

► Hydronic Heaters (aka indoor and outdoor wood boilers)

► Forced-air Furnaces

► Masonry Heaters

► Test methods

► Peak, Shorter-term Emissions

► Cordwood Test Method

► Efficiency and Carbon Monoxide

► Projected Impacts

► Questions

► Appendix - Historical Overview

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Key Changes

► Two-Step Approach Preferred for Proposal

► The states and tribes and environmental communities feel strongly about the need for 

stringent stepped standards as soon as possible.

► We would propose to require compliance with Step 1 emission limits immediately and 

Step 2 tighter emission limits in 5 years.

► Three-Step Approach for Comment

► We would ask for comments and environmental and economic data for potential 

justification of a Three-Step Approach that would require Phase 1 immediately, an 

interim Step 2 in 3 years, and a final Step 3 in 8 years. The emission limits would be 

identical for Step 2 in the Two-Step Approach and Step 3 in the Three-Step approach. 

► EPA’s current preference is for the Two-Step Approach but we will consider the 

information submitted during the public comment period and the final rule will include 

the appropriate approach. We do not expect the final rule to allow individual 

manufacturers to choose between approaches. 

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Wood Stoves

Preferred Two-Step Approach for Wood Stove NSPS Proposal

► Step 1: Washington State noncat emission level upon promulgation

• Over 85% of sales of EPA-certified wood stoves are models that 

already meet this level.

► Step 2: “Best Systems” emission level five years after promulgation

► We would combine catalytic and non-catalytic units under one emission limit. 

► We would include single-burn-rate stoves and pellet stoves.

► We would establish an emission limit for cordwood (rather than cribs) for 2019, 

if possible. We appreciate the testing that EPA-accredited labs are conducting 

now to help inform us of what is possible.

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Hydronic Heaters

Preferred Two-Step Approach for Hydronic Heater NSPS Proposal

► Step 1: Partnership Program Phase 2 level upon promulgation

– 36 hydronic heater models (27 cordwood and 9 pellet models) 

built by 17 U.S. manufacturers have already been qualified at this 

level.

► Step 2: “Best Systems” five years after promulgation

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Forced-air Furnaces

Preferred Two-Step Approach for Forced-air Furnaces NSPS Proposal

► Step 1: CSA B415 level upon promulgation

– The two primary U.S. manufacturers of forced-air furnaces both have 

models that can meet Step 1 already. Other manufacturers are 

conducting tests now.

► Step 2: “Best Systems” five years after promulgation

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Masonry Heaters

Preferred Compliance Requirements for Masonry Heater NSPS Proposal:

► Level Equivalent to HH upon promulgation except for small volume 

masonry heater manufacturers.

– Based on data submitted by the Masonry Heater Association, over 10 

models already achieve this level.

– Many other models are expected to use a computer simulation to show that 

their design would be expected to achieve the NSPS level without 

conducting further testing.

► For small volume masonry heater manufacturers (less then 15 total units 

per year), deadline would be 5 years after promulgation

– Most masonry heater manufacturers are very small businesses that produce 

less than 12 heaters per year.

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Scope of the Rules

► We feel strongly about the need to minimize potential loopholes.

► We are considering proposing three subparts as follows:

• Subpart AAA, aka “room heaters”

– Adjustable burn rate stoves, single-burn rate stoves, and pellet 

stoves

• Subpart QQQQ, aka “central heaters”

– Outdoor and indoor hydronic heaters

– Forced-air furnaces

• Subpart RRRR

– Masonry Heaters

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Test Methods

► Peak, shorter-term emissions

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

regarding start-up and anticipated peaks.

► For Step 2, we would 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 would add testing with cordwood to encourage best real-world 

performance. For Step 1, the manufacturer would submit 2 test reports, 1 

with cribs and 1 with cordwood and choose which results to use for 

certification. For Step 2, the tests would all be with cordwood. 

► We are working with states and labs and industry on the details.

► Precision

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

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Efficiency and Carbon Monoxide 

► Efficiency 

► We would require testing and reporting but not a minimum efficiency.

► Carbon Monoxide

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

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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 2014-2022 timeframe; many 

reductions would be in areas with significant particle pollution problems. 

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

lives would be saved.

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

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Questions?

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Appendix - Rulemaking Overview

► On February 26, 1988, EPA published the original NSPS for residential wood heaters.

► In 1995, Washington State tightened the emission limits in WA. Almost all 

manufacturers chose to meet the WA limits for all U.S. models. Today, over 85% of 

EPA-certified models meet the WA emission levels. 

► In November 2009, EPA released a draft review document with preliminary draft 

conclusions.

► EPA conducted numerous stakeholder outreach activities and prepared the technical 

and economic information necessary for a draft proposal. However, the February 2012 

draft proposal did not have great support and EPA began to consider other options.

► In November 2012, State and local air pollution control agencies hosted a national 

forum for a broad range of stakeholders (including EPA, manufacturers, health 

organizations, and environmental groups) to discuss the issues and potential options.

► EPA has prepared new options for the draft proposal after consideration of the 

information and recommendations discussed in November and in numerous follow-up 

discussions.

► The new options would better reflect current best systems of emission reduction and 

add emission limits for new appliances that were not regulated in 1988, such as indoor 

and outdoor wood boilers, forced-air furnaces, and single-burn-rate stoves. They would 

also include improvements of the repeatability of the test methods and add testing 

requirements to address short-term emission peaks and testing with cordwood to better 

represent real-world conditions. 

► The monetized health benefits far exceed the costs for all options considered.

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