OA~~ dOOtt- o 134 

OCT 17 2012 

'?fJIU4t 

'P.tJ. 

~ 

S'tJ~ 34() • 

'P~ 

~. "'HH~ 

~ 

5452() 

POTAWATOMI 

(Keeper nf lhe Fire I 

October 3, 2012 

Honorable Lisa P. Jackson, Administrator 

U.S .. Envir(?J:Wlental Protection Agency 

Mail Code: 61 02T 

1200 Pennsylvania Avenue, N.W. 

Washington, DC 20460 

. ,. '·'· 

Re: New Source Performance Standard for Residential Wood Burning Devices 

Dear Administrator Jackson: :r• 

The Forest County Potawatomi.Community ("FCPC") is located in rural 

northeastern Wisconsin where wood is a primary residential and commercial heat source 

beginning as early as mid-September and lasting, some years, into early June! There has 

also been a noticeable increase in the number or outdoor wood boilers; particularly for 

small commercial operations and residential "outbuildings" such as garages and barns. 

Early morning temperature inversions which capture the wood smoke provide visual 

evidence of certain air quality issues that wood heating can create. 

The FCPC air quality management program urges EPA to expeditiously 

promulgate an update to the New Source Performance Standard (NSPS) for Residential 

Wood Burning Devices. With EPA's recent proposal to strengthen the national ambient 

air quality standard for fine particulate matter, updating this performance standard to 

reflect best demonstrated emission controls, and to broaden the standard to address 

devices that are not included in the current NSPS, is now more important than ever. 

Wood is a domestic renewable energy resource for home heating, and as such can 

be an important part of a state's portfolio ofrenewable energy alternatives. However, 

with inadequate controls, wood burning can emit high levels of fine particulate and air 

toxics, potentially endangering public health. Over the 20-plus years since EPA 

promulgated the NSPS for Residential Wood Burning Devices, improved technologies to 

limit emissions from these devices have been develop~' and demonstrated. Many 

manufacturers have been building wood heaters with emission rates far below EPA's 

OCT 12 2012 
current standards, and have for many years. Consistent with Section 111 of the Clean Air 

Act, we urge EPA to move forward with a revision to the NSPS that reflects the best 

system of emission reduction that has been adequately demonstrated. Moreover, EPA 

should examine the testing methods used to determine compliance with the standards, 

and revise the methods as appropriate and necessary to accurately determine emission 

performance. Both strong emissions standards and an accurate emissions test method are 

essential to the continued credibility ofEPA's wood heater certification program. 

In summary, an update to the NSPS for Residential Wood Burning Devices is 

long overdue, and with EPA's latest proposal for a more stringent fine particulate 

standard, EPA has effectively acknowledged the public health impacts from fine 

particulate matter at concentrations far lower than the levels contemplated in 1988, when 

this NSPS was first promulgated. We look forward to working with EPA on this 

important effort in the coming months knowing that the alternative is for state and local 

agencies and Tribes to undertake rulemaking or other regulation on their own, faced with 

many of the same challenges that EPA faces but without EPA's resources or expertise. 

Accordingly, it is EPA's responsibility to expeditiously promulgate new performance 

standards for wood heaters that encompass the full range of wood heating devices in use 

today, and that reflect best demonstrated technologies. 

Sincerely, 

{00250219.DOCX}