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# o 134 OCT 17 2012 

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POTAWATOMI (Keeper nf lhe FireI

October 3, 2012 Honorable Lisa P. Jackson, Administrator U.S
..Envir(?J:Wlental Protection Agency Mail Code: 6102T 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 inrural northeastern Wisconsin wherewood is a primaryresidential and commercial heat source beginningas early

## as mid-September and lasting, some years, into early June! There has also been a noticeable increase in the number or outdoorwoodboilers; particularly for small commercial operations andresidential "outbuildings" suchas garages and barns. Earlymorning temperature inversions which capture the wood smoke provide visual evidence ofcertain air quality issues that wood heating can create. The FCPC air quality managementprogram 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 inthe current NSPS, is now more important than ever. Wood is a domestic renewable energyresource for homeheating, and as such can be an important part ofa state's portfolio ofrenewable energy alternatives. However, with inadequate controls, woodburning can emithigh levels offine particulate and air toxics, potentially endangeringpublichealth. Over the 20-plus years since EPA promulgated the NSPS for Residential Wood Burning Devices, improved technologies to limit emissions from these devices havebeen

**develop~'**and demonstrated. Many manufacturers havebeenbuilding wood heaters with emission rates far below EPA's 

# OCT 12 2012current standards, andhave for many years. Consistent with Section 111 ofthe Clean Air Act, we urge EPA to move forward with a revision to the NSPS that reflects the best system ofemission reduction thathas 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 latestproposal 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 inthe comingmonths knowing that the alternative is for state and local agencies and Tribes to undertake rulemaking or otherregulation on their own, faced with manyofthe same challenges that EPA faces but without EPA's resources or expertise. Accordingly, it is EPA's responsibility to expeditiouslypromulgate newperformance standards for woodheaters that encompass the full range ofwood heating devices 

### inuse today, and thatreflectbest demonstrated technologies. Sincerely,

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