# EXHIBIT C

Case 1:13-cv-01555-GK Document 13-5 Filed 10/31/13 Page 1 of 4IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

AMERICAN LUNG ASSOCIATION, et al. Plaintiffs,

and HEARTH, PATIO & BARBECUE ASSOCIATION, Proposed Plaintiff-Intervenors,

v. GINA MCCARTHY, in her official capacity as Administrator, U.S. Environmental Protection Agency,

Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. 13-cv-1555 (GK)

DECLARATION OF BRET WATSON I, Bret Watson, declare under penalty of perjury as follows: 1. I am the President of Jøtul North America (“Jøtul”) . In that role, I am responsible for all facets of the North American subsidiary bus iness to Jøtul AS Norway, one of the world’s oldest producers of stoves, inserts, and fireplaces . Jøtul is a member of the Hearth, Patio & Barbecue Association. I have personal knowledge ab out the contents of this declaration, which I offer in support of HPBA’s Motion to Intervene in t his case.

2. Prior to joining Jøtul, I served as National Sales and Marketing Manager for NHC/HearthStone Home Heating Products, another manu facturer of wood, gas, and pellet stoves. There, I managed all external and internal sales, marketing and customer service activities, and supported a network of over 500 hea rth dealers. In the past, I also served as a board member of the Northeast Hearth, Patio, & Barb ecue Association (NEHPBA) for six years. Case 1:13-cv-01555-GK Document 13-5 Filed 10/31/13 Page 2 of 42

NEHPBA is a regional affiliate of HPBA. Altogether , I have 19 years of experience in the hearth products industry. I have a deep understand ing of the industry, including, in particular, the economic and regulatory challenges that compani es like Jøtul are currently facing.

3. Jøtul’s woodstove products are subject to EPA’s new source performance

standards for residential wood heaters issued under the Clean Air Act. Under those standards, woodstoves are subject to weighted average particul ate matter emissions limits of 7.5 grams per hour for non-catalytic stoves and 4.1 grams per hou r for catalytic stoves. These standards have been in place for over 20 years, though EPA has bee n in the process of reviewing and revising those standards for quite some time. EPA’s delay i n issuing new standards has led to tremendous confusion, uncertainty, and concern.

4. Jøtul has been essentially treading water with resp ect to initiating any new woodstove projects because we do not know what EPA’ s revised standards will look like, when they will be issued, what the compliance timeline w ill be, etc. Without knowing these important variables, it is hard for Jøtul to make long range planning decisions or capital investments.

5. For instance, Jøtul does not know whether to start work on research and development projects that will rely on catalytic te chnology to try to achieve weighted average emissions below 2 grams per hour or whether to focu s on trying to modify existing non-catalytic technology to achieve weighted average emissions of 4.5 grams per hour, which is the current standard in the State of Washington. Jøtul’s origi nal understanding, based on stakeholder meetings with EPA, was that the Agency was consider ing lowering its standards to the 4.5 g/hr limit established by the State of Washington. Unti l EPA finalizes its revised standards, however, Jøtul cannot devote significant capital expenditure s on technology tailored to meet that standard. Spending money to try to meet a potentially moving target would unnecessarily drive the retail Case 1:13-cv-01555-GK Document 13-5 Filed 10/31/13 Page 3 of 4Case 1:13-cv-01555-GK Document 13-5 Filed 10/31/13 Page 4 of 4