EXHIBIT C 

Case 1:13-cv-01555-GK Document 13-5 Filed 10/31/13 Page 1 of 4
IN 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. 

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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 business 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 about the contents of this declaration, which I 

offer in support of HPBA’s Motion to Intervene in this case. 

2. Prior to joining Jøtul, I served as National Sales and Marketing Manager for 

NHC/HearthStone Home Heating Products, another manufacturer 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 hearth dealers. In the past, I also served as a 

board member of the Northeast Hearth, Patio, & Barbecue Association (NEHPBA) for six years. 

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NEHPBA is a regional affiliate of HPBA. Altogether, I have 19 years of experience in the 

hearth products industry. I have a deep understanding of the industry, including, in particular, 

the economic and regulatory challenges that companies 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 particulate matter emissions limits of 7.5 grams per 

hour for non-catalytic stoves and 4.1 grams per hour for catalytic stoves. These standards have 

been in place for over 20 years, though EPA has been in the process of reviewing and revising 

those standards for quite some time. EPA’s delay in issuing new standards has led to 

tremendous confusion, uncertainty, and concern. 

4. Jøtul has been essentially treading water with respect 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 will 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 technology to try to achieve weighted average 

emissions below 2 grams per hour or whether to focus 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 original understanding, based on stakeholder 

meetings with EPA, was that the Agency was considering lowering its standards to the 4.5 g/hr 

limit established by the State of Washington. Until EPA finalizes its revised standards, however, 

Jøtul cannot devote significant capital expenditures on technology tailored to meet that standard. 

Spending money to try to meet a potentially moving target would unnecessarily drive the retail 

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