December 27, 2012

Regina McCarthy, Assistant Administrator

Office of Air and Radiation U.S. Environmental Protection Agency Ariel Rios Building 1200 Pennsylvania Avenue, N.W.

Mail Code: 6101A Washington, DC 20460

Re: New Source Performance Standards for Residential Wood

- burning Devices

Dear Ms. McCarthy:

Maine Energy Systems encourages the US EPA to take bold steps in establishing New Source Performance Standards for residential scale wood burning appliances to be sold and used in the United State s. Only bold steps can hope to clear widespread misconceptions about the possibility of very clean biomass combustion.

Perceptual stance

Maine Energy Systems is a relative newcomer to the biomass appliance trade. For approximately five years,

we have b een importing, distributing, and, now, manufacturing European designed pellet boiler equipment. Perhaps this perspective allows us a fresh look at an issue that seems to have a deep, difficult regulatory history.

We have entered a field with advanced pro ducts that we’ve found to be poorly understood by all, routinely miscategorized by bureaucrats, and commonly subjected to irrelevant rules by regulators. We’ve gained sudden experience in trying to help others understand refined biomass heating with pelle t boiler equipment.

Encouragement of licensing of advanced products

We urge the US EPA to encourage and support the adoption and licensing of existing advanced products for residential biomass heating, even when importation is required. This can be accomplished through promulgation of reasonable but rigorous New Source Performance Standards and achievable documentation procedures for compliance with those standards. Achievable documentation procedures can be created using current test/report procedur es and willingly adapting specified European EN test results for standards compliance as has already been done by several State environmental protection agencies.

For nearly two decades the Western Europeans have been carefully refining the ways in which they use renewable energy sources. This refinement, coupled with the overlays of strict environmental regulation and government deployment support, has led to classes of equipment that are superior to those that have been developed in the United States in the absence of either strict regulation or government support. If the United States is becoming serious about alternative energy use, product development from these known best practices has obvious advantages.In the case of biomass heating appliances, adaptation of existing refined equipment is technically manageable and bureaucratically difficult. The regulatory landscape impacting everything from installation practices to

emissions standards is a state

- by

- state patchwork of laws and rules based larg ely on the demands and behaviors of the appliances of less sophisticated design generally available here today.

Testing for air quality compliance is a well

- established practice in the European Union. While there are

differences between EN 303

- 5 test pro tocols and existing US EPA recognized protocols, the European methods, and the rules they support, have led to the cleanest wood combustion equipment in the world. It would be hard to argue that the well

- established European testing methods don’t provide ample information to establish the suitability of tested products in the American marketplace. This is particularly true since pellet boilers, for example, with suitable emissions levels for use in Western Europe, are often nearly an order of magnitude cle aner, as measured by particulate emissions, than the current OWHH hangtag requirements in many states.

Importing these well

- developed technologies is cost

- effective and technology advancing. Official support for adaptation of specific EN test results to demonstrate compliance with American standards would allow the American biomass burning marketplace to advance itself a decade, or more, in technical development at minimal cost. While we understand that it is not common American practice to be accepting of standards or tests beyond our design, it would be reasonable to reconsider our common practice in this, and similar, cases.

Over the past five years, Maine Energy Systems has become a manufacturer of highly efficient, very clean, Austrian designed pe llet boiler equipment. Our inclusion in the Minneapolis air quality event was certainly due to the efficiency, the cleanliness, and the automaticity of our equipment. Access to that equipment was acquired over a reasonable time at a reasonable cost and d eployed through the reasonable actions of States’ departments of environmental protection. Surely the model is worth emulation where it would advance the needs of the US public and biomass combustion equipment manufacturers.

Combustion quality and mark et growth

Western Europe has forced substantial reduction in fossil fuel consumption over the last decade. Most of that reduction (70%+/

- ) is attributable to the combustion of biomass. Reduction through the use of other

renewables is less than 10% in ea ch energy source category.

As the European marketplace and its governments have adopted the view that reduction in fossil fuel consumption is important, standards for efficiency of combustion equipment and air quality have also been tightened. That the market has grown at an exponential rate in the face of these tightening standards should give the EPA courage to heighten emission and efficiency standards as that is what is best for both our environment and the biomass combustion marketplace.

Because US resolve for fossil fuel reduction does not match that of our European counterparts, our biomass appliance growth rates are likely to be more gradual than theirs have been, but demonstrably cleaner flue emissions and improved efficiencies will only serve t o enhance public opinion of the cleanliness and cost

effectiveness of this abundant renewable fuel and should be clear targets of EPA standards.

Basis for regulation

The US EPA finds itself in a difficult regulatory position. It is clear that there are superior biomass combustion technologies available in the world yet commonly available American technologies don’t often achieve their efficiencies or cleanliness. At the root of the debate about industry regulation in the US there is a small, highly

vari able data set that was collected some time ago from a diminishing group of test labs over a period of years. The questionable value of analyses from these data allows them to be used in various ways as wedge issues in debates about standard setting.We recommend that the value of the existing data be recognized as limited and that known achievable emissions standards for biomass appliances from across the world be seriously considered in setting long

- term target values for the New Source Performance Standards to be established for residential scale appliances.

Bin paradigm

In Minneapolis, Northeast States Coordinated Air Use Management (NESCAUM) introduced a bin paradigm for consideration in standards setting. From our perspective there were several good ideas represented in the paradigm and one we would modify.

Categorization of equipment into function groups is important. As use of biomass appliances moves increasingly in the direction of whole building solutions, it will be important that central heating systems and thermal storage units are as clean and efficient as the state

- of

- the

- art allows. The NESCAUM proposed categorization would allow for technology forcing standards in the two larger use categories while allowing the space heater s to evolve from a different starting point.

The bin concept appeals to us assuming that there are reductions in allowable emission levels and increased efficiency standards across the bins that are meaningful. It is also important that the time windows for each bin are short enough to provide meaningful improvement in air quality and long enough to allow diligent industry members to comply either through development or acquisition of cleaner, more efficient technologies.

We object to the third bin being considered an alternative achievement rather than a target. We are industry practitioners; we want the industry to grow robustly. We believe that its robust growth is tied to improving standards of efficiency and cleanliness. The goals currently listed as Bin 3 standards should be the third target

in our view.

Summary

We have invested heavily in capital and human resources to achieve a leadership position in pellet central heating for small to mid

- sized buildings. We have done that with full attenti on to combustion cleanliness, boiler efficiency, and end

- user convenience. Our investments, and those of many others, will be of the highest value if the US EPA creates standards that require all who would be in the marketplace to meet standards that are good for the health of our citizens and for the efficient use of their heating dollars

.

Respectfully submitted,

Leslie B. Otten, CEO, President

Harry “Dutch” Dresser, Managing Director