5 April 2013

US EPA

109 T.W. Alexander Drive

Mail Code: C404

- 04
Research Triangle Park, NC 27709

Attn: Mr. Stephen D. Page

, Director Office of Air Quality Planning & Standards

Mr. Page

,

As the leading manufacturer of wood burning fireplaces, IHP is very concerned with the direction wood burning fireplaces are heading, and I believe we are at a critical juncture from a regulatory perspective . Because there has not been a New Source Performance Standard (NSPS) regulating wo od burning fireplace emissions, states

across the country including California, Arizona

, Colorado and others have started to ban their very existence. Our marketing efforts in conjunction with EPA on the Voluntary Program for cleaner burning fireplaces have been collectively ignored by most of the states and air districts

. Rather than see this product category become

irrele vant and wood burning fireplace becoming obsolete; we have decided to take a bold step and request that EPA regulate wood burning fireplaces through the adoption of a New Source Performance Standard designed

around the existing EPA Voluntary Program requir ing all fireplaces to burn 70% cleaner.

EPA has previously indicated that one of their main concern s when they elected not to have an NSPS for wood burning fireplaces was the potential economic impact of an NSPS on the hearth industry. Well, that economi c impact has quietly happened over the past four years. Nine different companies have qualified 21 fireplace models under the voluntary fireplace program at the Phase 2 emissions level. These companies include IHP as the largest factory built wood burning fireplace company in North America along with Earthcore Industries as the largest manufacturer of modular fireplaces and Whitacre Greer as one of the largest producers of components for site built masonry fireplaces. We believe that collectively the group of companies with EPA Qualified fireplaces represent over 65% market share in the wood burning fireplace category.

Several months ago, FMI submitted an unsolicited proposal to EPA to regulate all future wood burning fireplaces through the adoption of a N ew Source Performance Standard NSPS. We bel ieve that our proposal to EPA was

very persuasive as a health based regulatory initiative. W e feel that we have a diverse range of support for this

initiative from health advocacy groups and regulatory agencies wh o have previously petitioned EPA on this topic.

A federal NSPS for wood burning fireplaces will regulate wood smoke emissions in an equitable way. An NSPS will provide equal protection under the law for everyone in this country, not just those fortunate enough to live in

areas like Northern Utah where there are laws and ordinances that allow responsible wood burning by requiring

the use of Best Available Control Technologies for wood burning fireplaces

. This should be a national standard.

We are therefore officially requesting the adoption of a New Source Performance Standard by the US Environmental Protection Agency for wood burning fireplaces. We respectfully request a written response to this request within 30 days.

Thank you

, Mark Klein

Chief Executive Officer

Innovative Hearth Products