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From: "cneufeld" <cneufeld@bmi.net> To: Gil W ood/RTP/USEPA/US@EPA Date: 04/09/2012 10:26 AM Subject: RE: CHC Concerns

Gil: You are correct. E ngineering time required to develop a catalytic wood stove is far less than a non catalytic. I n fact, since the fall of 2010, we developed, tested and received EPA approval for two different catalytic fireboxes. W e have a single engine er, Mr. Ivo Hoovers, who developed both fireboxes. As for patents, ours expired many , many years ago. I n fact, the hybrid wood stove patent that another ma nufacture has applied for is somewhat interesting. I n 1983, Blaze King built, by current definiti ons, a hy brid wood stove. I t used both secondary air tubes and a catalytic combustor. W e have advised the patent office of this fact. In 2011, at our industry Expo (you were present as I recall) major players did not display catalytic wood stoves. O ne ye ar later, Travis, Regency and others are all now promoting the catalytic models they have ma de and that are coming to market. O ne of the most outspoken manufacturers, with solid political connections, does not even know that his anti

- catalytic statemen ts in past are about to cause some awkwardness. T heir corporate offices and engineering labs overseas are buying combustors for their new catalytic prototypes! As for the old R & C (research and copy) it is indeed far more prevalent that you might ever im agine. As far as catalyst suppliers, they will sell without restriction. I n fact, in the past year, several new US suppliers have really picked up on the market potential and have approached wood stove manufacturers. There are at least 7 manufacturers, Blaze King, W oodstock Soapstone, Vermont Castings, Kuma, Buck, Regency, Travis, and others currently making or introducing catalytic models. I would expect that a single standard would encourage manufacturers to make cleaner burning stoves, both catalytic and non catalytic;ytic alike. Wh at I feel is important, as you know since I have said this so many times in the past three years, testing requirements and standards should both reflect and be based upon how wood stoves are used in a home not a test l ab. W ood stoves spend 80% of their time on low settings. C atalytic wood stoves shine on the lowest settings and even on high burn are cleaner than most non catalytic models. Keep in mind that if a catalytic wood stove is certified at 1.0 gr/hr., that i s the average based on the four burns. I n fact, since 80% of the time the stove is actually burned on a lower setting, the emissions are mu ch, much lower than 1.0 gr/hr. In a non catalytic model, you have the inverse scenario. A non catalytic model certified at 3.5 gr/hr, spending 80% of the time on low, is actually producing more than 3.5 since low is where they burn dirtiest. Now you can see why industry wants to increase the low burn rate by 15% to 1.15kg/hr. I t's just out right gam e pla ying. I was on a call two weeks ago with most of the industry executives and they were complaining about the70% HHV efficiency requirement stating that 30% of the stoves on the market would not make that

num ber. I spoke up and said, " In the pest two years you h ave all beat your chests and said your stoves were more than 75% efficient so your products would qualify for the tax credit. N ow, the HHV efficiency gets introduced, which is more reflective of real world use and you're all worked up about it." They me t with EPA staff last week to raise their concerns over the matters and I hope EPA stays the course! I will loose two models, but that's o.k., we'll just innovate, build cleaner and more efficient mo dels. I sn't that what the NSPS is all about? Thanks C hris PS I am off to by a bullet proof vest for m y next industry wide meeting.

**From:** Gil Wood [mailto:Wood.Gil@epamail.epa.gov] **Sent:** Monday, April 09, 2012 6:19 AM **To:** cneufeld **Subject:** RE: CHC Concerns
Thank you for the confidential cost info Chris! A continuing issue for having one emission limit for both catalytic and noncatalytic stoves is the cost for R& D for noncatalytic manufacturers to develop catalytic stoves [or other low emission systems] that meet the tighter emission limits that c atalytic stoves can already easily meet... To me, it seems like a manufacturer or consultant that has experience developing EPA

- certified noncatalytic stoves could also develop a new catalytic stove a lot cheaper than what it took for them to develop thei r EPA

- certified noncatalytic stove... since presumably they already know a lot about com bustion and materials and the catalyst will do a lot of the additional work to get the emissions even lower... Wo uld one engineer for a year seem reasonable? How solid are the stove patents for BlazeKing and other companies that make catalytic stoves? I presume some competitors will tr y to reverse engineer from what they see from your stoves... Do you sell licenses for your stove catalyst integration technology? I pr esume there are no limits by the catalyst manufacturers on buying/using their catalysts, right? How long do you think it would take to meet the total stove demand mostly by catalytic stoves instead of mo stly noncats? Thanks again. Gil