April 29, 2008

Steve Page, Director Office of Air Quality Planning and Standards U.S. Environmental Protection Agency

Mail Code: C404-04 Research Triangle Park, North Carolina 27711

Re: Performance Standards for Wood -burning Device s

Dear Mr. Page:

The Western States Air Resources Council (WESTAR) a nd the Northeast States for Coordinated Air Use Management (NESCAUM) strongly u rge the U.S. Environmental Protection Agency (EPA) to update and develop regul ations relating to a variety of wood combustion devices. The recently revised National Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM 2.5 ) recognizes the public health dangers of excessive fine particulate matter. Unfortunately, many communities throughout the country are measuring ambient conditions above or v ery close to that new standard. In many instances, emissions from wood smoke are a sig nificant contributor to those high

PM 2.5 levels.

Currently, federal regulations only target a limite d universe of wood burning sources, via the New Source Performance Standards (NSPS) for res idential wood heaters (i.e., indoor wood stoves), major New Source Review, and the Maxi mum Achievable Control Technology (MACT) program for boilers. These regul ations, along with state and local minor source permitting, exempt a significant numbe r of devices that greatly, and adversely, affect the environment and public health

.

Indoor Residential Wood Heating Devices

The Residential Wood Heater NSPS, which was develop ed in 1988 and implemented fully by 1992, set emission standards for indoor wood sto ves but excluded a broader suite of residential wood heating devices (RWDs). In additi on, wood heat technology has advanced significantly since the existing standards were phased in almost twenty years ago. New technologies for regulated RWDs are comme rcially available now in the U.S. that perform at significantly lower grams-per-hour emission rates than required under the existing indoor wood stove standard. Furthermore, even greater performance can be2

achieved by technologies employed in Europe. The C lean Air Act requires review of a NSPS every eight years unless determined “that revi ew is not appropriate in light of readily available information on the efficacy of su ch standard.” At a minimum, given the current body of evidence, review and revision of th e current residential wood heater/indoor wood stove NSPS to capture the broader suite of RWD s is appropriate and warranted.

A critical concern of our states is the lack of reg ulations for a broad variety of RWDs that are available for sale and not addressed by the NSP S at all; these include fireplaces, masonry heaters, pellet stoves, and indoor and outd oor wood boilers, furnaces, and heaters. These devices are making their way to market and we urge EPA to develop standards for

them.

As many state and local agencies move forward with strategies to meet the revised PM 2.5 NAAQS, they are implementing new or enhancing their existing “wood stove change-out” programs. These efforts will reduce the number of high-polluting uncertified wood stoves

in local communities. Without new and revised stan dards, however, newly installed devices may not be the cleanest available in the ma rketplace. Ensuring that the change-out programs are replacing uncertified stoves with the cleanest-burning devices available in the marketplace would assure that public and private do llars are spent wisely and on the best possible public health and pollution control outcom es.

In addition, we urge EPA to expand change-out effor ts to include other RWDs by supporting change-outs of all outmoded RWD technolo gies. To support that outcome, we ask EPA to update and develop standards for RWDs in the same manner that emission standards are updated for mobile source technologie s. Newer models should be required to meet lowered emission limits as technology permits, creating a cleaner “fleet” of devices over time. Given that cleaner-burning technologies are readily available in the marketplace, it is a lost public health opportunity to allow the continued manufacture and sale of equipment with low-end, higher-polluting te chnology that will remain in homes for

years to come.

Outdoor Residential Wood Heating Devices

One significant area of concern is outdoor wood-fir ed boilers (or outdoor wood-fired hydronic heaters -- OWHHs). These units represent a new and growing public health concern in both the East and West. They can be hig hly-polluting and, when improperly used, subject neighbors, neighborhoods, and entire communities to serious impacts from particulate matter and products of incomplete combu stion. While EPA’s voluntary program has made great progress towards encouraging the development of cleaner

OWHHs, it has not banned the sale of new units with older, dirtier designs and is not a mandatory program. We therefore urge EPA begin eff orts to develop a technical basis for regulating emissions from these devices.3

Small Commercial and Institutional Wood Boilers

We also urge EPA to develop emission standards for small commercial and institutional wood boilers, especially those being marketed for u se in schools and hospitals. As the price of fossil fuels increases, many schools and h ospitals are considering or installing wood-fired boilers. In many instances, these units are replacing natural gas-fired boilers that emit less particulate matter and other criteri a and air toxic pollutants than wood-fired boilers. For example, a report developed for Wisco nsin Division of Energy reported that more than 300 schools -- representing more than 25 percent of the schools currently heating with natural gas -- would find it economica lly beneficial to switch to wood-fired boilers. Schools, however, are receiving little to no information on the adverse health effects caused by smoke from these boilers, nor are they told of the potential costs of future air pollution control equipment once these dirtier boilers are installed.

Unfortunately, technical data characterizing emissi ons from these units and analyses regarding the efficacy of pollution controls is lac king. This impedes both state and federal activities to properly address these emission sourc es. Therefore, it is critical that EPA direct resources to properly investigate this issue . As energy and forestry programs move forward with their support of these programs, and a s we move towards greater use of biomass resources for space heating purposes, we mu st have methods to ensure protection from exposure to toxic and criteria air pollutant e missions. We therefore urge EPA to immediately invest in analyses to create a technica l basis for characterizing wood boiler emissions to support state and federal regulations for these units.

Conclusion

In light of the new PM 2.5 NAAQS and the preponderance of wood smoke as a sou rce of fine particle pollution in the U.S., further tighte ning of standards for wood heating appliances is essential. Improved standards for ne w wood heating devices would provide a

much needed tool for states and local communities t o use in addressing the growth of pollution from these sources. Typically, EPA regul ations take six to seven years to complete. If EPA were to begin work now on a NSPS, a likely implementation date would be around 2015. However, many federal, state, and local agencies are making investments in renewable energy programs now. If not implement ed properly, these programs are likely to encourage increases in air pollution, esp ecially air toxics and particulate matter. Therefore, it is essential that EPA provide guidanc e now during this crucial time.4

We urge you to move forward promptly on these impor tant issues. We would be happy to meet with you to discuss this issue in greater deta il. If you have any questions, please

contact either Arthur Marin at 617-259-2017 or Dan Johnson at 206-254-9145.

Sincerely,

Arthur Marin, Executive Director Dan Johnson, Exe cutive Director

NESCAUM WESTAR

cc: Rob Brenner Greg Green