6/8/2010 1

Revision of Subpart AAA

Residential Wood Heaters

& Additional New Source 

Performance Standards (NSPS)

Pre-Panel Outreach Meeting

with Small Entity Representatives (SERs)

June 29, 2010
6/8/2010 2

Agenda

 Introduction

 Background, perspective, and regulatory history

 Overview of proposals under consideration

 Applicable small entity definitions

 Small entities that may be subject to the regulation

 Regulatory Flexibility Options for Small Entities

 Example options by sub-categories

 Very large benefits

 Costs
6/8/2010 3

Background

 Current rule requires manufacturers of new residential wood 

heaters (e.g., wood stoves) to design heaters to meet particulate 

emission (PM) limits, have representative model lines tested by 

EPA-accredited labs, and attach EPA labels and hangtags after 

EPA approval

 Originally promulgated February 26, 1988

 Proposal was first regulatory negotiation by EPA (included 

industry, labs, states, consumer advocates)

 Not substantively reviewed until now

 Revisions are not negotiation but are transparent, open 

government rulemaking (www.epa.gov/open)
6/8/2010 4

Perspective: Wood Smoke PM2.5 Emissions 

Are Significant 

 2008 National Emission Inventory: 2,449,000 tons

 2008 Residential Wood Combustion:(~13%) 318,323 tons 

 Fireplace: general 51,132

 Woodstove: fireplace inserts, non-certified 54,286

 Woodstove: fireplace inserts, certified, non-catalytic 12,017

 Woodstove: fireplace inserts, certified, catalytic 4,245

 Woodstove: freestanding, non-certified 71,424

 Woodstove: freestanding, certified, non-catalytic 15,092

 Woodstove: freestanding, certified, catalytic 7,911

 Woodstove: pellet-fired, general 1,798

 Furnace: indoor, cordwood-fired, non-certified 36,213

 Hydronic Heater: outdoor 50,427

 Outdoor Wood Burning Device 7,105

Note: Wood smoke emissions also include other pollutants. Nationally, residential wood 

combustion accounts for 44 percent of total stationary and mobile polycyclic organic 

matter (POM) emissions and 62 percent of the 7-polycyclic aromatic hydrocarbons 

(PAH), which are probable human carcinogens and are of great concern to EPA.
Perspective: Wood Smoke Can Cause 

Significant Health Effects

 There are a number of communities where residential wood 

smoke can increase particle pollution to levels that cause 

significant health concerns (e.g., asthma attacks, heart attacks, 

premature death).

 Several areas with wood smoke problems either exceed EPA’s 

health-based standards for fine particles or are on the cusp of 

exceeding those standards.

 For example, residential wood smoke contributes 25 percent of 

the wintertime pollution problem in Keene, New Hampshire.

 In places such as Sacramento, California, and Tacoma, 

Washington, wood smoke makes up over 50 percent of the 

wintertime particle pollution problem.
6/8/2010 6

Perspective: State, Local, and Tribal Officials 

Working to Reduce Wood Smoke Emissions

 Wood smoke programs are very important in numerous areas 

working to attain or maintain the National Ambient Air Quality 

Standards (NAAQS) or to avoid exceeding the NAAQS.

 Some have implemented changeouts; some have implemented 

burn bans; while others have implemented combinations of 

education, wood-burning curtailment and changeout programs.

 EPA has provided: “Strategies for Reducing Residential Wood 

Smoke”, EPA-456/B-09-001,October 29, 2009 

http://www.epa.gov/ttn/oarpg/t1/memoranda/strategies-doc-8-

11-09.pdf

 For areas that are not meeting or may not meet the NAAQS for 

fine particles, EPA has encouraged a wood smoke reduction 

plan to achieve wood smoke emission reductions as soon as 

possible.
6/8/2010 7

Perspective: EPA Encourages Replacement of PreNSPS Wood Stoves with Newer, Cleaner Appliances

 Replacing pre-NSPS wood stoves with newer, cleaner, more efficient 

appliances, can reduce fine particle emissions by ~70%

 EPA’s wood stove focus of the last 5 years has been on encouraging 

replacements because they can result in very large emission reductions, greater 

energy efficiency, less wood burned, and less money wasted.

 For example, a wood stove changeout program implemented in Libby, Montana 

changed out over 1,100 wood stoves and reduced wintertime particle pollution levels 

by 7 micrograms per cubic meter (~28%). This reduction has helped Libby attain the 

1997 annual and 24-hour fine particle national standards. Also, indoor pollution was 

reduced by ~70%.

 Over 44 areas have conducted changeout campaigns. For more info, see 

www.epa.gov/burnwise

 While changeouts can provide significant air quality improvements, EPA and 

NACAA (National Association of Clean Air Agencies) and industry want the 

replacements to be today’s technology, not 1988 technology!

 When asked, EPA has been very supportive of tax incentives for more efficient 

and cleaner appliances.
6/8/2010 8

Perspective: EPA Encourages Best Practices 

via “Burn Wise”

 “Learn before you burn” 

 “Burn the right wood, the right way, in the right 

appliance”

 “Your choices and actions make a difference”

 “A properly installed, correctly used wood-burning 

appliance should be smoke-free. If you see or smell 

smoke, that means you may have a problem”

 EPA continues to coordinate efforts with industry and 

NACAA

 For more info, see www.epa.gov/burnwise
6/8/2010 9

Serious Concerns about Hydronic Heaters, 

aka Outdoor Wood Boilers 

 An outdoor wood boiler (OWB) combusts wood to 

heat water that is typically piped to another building 

for heat and hot water

 Technically, it is not a “boiler” but a “hydronic heater” 

(it typically heats but doesn’t boil the water)

 Old dirty OWBs are a significant problem in 

numerous areas because of high emissions, short 

stacks, too close to neighbors

 A few pictures to illustrate...
6/8/2010 10

How Outdoor Wood Boilers Work

Diagram Courtesy of HPBA
6/8/2010 11

Photos courtesy of Vermont DEC

Photos of OWB Emissions
6/8/2010 12

Petition to Regulate OWBs

 From 6 northeastern states plus Michigan and 

NESCAUM (Northeast States for Coordinated Air 

Use Management)

 Requested EPA develop an NSPS for OWB or revise 

the current wood stove NSPS to include OWB

 Our initial response:

 We developed a voluntary program and provided technical 

and financial support for NESCAUM model rule... faster than 

an EPA regulation...

 Phase 1 rolled out January 2007

 22 partners, 12 qualified models (70% reduction)
6/8/2010 13

Industry Request for OWB Rules

 September 27, 2007 letter

 From Hearth, Patio, and Barbecue Association (HPBA)

 Outdoor Wood-fired Hydronic Heater (OWHH) Caucus

 Expressed “unanimous support for EPA 

establishment of an NSPS for OWHH”

 Their concern was proliferation of local bans and 

state rules with differing requirements
6/8/2010 14

Wood Stove NSPS Revision Request

 April 29, 2008 joint letter to EPA

 From NESCAUM and WESTAR (Western States Air 

Resources Council)

 Requesting:

 “review and revision of the current residential wood heater/ 

indoor wood stove NSPS to capture the broader suite of 

RWD (residential wood heating devices)”

 “fireplaces, masonry heaters, pellet stoves, and indoor and 

outdoor wood boilers, furnaces, and heaters... we urge EPA 

to develop standards...”
6/8/2010 15

EPA Initial Response: Develop Additional 

Voluntary Programs

 Faster than a Federal Regulation

 October 2008 Phase 2 Hydronic Heaters Program

 Tightened qualifying level (~90% overall reduction), 

expanded to indoor units, other solid biomass

 13 Phase 2 models have qualified, more in pipeline

 February 2009 Low-Mass (Manufactured) Fireplace 

Program

 Phase 1 and Phase 2 simultaneously

 July 2009 expanded to include Masonry Fireplaces

 6 models have qualified at Phase 2 level (~70% reduction), 

more in pipeline

 Considering tightening Phase 2 level
6/8/2010 16

EPA Announcement for Review and 

Revision of the NSPS

 Draft Review Document prepared

 Draft Preliminary Conclusions prepared

 Drafts released on November 4, 2009

 Have conducted numerous outreach presentations

 Have posted info on Burn Wise website
6/8/2010 17

Overview of Proposals under 

Consideration

 Tighten emission limits to reflect today’s Best Demonstrated 

Technology (BDT)

 Close “loopholes,” eliminate exemptions (e.g., cook stoves)

 Add pellet stoves explicitly

 Add wood “boilers” (hydronic heaters) and furnaces

 Revise test methods as appropriate

 Streamline certification process & incorporate International 

Standards Organization (ISO) process plus compliance 

affirmation

 Improve compliance assurance & enforceability

 Regulate fireplaces

 Regulate devices fueled by other solid biomass, e.g., corn, 

various pelletized biomass

 Regulate coal-fired heaters (in order to level the playing field)
6/8/2010 18

No Recommended Specific Emissions Limits 

Yet Because Data Are Still Being Analyzed

For example:

 An analysis shows that the burn rates used in 1988 for the NSPS should be increased an 

unspecified amount because of differences in burn end points in test methods used.

 HPBA has provided additional information on fireplace potential emission reductions.

 HPBA has provided a review of emissions per burn rate for certified stoves; however, there 

is concern that the NSPS equation for conversions between 5G and 5H is erroneous and 

needs to be re-established. EPA-accredited labs will conduct additional tests to do this. 

 EPA is using §114 authority to request data for currently exempt pellet stoves.

 EPA is reviewing costs and analyzing market and economic data. 

 Bioenergy2020+ has recently finalized a review of advanced combustion technology 

performance in Europe.

 Catalytic Hearth Coalition is conducting a review of catalytic performance versus time.

 EPA’s Office of Research and Development is analyzing results of their tests of hydronic 

heaters, including typical and advanced designs.
6/8/2010 19

Still Reviewing Test Methods

For example:

 EPA & HPBA are participating on numerous ASTM work groups

 HPBA participated on revision of Canadian method B415.1

 NYSERDA (New York State Energy Research and Development 

Authority) and EPA and others are reviewing European test 

methods

 Continuing concern of “real world variability ” vs. lab tests, cribs, 

etc. 

 Continuing discussions on emissions averaging (burn rate 

weightings), low burn rate, number of runs, time for hot start, 

caps, degradation, etc.

 Efficiency test methods (ASTM, CSA B415.1, etc.)
6/8/2010 20

Anticipate More Inclusive Scope

 Pellet stoves – emission data show excellent performance potential with 

premium pellets; need pellet fuel quality standards to ensure good performance 

and lower emissions

 Masonry heaters – considering development of 2-prong NSPS (emission limit 

and design option) 

 Cook stoves – considering improved definition of “traditional North American 

cook stoves” (estimated to affect <2000 units)

 Also considering definitions of “traditional Native American bake ovens” and 

“ceremonial fires” so that they may be excluded

 Hydronic heaters

 Over a dozen U.S. models already qualified at Phase 2 voluntary level

 Typical European levels are much lower than Phase 2 voluntary level

 Some new designs avoid operation at typically dirty low burn rates

 Considering requiring heat storage which greatly reduces emissions 

 Furnaces – manufacturers are beginning to get on board with developing BDT

 Fireplaces – numerous air agencies want regulations but HPBA has 

recommended that EPA allow the voluntary program to mature first

 Coal – asked for data, will test, may use transfer of technology
6/8/2010 21

Pollutants

 PM2.5 (>85% of the PM) is our focus

 Black Carbon, CO, CO2, CH4, N2O?

 Limited testing planned, principally for informational 

purposes

 Perhaps CO and efficiency limits which will also reduce 

PM2.5 emissions
6/8/2010 22

Environmental Justice

 A tighter, more comprehensive NSPS will reduce 

environmental impacts for all

 Preliminary draft analysis results show no disparate 

impacts nationally

 We may look closer at a few specific geographic 

areas

 For now, we foresee no EJ-focused changes to the 

NSPS that would not apply to everyone
6/8/2010 23

Compliance & Enforcement Aspects

We intend to:

 Streamline certification process --- develop electronic system for 

submittals and approvals

 Improve compliance assurance --- inspections of labs and 

manufacturers, random audits, monitor websites and trade 

shows and fairs, alert foreign companies 

 Make consumer-friendly --- Burn Wise website, spreadsheets of 

certifications ranked by emissions, tested efficiency, output

 Incentivize lab proficiency testing?

 Streamline recordkeeping and reporting of manufacturing 

tolerances and quality control

 Require compliance tests on “worst” grade of each type of pellet 

that manufacturer specifies/warrants for use

 Require Federal rules on pellet quality if adequate industry 

standards are not in place in time (see next slide)
6/8/2010 24

Pellet Standards Specifications Needs

 EPA has encouraged pellet manufacturers and appliance 

manufacturers to quickly meet and agree on grades of necessary 

characteristics, for example: 

 Durability

 Ash %

 Fines %

 Fusion properties

 Limits on bark, dirt, sand, construction debris, chemicals, etc. 

 Tailored QA/QC plans, training, transparency 

 Testing frequency tailored to results 

 Not just 3rd party analyses but also 3rd party inspections, approval of 

QA/QC plans, sampling, auditing, corrective actions, certification of 

conformity, reporting of results 

 Goal: pellets that consumers, manufacturers, and Congress can 

consistently depend upon as they consider decisions to buy and/or 

support biomass
6/8/2010 25

Small Business Definitions

 Most of the affected companies are small businesses

 Typically the size cutoff is 500 employees. Most of 

the affected companies are much, much smaller than 

that

 A few are subsidiaries of large companies, e.g., 

Hearth and Home Technologies is a subsidiary of 

HNI Corporation
6/8/2010 26

Small Businesses Affected

 There are some small businesses in every sector of 

the residential heater industry

 Thus, we are considering minimizing potential 

impacts on small businesses throughout the rule 

development effort
6/8/2010 27

Regulatory Flexibility Options 

for Small Entities

 Since most companies are small businesses, we will carefully consider all 

options

 Current NSPS gave additional time for initial compliance for small volume 

manufacturers – we expect to do that again

 Current NSPS allows manufacturers to show compliance by model lines rather 

than testing each source – we expect to continue that approach to reduce costs

 As we transition to an ISO-accredited lab approach, we expect to give additional 

time to small labs that have experience as EPA-accredited labs

 For masonry heaters and site-built masonry fireplaces, we are working with the 

companies to consider a 2-prong NSPS that allows use of previously approved 

equipment standard options in lieu of testing each new model line

 For single-burn-rate appliances, we are working with the companies to consider 

appropriate modifications to the test method 

 For “traditional North American cook stoves” and “camp stoves”, we are working 

with the companies to consider definitions/equipment standards to reduce 

impacts

 For “traditional Native American bake ovens”, we are working with Tribes to 

develop a definition that will likely exclude such devices

 For indoor and outdoor hydronic heaters and forced air furnaces, we are working 

with industry to consider appropriate modifications to the test method to consider 

more flexibility in heat storage options and burn rate options
6/8/2010 28

Options for Emission Limits

 Emission levels and costs are still being developed

 Thus, the following slides are examples for early 

discussions only
6/8/2010 29

Wood Stove Example Options

 1988 NSPS:

 7.5 g/hr for non-catalytic

 4.1 g/hr for catalytic

 1998 Washington State limits

 4.5 g/hr for non-catalytic

 2.5 g/hr for catalytic

 On sales-weighted basis, over 85% meet today

 Require at promulgation?

 New NSPS limits for 2014

 3.0 g/hr for either? (~half of “WA stoves” meet today)

 2.5 g/hr? (~1/4 of “WA stoves” meet today)

 2.0 g/hr? (>12% of “WA stoves” meet today)
6/8/2010 30

Pellet Stove Example Options

 1988 NSPS:

 7.5 g/hr for non-catalytic

 4.1 g/hr for catalytic

 However, most pellet stoves are exempt via the 35:1 air-to-fuel ratio 

exemption

 1998 Washington State limits:

 4.5 g/hr for non-catalytic

 2.5 g/hr for catalytic 

 Oregon tax credit level: 2.5 g/hr

 Require at promulgation? 

 Match Wood Stove NSPS 2014 level: ~2.0 g/hr?

 over 2/3 of pellet stoves meet today

 Pellet Stove NSPS 2014 level: 1.0 g/hr ?

 over 1/3 of pellet stoves meet today
6/8/2010 31

Hydronic Heater Example Options

 Exempt from 1988 NSPS

 Typical emissions: >4 lb /mmBTU heat output

 EPA 2010 Phase 2 Voluntary Level:

 0.32 lb / mmBTU heat output

 >14 EPA-qualified models already 

 Require at NSPS promulgation?

 Typical State 2010 regulatory level:

 0.32 lb / mmBTU heat output

 Many local jurisdictions ban HH

 New NSPS limit for 2014 ?

 0.20 lb / mmBTU heat output ?

 >7 EPA-qualified models already

 0.15 lb/mmBTU heat output?

 >3 EPA-qualified models already

 >100 models qualified by EN 303-05 are estimated to meet this level

 Maine Voluntary Phase 3 level:

 0.06 lb/mmBTU heat output

 Many models qualified by EN 303-05 models are estimated to meet this level
6/8/2010 32

Fireplace Example Options

 Most are exempt from 1988 NSPS via exemptions for >35:1 air-to-fuel 

ratio or “open masonry fireplace constructed on site”

 Typical emissions: 12 g/kg where not regulated

 1988 Washington State limit

 7.3 g/kg of wood burned

 EPA 2010 Phase 2 Voluntary Level:

 5.1 g/kg

 EPA 2011 Phase 2 Voluntary Level

 TBD g/kg of wood burned?

 Typical California AQMD 2010 regulations:

 Ban

 NSPS 2014 levels ?

 Allow Open doors: 4.0 g/kg?

 >4 models already meet this level

 Require Closed doors: 1 g/kg?

 numerous models can meet this level with doors closed 
6/8/2010 33

Masonry Heater Example Options

 Exempt from 1988 NSPS via weight exemption (800 

kg)

 Colorado limit: 6 g/kg

 Industry request for EPA to initiate voluntary 

program:

 2.0 g/hr daily average, 0.13 g/MJ (0.32 lb/mmBTU heat 

output)

 NSPS 2014 level?

 2.0 g/hr daily average, 0.32 lb /mmBTU heat output, plus 7.5 

g/hr max while burning
6/8/2010 34

Single-Burn-Rate Appliance Example

Options

 Exempt from 1988 NSPS

 NSPS 2014 level? 

 “Camp stoves” must be for temporary use?

 Same as wood stoves, except burn rates?
6/8/2010 35

Cook Stoves Example Options

 Exempt from 1988 NSPS

 NSPS 2014 levels?

 Design requirements for “North American traditional cook 

stove”?

 Estimates of less than 3000 units per year

 Some States, same as wood stoves

 European BAT: 3.0 g/hr?
6/8/2010 36

Forced-Air Furnace Example Options

 Exempt from 1988 NSPS

 Canadian B415.1 level

 0.60 lb/mmBTU heat output

 Require at NSPS promulgation?

 NSPS 2014 level?

 Same as hydronic heaters?

 To level the playing field

 Allow longer time?
6/8/2010 37

Coal Stoves Example Options

 Exempt from 1988 NSPS

 NSPS 2014 level?

 Same as wood stoves?

 To level the playing field

 Allow longer time?
6/8/2010 38

Very Large Benefits

 Will be more specific after the options are clearer

 For perspective, the overall benefits for wood 

residential wood smoke emission reductions are 

~$500,000/ton of PM2.5 emissions reduced (actual 

values will vary by location)

 For example, the benefits of changing out all the old 

wood stoves in the U.S. to 1988 NSPS level 

appliances are $35 billion to $86 billion per year

 This is based principally on reductions in mortality, 

non-fatal heart attacks, and chronic bronchitis
6/8/2010 39

Costs

 Will be more specific after the options are clearer

 For perspective: wood stove retail sales prices are 

correlated with looks and size more than emissions... 

marketed “like furniture and how it looks in the room”

 For perspective: there are large differences in base 

costs within most appliance categories, regardless of 

emission considerations

 For perspective: hydronic heater Phase 2 voluntary 

program model sales prices are ~25% greater than 

base model prices
6/8/2010 40

Contacts:

Gil Wood

wood.gil@epa.gov

(919) 541-5272

David Cole

cole.david@epa.gov

(919) 541-5565