E

C

/R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Dr., Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919) 484-0222  Fax: (919) 484-0122

MEMORANDUM

TO: Docket EPA-HQ-OAR-2009-0734

FROM: Jill Mozier, EC/R Inc.

DATE: February 14, 2014

SUBJECT: Notes from the EPA Air Toxics Risk Assessors Call, February 13, 2014, with 

Leigh Herrington and Gil Wood as presenters

The EPA Air Toxics Risk Assessors (ATRA) Call was moderated by Kyle Olson of USEPA 

Region 8. Leigh Herrington of EPA’s voluntary Burn Wise program presented her overview 

slides first (attached) and then answered questions. Next, Gil Wood presented overview slides 

(also attached) summarizing the proposed Residential Wood Heater NSPS and answered 

questions following his presentation. 

The questions and answers following Leigh’s Burn Wise presentation were as follows:

 Question for Leigh: Are you going to expand the voluntary program to firepits and other 

backyard devices?

Answer: Leigh noted that this is becoming a higher priority for regions and that Region 5, 

for example, has developed policy around burn barrels. Leigh answered that overall, no, 

EPA’s Burn Wise program is not expanding within the next few months although they 

are not discounting expanding at some point in the future. Currently the program’s focus 

is to educate regarding the appropriate fuel source characteristics for wood burning.

 Question for Leigh: How successful has this program been, given that there are no 

incentives or money to help homeowners? And are there incentives being offered from or 

to manufacturers?

Answer: Leigh noted that there are many ways to measure success and that one measure 

is the number of manufacturers who have joined the program. One incentive the 

manufacturers have is that they know they must improve their technology to remain in 

the market long-term. While the number of manufacturers in the program is not very 

large, it is a decent portion of the market and there are now cleaner devices in homes as a 

result of this voluntary program. For example, Libby, Montana and other places are 

seeing a difference in their PM levels due to changeout programs. Manufacturers are 

behind changeouts as well; changouts are in their interests and bringing cleaner 

technology to the market helps manufacturers stay relevant. In terms of consumer 

penetration, the Burn Wise program is still too shallow and needs help from locals and 

states to reach consumers. But the program has been successful in helping to encourage 

and bring cleaner technologies to market.
2

 Question for Leigh and Gil: Are cleaner technologies also more efficient technologies? 

 Answer: Leigh answered that cleaner technologies are not necessarily also more efficient 

and asked Gil to explain further. Gil Wood explained that in general as device technology 

becomes cleaner it also becomes more efficient, but that as Leigh noted it is not a one-toone correlation. A typical stove default efficiency value based on the current 1988 rule is 

65% (although many devices are not as efficient as this default value). Today’s cleaner 

technologies can reach 85% efficiency. 

 Question for Leigh: A call participant noted that there exist conspiracy theories which 

purport that EPA is making a concerted effort to freeze out rural Americans who are 

living off the grid – i.e., that EPA is seeking to make wood stoves illegal or at least much 

more difficult for rural America to use.

Answer: Leigh noted that EPA is aware that there are many misconceptions being 

propagated about both the Burn Wise program and the proposed NSPS, and that EPA is 

considering directly addressing the top myths that are circulating in an effort to correct 

the misinformation. She noted that Larry Brockman (also of EPA’s Burn Wise program) 

is working with Alison Davis, an EPA press officer, to address the misconceptions and 

conspiracy theories. The bottom line is that EPA is not going after people’s wood stoves 

and in fact does not have that goal or such authority in any event. EPA is merely 

attempting to educate consumers about the best type wood to burn in terms of least 

polluting and most efficient, the cleanest wood stoves available on the market, and to 

push manufacturers to produce the cleanest technologies possible for future market sales.

The questions and answers following Gil’s proposed NSPS presentation were as follows:

 Question for Gil: There will presumably be more inspections under the proposed NSPS

and yet everything we’re reading about regarding EPA’s realignment (specifically with 

regards to the Office of Enforcement and Compliance Assurance, OECA) implies there 

will be less EPA inspections.

Answer: Gil noted that there will continue to be the appropriate and necessary inspections 

by EPA’s OECA, but that initial inspections will be performed not by EPA but by ISOaccredited bodies. With EPA resource limitations, OECA is faced with more rules than 

current resources allow for OECA-only inspections everywhere. Hence the proposed 

wood heater NSPS calls for ISO-accredited bodies to perform quarterly unannounced 

inspections at all manufacturing facilities and also allows delegation to the states [upon 

request and approval] so that states can also conduct site observations of manufacturing 

and of testing.

 Question for Gil: Can we send out your presentation slides to the states participating in 

the Northeast States for Coordinated Air Use Management (NESCAUM)?

Answer: Gil answered that yes, there is no problem in releasing the slides; they are public 

information. 

 Question for Gil: Do you want us to encourage the NESCAUM states to register to speak 

at the public hearing?
3

Answer: Gil answered that yes, the more who register to speak the better. Although 

submitting a comment to the public docket is just as good/effective, it is nice to hear from 

people directly.

 There were no further questions.