Proposed New Source Performance Standards

for New Residential Wood Heaters,

New Residential Hydronic Heaters,

New Forced-Air Furnaces, and New Residential 

Masonry Heaters

EO 12866 Review

Briefing for OMB

July 17, 2013
Background

► Section 111 of the Clean Air Act (CAA) requires EPA to set New Source 

Performance Standards (NSPS) for categories that cause, or significantly 

contribute to, air pollution that may endanger public health or welfare. 

► The CAA requires NSPS to reflect best system of emission reduction (BSER), 

taking into account costs.

► Residential wood combustion is a significant source of fine particle pollution, 

emitting more than 350,000 tons of fine particles in 2008, according to EPA’s 

National Emissions Inventory. Several areas are nonattainment (NA) or near NA

due largely to wood smoke.

► Wood smoke is made up of a mixture of gases and fine particles that are 

produced when wood and other organic matter burns. The fine particles in 

smoke – also called fine particle pollution or PM2.5 – can get deep into the lungs, 

harming both the lungs and heart. People with heart or lung disease, older 

adults and children are the most at risk.

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Background (continued)

► The current NSPS for residential wood heaters were promulgated by EPA in 1988. 

► The 1988 standards were developed through a regulatory negotiation process that included 

representatives of the environmental community, consumer groups, state air pollution 

control and energy agencies, industry, and EPA. 

► Wood heater technology has improved greatly since 1988.

► The CAA requires EPA to review these standards every 8 years. 

► EPA has received many requests from states, local agencies, tribes, environmental 

groups, industry, and the public to strengthen the NSPS to help protect public health. 

► Numerous states have requested this rule, because some areas with wood smoke 

problems either are exceeding (or close to exceeding) the health-based NAAQS for fine 

particles. For example, in places such as Keene, NH, Sacramento, CA, Tacoma, WA, and 

Fairbanks, AL, wood combustion can contribute over 50 percent of daily wintertime fine 

particle emissions. States are required to develop State Implementation Plans and may 

have to consider higher cost (and less effective) regulations without this rule. 

► EPA has also received a petition from the Northeast States, and letters and resolutions from 

the Environmental Council of States, the National Association of Clean Air Agencies, 

Western States Air Resources Council, Central States Air Resources Agencies, Lake 

Michigan Air Directors Consortium, Mid-Atlantic Regional Air Management Association, and 

Northeast States for Coordinated Air Use Management encouraging the agency to develop 

these standards.

► Industry has requested a federal rule because of the patchwork of existing and feared state 

and local rules and bans.

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Current Action

► The proposal will...

► strengthen the standards for new wood stoves 

► set emission limits (for the first time) for new hydronic heaters

► set emission limits for new pellet stoves, new wood-fired forced-air furnaces, new 

masonry wood heaters, and new “single-burn-rate” stoves

► provide significant lead time for manufacturers to adapt best technology across model 

lines, produce cleaner models, and sell current stocks

► significantly reduce fine particle pollution from new stoves and other wood heaters. 

Emissions of volatile organic compounds, carbon monoxide, hazardous air pollutants 

and greenhouse gases also will be reduced. The benefits greatly exceed the costs.

► The proposal will not...

► affect heaters that are fueled solely by oil, gas or coal

► apply to existing wood heaters

► apply to fireplaces (which typically are not “heaters”)

► New models will be more efficient. Homeowners will get more heat from the wood 

they burn.

► EPA plans to take public comment for 90 days and hold two public hearings.

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EPA’s Voluntary Partnership Program for Hydronic Heaters

► EPA developed a voluntary program to encourage manufacturers to redesign 

their models to reduce emissions -- faster than an EPA regulation

• Phase 1 rolled out January 2007

• 22 Phase 1 partners, 12 Phase 1 qualified models (>70% reduction in emissions)

► At the same time, the Northeast States for Coordinated Air Use 

Management developed a “model rule”...

• Many states used the model rule as the starting point for adopting state rules to control 

emissions from certain wood-fired devices

• Many areas required set-back distances

• Some local areas banned hydronic heaters

► EPA developed Phase 2 of the voluntary program to further reduce 

emissions

• Phase 2 started in October 2008 and over a dozen states require the Phase 2-level (or better)

• Currently, there are 39 Phase 2 qualified models (90% reduction in emissions)

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Small Business Regulatory Enforcement Fairness Act 

(SBREFA)

► Some of the options considered in the proposal have the potential for a 

significant economic impact on a number of small entities.

► EPA convened a SBREFA panel on August 4, 2010.

► As a result of the panel recommendations and additional discussions with small 

entities, this proposal incorporates reasonable time for all manufacturers to 

develop cleaner models by allowing a phased approach.

► This proposal includes additional time for small-volume manufacturers of some 

heaters.

► A full discussion of the SBREFA panel recommendations and EPA’s actions to 

reduce the potential impacts on small businesses will be included in the 

preamble.

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Summary of Proposed Requirements

► EPA is proposing that each type of new residential wood heater meet PM 

emission limits in a 2-step approach

► Step 1 – effective upon promulgation

► Step 2 – effective 5 years after promulgation - provides time for additional research 

and development (R&D)

► EPA is also taking comment on a 3-step approach with a longer compliance 

timeframe

► Step 1 – effective upon promulgation (note: same emission limit as Step 1 in 2-step 

approach)

► Step 2 – effective 3 years after promulgation

► Step 3 – effective 8 years after promulgation (note: same emission limit as Step 2 in 

2-step approach) – provides more time for additional R&D

► See proposed emission limits in the Appendices.

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Projected Impacts

► PM2.5 from new heaters would be reduced by >4,800 tons/year over the 2014-

2022 timeframe.

► Many reductions would be in NA areas or areas on the cusp of NA, where states are looking for every 

cost-effective reduction they can attain.

► States and local agencies are greatly concerned that the emissions are near ground level and close 

to homes and have caused significant health effects, especially due to hydronic heater emissions. 

► Health benefits would be $1.7 billion to $4.2 billion/year. (2010 dollars)

► Non-monetized benefits would be:

► 33,000 tons of carbon monoxide reductions

► 3,200 tons of volatile organic compounds reductions

► Reduced exposure to hazardous air pollutants, including formaldehyde, benzene, and polycyclic 

organic matter

► Reduced climate effects due to reduced black carbon emissions

► Reduced ecosystem effects

► Reduced visibility impairments

► Cost-to-receipts ratios would potentially range from 2.3 percent for pellet stoves 

to 6.4 percent for single burn rate stoves.

► Cost effectiveness values ($/ton) for PM2.5 would be very reasonable:

► $471 for Wood Heaters

► $50 for Single Burn Rate Heaters

► $1,513 for Pellet Stoves

► $37 for Indoor Furnaces

► $160 for Hydronic Heaters

► $123 for total rule

► Total rule costs would be ~$16 million per year -- far less than the monetized 

benefits.

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Anticipated Public and Stakeholder Response

► States, local agencies, and tribes strongly support strengthened standards. 

Some need these NSPS to help them meet the PM2.5 national ambient air quality 

standards. 

► Environmental groups strongly support strengthened standards and, in 

particular, stringent limits on hydronic heaters.

► Most public feedback supports strong regulations, especially for hydronic 

heaters.

► Industry groups agree that standards are needed for hydronic heaters and 

forced-air furnaces and that it is appropriate to update the wood stove standards 

to at least the State of Washington levels. Manufacturers of the cleaner models 

support the levels in this proposal or those more stringent. 

► Some industry groups question the cost effectiveness and potential economic 

impacts of some more stringent proposed options.

► At least one fireplace manufacturer questions why the agency is not proposing 

standards for new fireplaces.

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Appendices

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Wood Heaters Rulemaking History

► On February 26, 1988, EPA published the original NSPS for residential wood heaters.

► In 1995, Washington State tightened their state emission limits. Almost all manufacturers 

chose to meet the WA limits for all U.S. models. Today, over 85% of EPA-certified models 

meet the WA emission levels. 

► In November 2009, EPA released a draft review document with preliminary draft conclusions.

► EPA conducted numerous stakeholder outreach activities and prepared the technical and 

economic information necessary for a draft proposal. EPA management committed to a 

strong proposal for all stakeholders and solicited additional feedback from stakeholders.

► In November 2012, state and local air pollution control agencies hosted a national forum for 

a broad range of stakeholders (including EPA, manufacturers, health organizations, and 

environmental groups) to discuss the issues and potential options.

► EPA prepared new options for this draft proposal after consideration of the information and 

recommendations discussed in November 2012 and in numerous follow-up discussions.

► This proposal reflects current best systems of emission reduction and adds emission limits 

for new heaters that were not regulated in 1988, such as indoor and outdoor wood boilers, 

forced-air furnaces, and single-burn-rate stoves. This proposal also includes improvements 

to the test methods and adds testing requirements to address short-term emission peaks and 

testing with cordwood to better represent real-world conditions. 

► The monetized health benefits far exceed the costs for all options considered.

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Scope of the Proposal

► An important goal is to minimize potential loopholes.

► The proposal includes the following three subparts:

• Subpart AAA, aka “room heaters”

– Adjustable burn rate stoves, single-burn rate stoves, and pellet stoves

• Subpart QQQQ, aka “central heaters”

– Outdoor and indoor hydronic heaters

– Forced-air furnaces

• Subpart RRRR

– Masonry heaters

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Wood Stoves

Proposed Two-Step Approach

► Step 1: 4.5 g/hr upon promulgation

– This matches the Washington State noncatalytic stove emission level.

– Over 85% of sales of EPA-certified wood stoves are models that already 

meet this level.

► Step 2: 1.3 g/hr five years after promulgation

– Best System of Emission Reduction (BSER) 

► Proposal combines catalytic and non-catalytic units under one emission limit. 

► Proposal includes single-burn-rate stoves and pellet stoves.

► Proposal establishes an emission limit for cordwood (rather than cribs) for 2019.

Three-Step Approach for Comment

► Step 1: 4.5 g/hr upon promulgation

► Interim Step 2: 2.5 g/hr three years after promulgation

► Step 3: 1.3 g/hr eight years after promulgation

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Hydronic Heaters

Proposed Two-Step Approach

► Step 1: 0.32 lbs/MMBtu heat output upon promulgation

– This matches the EPA Voluntary Partnership Program Phase 2 level.

– 36 hydronic heater models (27 cordwood and 9 pellet models) built by 17 

U.S. manufacturers have already been qualified at this level.

► Step 2: 0.06 lbs/MMBTU heat output five years after promulgation

– Best System of Emissions Reduction

Three-Step Approach for Comment

► Step 1: 0.32 lbs/MMBtu upon promulgation

► Interim Step 2: 0.15 lbs/MMBTU three years after promulgation

► Step 3: 0.06 lbs/MMBTU eight years after promulgation

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Forced-Air Furnaces

Proposed Two-Step Approach

► Step 1: 0.93 lbs/MMBtu heat output upon promulgation

– This matches the consensus standard developed by the Canadian 

Standards Association. 

– The two primary U.S. manufacturers of forced-air furnaces both have 

models that can meet Step 1 already. Other manufacturers are conducting 

tests now.

► Step 2: 0.06 lbs/MMBtu heat output five years after promulgation

– This matches the hydronic heater level.

Three-Step Approach for Comment

► Step 1: 0.93 lbs/MMBtu upon promulgation

► Interim Step 2: 0.15 lbs/MMBTU three years after promulgation

► Step 3: 0.06 lbs/MMBTU eight years after promulgation

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Masonry Heaters

Proposed Two-Step Approach

► Step 1: 0.32 lbs/MMBtu heat output upon promulgation except for small volume 

masonry heater manufacturers (less then 15 total units per year) 

– This matches the Step 1 Level for hydronic heaters.

– Based on data submitted by the Masonry Heater Association, over 10 models 

already achieve this level.

– Many other models are expected to use a computer simulation to show that 

their design would be expected to achieve the NSPS level without conducting 

further testing.

► Step 2: 0.32 lbs/MMBtu heat output for the small volume masonry heater 

manufacturers five years after promulgation 

– Most masonry heater manufacturers are very small businesses that produce 

less than 12 heaters per year.

– There is not a tighter emission limit in Step 2.

► There is not a three-step approach for comment 

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Test Methods

► Peak, shorter-term emissions

► The proposal adds multiple 1-hour filters for each test run to gather data regarding 

start-up and anticipated peaks.

► For Step 2, the proposal requires compliance with emission limits at the lowest burn 

rate (“Category 1”) and the maximum burn rate (“Category 4”) rather than the 

weighted average of the four burn rates in the 1988 NSPS.

► Cordwood test method

► The proposal adds testing with cordwood to encourage best real-world performance. 

For Step 1, the manufacturer would submit 2 test reports, 1 with cribs and 1 with 

cordwood and choose which results to use for certification. For Step 2, the tests would 

all be with cordwood.

► Precision

► The proposal includes enhancements to the test methods to improve precision.

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Compliance & Enforcement

► The proposal improves and streamlines the model line certification, inspection and appeals 

processes.

► The proposal adds electronic reporting by manufacturers and labs.

► The proposal adds 3rd-party laboratories accredited by the International Standards 

Organization as the primary basis for EPA approvals for testing and certifications.

► The proposal adds potential for delegation of compliance monitoring to states and EPA 

regional offices (in addition to EPA headquarters).

► The proposal requires emission tests on each type of fuel that the heater manufacturer 

specifies/warrants for use.

► The proposal requires that certification tests for pellet-burning heaters use graded and 

licensed fuels that have been approved by the heater manufacturer for use in their heater.

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Permanent Labels and Temporary Hangtags

► The proposal would retain the 1988 requirement of permanent labels after EPA 

certification.

► The proposal would not retain the 1988 requirement of temporary hangtags for marketing 

at the consumer level.

► The proposal asks for comments on whether EPA should require temporary hangtags or 

other mechanisms to help inform consumers of which heaters perform the best.

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