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/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 13, 2014

SUBJECT: Notes from the Environmental Justice Communities Call, February 12, 2014, with 

David Cole and Gil Wood as presenters

The attached list of attendees signed up for this Environmental Justice (EJ) Communities Call 

which took place on February 12, 2014 during a snow storm in Research Triangle Park, NC. Due 

to the snow storm, EPA’s offices in RTP closed early and David Cole presented for Gil Wood, 

until Gil Wood was able to also call in. David presented slides (attached) giving an overview of 

the residential wood heater NSPS proposal which was published in the Federal Register on 

February 3, 2014. Following the slide presentation, David opened the call to questions. The 

questions and answers are summarized below. 

 Question: John Ackerly of the Alliance for Green Heat commented that he was surprised 

EPA did not address the EJ analysis in the proposed rule’s docket and that he was also 

surprised that this EJ analysis only looked at cancer. John commented that more of an EJ 

analysis should be done – that the EJ analysis should not only have looked at cancer 

because there are many other impacts that EJ communities face from woodstoves 

including health effects resulting from indoor air issues. John further commented that 

there are many studies noting impacts to poor and non-white communities from wood 

stove emissions, and concluded that EPA is known for doing perfunctory EJ analyses.

Answer: David Cole noted that EPA’s contractor (EC/R) had performed an EJ analysis 

several years ago (which is in the docket) and that this analysis did not find 

disproportionate impacts. Gil Wood further explained that this EJ analysis did not 

find/claim that EJ communities were not experiencing health impacts from wood smoke 

(such as respiratory effects, etc), but rather that these impacts were not disproportionate 

compared to the general population. Gil further noted that the proposed NSPS included 

the strictest standards that EPA could set; thus EPA is proposing with these strict 

standards to help EJ communities and the general population to the maximum degree 

possible. Laura Mckelvey of EPA further explained that EJ analyses in general look for 

disproportionate impacts related to proposed rules and are not regarding what health 

impacts currently exist from emissions. Gil noted that the analysis was not perfunctory 

and that the Outreach and Information Division (OID), under which the proposed NSPS 

is being shepherded, is in fact the division that has been the most instrumental in 

advancing EJ analyses in permitting and rulemaking not just in OAQPS but Agency-
2

wide. Both Gil and Laura asked John to submit his comments and specific suggestions to 

the docket regarding how EPA could better address his EJ concerns.

 Question: A call participant noted that in the South wood heaters are essentially luxury 

items installed in new homes. He asked if there is a modified Method 5 for testing, and

what exactly is the test method being proposed.

Answer: Gil Wood noted that the test method for wood stoves is Method 28, which 

originated back in the 1980’s and uses a dilution tunnel in order to replicate the 

condensation of the hot gases as happens in the atmosphere, whereas Method 5 does not 

measure those condensed gases. Thus Method 28 gives higher (more conservative) 

numbers than Method 5 and is better able to replicate what happens in the atmosphere.

 Question: A call participant asked if there has been an analysis as to whether the rule will 

result in an increased cost to the appliances.

Answer: Gil Wood replied that yes, the increased costs are discussed in the preamble and 

in the Regulatory Impact Analysis (RIA). For woodstoves, it’s been estimated that there 

may be roughly a $100 increase on a $3,000 stove – so EPA estimates that there will be 

some increase, but not a large increase in price.

 There were no other questions.