# 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 1 3 , 2014

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

David Cole and Gil Wood as presenter s

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. D ue 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 th is 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), b ut 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 communitie s and the general population to the maximum degree possible. Laura Mc k elvey of EPA further explained that EJ analys e s in general look for

di sproportionate impact s related to proposed rules and are not regarding what health impacts currently exist from emis sions

. Gil noted that the analysis was not perfunctory and that the Outreach and Information Division (OID), under which the proposed NSPS is being sheph e rded, is in fact the division that has been the most instrumental in advancing EJ analyses in permitt ing 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 essentia lly 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 estimate s that there will be some increase, but not a large increase in price.

 There were no other questions.