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{iEI`OR(vi

May 7, 2014 

Ms. Gina McCarthy 

Administrator 

Environinental Protection Agency 

1200 Pennsylvania Avenuc NW 

Wasliington, DC 20460-0003 

RE: Docket ID No, T:PA-HQ-OAR-2009-0734 

Standai-ds of Performance lor New Residential Wood Heatet:s 

Dear Ms. McCarthy, 

Thank you for the opportunity to present our comments on the Environmental Protection 

Agency's (EPA) pr•oposed new particulate matter emission standards for residential wood 

heaters. Vermont is home to botll wood stove manufacturers and many homes that rely 

on wood heat tlirough tlie winter. T'o meet the important needs of both groups, we urge 

the EPA craft a rule that includes strong clean air standards and remains attainable for 

small businesses in the woodstove industry. 

Vermont lias the higliest per capita use of wood stoves of any state other than Maine and 

we are home to two of the preniier wood stove manufacturers in the United States, 

Iiearthstone and Vermont Castings. A substantial majority of Vermonters do not have 

access to natural gas and for these housellolds, wood pellets and block wood ai-e among 

the most economical choices for keeping warm during oLir long winters. With nearly 70% 

of our latidscape forested, we arc also blessed to have an abundant wood resource. 

'I'l1e popularity of woodstoves in Vermont does liave a downside as some Vermont towns 

occasionally suffer from serious air quality dcgradation as a result of wood stove 

emissions under sonle local climatic conditions. The topography and winter climate of 

some Verrnont mountain valley towns can trap particulate emissions causing liealth 

standards to be exceeded and advisories to be issued. For this reason we support the EPA 

in updating its regulations on particulate matter ernissions from wood stoves for the first 

tirnc sincc 1988. 

Wood stove technology has improved since 1988, as has the understanding of the liealth 

impacts of fine particulate air pollution. That the current regulations are seriously out of 

date is evidenced by the fact that ceilified wood stoves currently sold by Hearthstone, 

Vermont Castings and other high quality manufactui•ers typically exceed the curt-ent EPA

standard by more than 100%. This is a rare case where industry leaders are well ahead of 

the EPA in protecting cnvironinental quality and hunlan health. 

A large challenge in the effort to minimize air pollution from wood stoves is the 

operational longevity of the units. Wood stoves last virtually forever and there is a 

healthy second-hand market for used stoves. The greatest gains in air quality are made as 

old uncertified units are voluntarily replaced with high quality celli6ed stoves. Currently 

certified wood stoves are an order of magnitude cleaner than older units and thousands of 

certified stoves are sold each year. Improvements in air quality will only inerease under 

the new standards but not if consumers fail to embrace the new units. 

In light of this tension, we ask that EPA find a way to implement higher standards in 

consultation witll slnall manufacturet•s so the new standards and testing can be brought 

about over a period of tinle that is cost effective for businesses and consumers. We ask 

that you work with manufacturers to draft regulations that are both ambitious and 

achievable in order to avoid a significant negative impact on the market for new wood 

stoves. These regulations should allow enough time for manufacturers to transition their 

entire product line. Any new testing regime must be clear, consistent and repeatable. We 

believe this all can be achieved without signiticant compromise in the stringent emissions 

standards you 11ave proposed. 

We applaud the long overdue move by the EPA to reduce the particulate matter elnissions 

allowed fi•om residential wood stoves. The health of our constituents living in cellain 

communities depends on it. For emissions to be reduced within the foreseeable future, 

however, we need reasonable emission standards that can be met by stoves that are 

aff'ordable. Otherwise consumers will sirnply continue to use dirtier older stoves. The 

EPA should implement new standards in cooperation witli the many fine U.S. wood stove 

makers, and should avoid compliance requirements that may drive many U.S. stove 

makers out of business. 

Enclosed, please find a copy of the comments sent to the EPA from Hearthstone, a 

Vermont manufacturer of stoves, which provides further details on these concerns. 1 

appreciate your consideration on this important issue for my state. 

P W/csl'

Comnients to EPA's NSPS Proposed Rule 40 CFR Part 60 

h arthstone	

2 May 2014 

We can all agree that it is time for an EPA review of the existing NSPS ru!ing. So much has changed in the last 

25+ years. With 7 million uncertified dirty units in use, it is time to make some changes. Thank you to everyone 

involved for their passion and commitment. Many people are spending much time and resources to do what each 

of us believes are the right things to do. The beauty of this process is that everyone gets to be heard. 

Undeniably, there are special interests on all sides. Burning wood is a curious issue. What a dichotomy! 

It can be seen as incredibly green, an a!most insignificant carbon foot print, e!iminating sheiks and big business 

from invading our wallets, providing local jobs, helping many people with limited means to stay warm, providing 

exercise ( wood heats you twice..) and a reason for the family to gather. Wood is comp!ete!y renewable and 

does not release sequestered carbon from another age. 

On the other hand, burning solid fuel is not like burning LP or NG gas. Gas burns with almost no emissions. But, 

it costs money, supports big business and has a transport, processing and environmental foot print that is huge. 

The impacts of fracking aren't even known yet. The lobbyists will support petro!eum and gas everyday but brush 

this option aside. 

We have been "doing the right thing" by building ONLY certified product. HearthStone was one of the companies 

that suffered bankruptcy in the last go-round of this process 25 years ago, so we have done what we perceived 

as the right thing ever since. The category of certified stoves and inserts we compete in is not the ones causing 

the visible smoke you see most often. The proposed ru!e pena!izes all manufacturers with no consideration for 

the work done a!ready. The opportunities lie in replacing these 7 mil!ion old, un-certified products in use every 

day as well as focusing on any product that has evaded EPA scrutiny for the last 25 years due to oversight and 

exemptions. The 150-200,000 Certi(iedwood stoves so!d annually are not the problem and should not be swept 

up in the mess. 

Hi tech, gadget oriented products that test well, cost a fortune and do not work well in the real wor!d is not the 

answer either. 

Consumers and manufacturers need a sane, middle of the road approach that environrnenta!ists will endorse, to 

find ways to encourage homeowners to realize that a modern stove will save fuel, be less likely to soot up their 

chimney and have all the latest safety features. Our monies we are spending wou!d be better spent in this effort. 

Following are HearthStone's comments regarding the proposed rule. We are a small company of 60 peop!e in 

northern Vermont. Please consider all the data and dig in a little if you have questions. This is not a good versus 

bad partisan conversation; it's a dialog of fact finding and solution finding. We all know this country cou!d use a 

little more of that these days. 

Thanks for being passionate. 

Sincerel 

David Kuhfahl 

Plrsident 

HearthStone Quality 1-ioine Heating Products Inc,	 317 Stafford Ave. Morrisville V"C 05661 

www.hearthstonestoves.com

4tj heardisbane
Comments to EPA's NSPS Proposed Rule 40 CFR Part 60 

Hcnrth,Stone (;)trality 1-1011W lleirting Pr Ocltrcts Inc. 

317 Stafford Avenue 

Morrisville, Vermont 05661 

Introduction: 

HearthStone has been building solid fuel appliances (wood stoves and fireplace inserts) in Vermont 

since 1978. 

In 1988, the original "Hearthstone Stoves" company suffered bankruptcy as the then new EPA standards 

obsoleted the entire "working" product line. The one product to achieve certification was a catalytic 

stove and while passing the standard in a laboratory, it did not work well in the real world and the wood 

stove customer was not ready for a contraption requiring overt user actions with no apparent intrinsic 

value. The assets were purchased in January of 1989 and the company reorganized, 

Solid fuel appliances are our core business and represents about 82% of our business today. The other 

18% is similar looking gas appliances. AII of our solid fuel heaters (free standing or inserts) are EPA 

Certified under the 1988 rule. We do not manufacture exempted boilers, furnaces or "single burn rate" 

appliances. Today we sell products under 16 different EPA Certificates. The average age is < 10 

years. We are constantly improving and with 16 to maintain, that is the life cycle on average. We are 

proud of our reputation as local Vermont company providing local jobs and manufacturing easy to , 

operate appliances that utilize locally sourced 100% renewable fuel. Since our reorganization we have 

avoided both "gadgets" to enhance test results, and finding exemption loopholes. 

General Comments: 

While we support that the time has come to revisit and rework the 1988 rule; the proposed NSPS signed 

by the administrator 1/3/2014 is full of concerns that would effectively have the undesired impact of 

increasing emissions. It is disappointing that we did not have this chance to comment before this rule 

was proposed a rule so replete with illogical assumptions and unsupported ideas. Designing and 

building these products is our expertise. 

Residential wood heaters certified under the 1988 rule have had a 25 year head start on "single burn 

rate" appliances as well as Residential Hydronic Heaters (outdoor wood boilers) and Forced-Air 

furnaces (warm air furnaces). The improvement from 80-100 grams/ hour of particulate to today's 4.5 +/- 

came at a great cost and impacted many businesses, jobs and technology. This portion of the industry 

has achieved the best part of the improvements possible without taking "extraordinary measures". We 

have reached a point of diminishing returns on these regulated heaters and draconian measures will 

drive customers to fix and repair old dirty ones to keep them in service. The best return on investment is 

to look at the old inventory and those that have skirted the 1988 rule until now. The graphs below show 

the EPA 

Ntllomolde Cumuldlvo Coot (200f) 

a

^a%Nrw 

 . - .. I . . 	cCVObdYbadrdPMdariy 

^

. aToW118P8hp01Plo)e140 

^

(d ProdM 0'M^^

PrnJaotod eumule(ho PM tll omlasiono nducl(on (tom) 

r nt°r"°'ce°' 

^:.	. 	aC.tlM1dW^a1rMP.GqaJ( 

'	 aTO W N8P8 NppproJ-Md 

'	 (d Cro}rt ") .^. .'..

projected cost 

to this 

category only 

versus the 

projected 

impact. 

Page 2

6 hearthstone 
Comments to EPA's NSPS Proposed Rule 40 CFR Part 60 

Consumer expectations and likely response that use these solid fuel residential room 

heaters have been studied. A survey was conducted by the Stevenson Company in 2013 surveying 

U 1 V UWIICI UI InlCly UWIICIS b11UUVCU 111C IUl1UVVllly. 

Ifyra(ivwetopurdaasearrvmrr;p'acen-L-nt(ska^p), wfxatfec.aiLjresinixakl 

le /7xist i7 pCa'ta/it to }xJ?

^ 

Prlce 1	95°l0	1$%e	10% 

i 

Efficiency ^	 , 

RBtln^	

( I 8"10_ ^	220Io	 1 A`Yo	O^t c^s 

User- ^	j 

friendly	9%^^ ^ 20%	 18Y0	`12%^ ^ 7%^ 

controls +

a1st _j 2nd w3rd u4th u8th n6th +7th

What does a consumer look for in a 

solid fuel appliance? To save money 

with a simple device. Here are the top 

three reasons grouped by choice, 1 st, 

2nd, etc. 75% saw price as a top three 

consideration to buying a solid fuel 

room heater. 

Made in America and low technology 

were other preferences. 

-

)cWk?(jfia1)l7lCS- fr7/I7/^vlf7Ca/7Je 

< $25,000 

$25,000 to < $50,000 

$50,000 to < $75,000 

$75,000 to < $100,000F

3%9% 

$100,000 to < $150,000 

$150,0 to < $199,000 00 

The Dernographic of the likely buyer and current 

user helps us to understand this behavior. 67% 

have family incomes below $75,000 

These products are used in primary residences. 

They are typically(90%) installed in residences of 

less than 2000 square feet.

2196

3396 

2396 

$200,000 + p 2% 

No Answer r 5gb 

oTotal Proclucts 

Product Location 

97%

^ 

I 

a	^ 

'	1 

^ 

^	2%	

19'0 

, 

PriniaryResidence SecondaryResidence	Other 

>~itTotal Products 

(n=61o) 

Page 3

Area Used 

33% 

2735

^	 22% 

8%	 ^	^	

10% 

<soo sq. R. soo to <1,060	1,006 to	1,500 to	2,000 sq, ft, or 

<1,500	4,000	more 

"Total Products 

(n=61o)

64k^ hearthstone
Comments to EPA's NSPS Proposed Rule 40 CFR Part 60 

These appliances are not purchased as decoration, but a economical sources of heat and are used often. 

Frequency of Product Use 

75%

13%	6%	1%	6a5

, 

paiiy	Few t(mes/wk Few tlmes/mo Once a month < Once a month 


rt Product Oviners 

Wood Burned Per Year (Cords*)

25% 

17%	

21%	

17'°	

11%	' 9%	`	t 

1	[k;'	€F	 1	1 

<iCord	Ito<2	2to<3	3to<4	4to<5	5+Ccrds 

t!t Pro(luct Owners


Mean:3.43 Cords 

ProductPurpose 

65% 

^	1 

(

29%

i 

^	7% 

Use mostly as Primary	Use mostly as	Use mostly for 

heat source	Supplemental heat	Aesthetic 

r4 Product Owners


(n=539)

Technology in Solid Fuel Residential heaters will create a detrimental effect on the continued 

replacement of older dirty stoves and not have the desired effect of improving air quality. Even though. 

consumers are aware of the need to use alternate controls, 79% familiar with them, 74% will sometimes 

to always run the stove in bypass, defeating the technology. (these data are from Catalytic stove owners, 

but any new "device" with extra controis that does not have an obvious, intrinsic "reward" will create 

similar behavior) A single; low-to-high control is what a consumer will operate intuitively and therefore; 

correctly.

WhyClose BypassDamper	 Operation With DamperOpen 

79%

34% 

^	 18%	

22%	

Is% 

16%

5%	

^ 	

.	

^	^ .

	

^ 	

^.	71/o 

^	

^ — ;	► .	I 	,	;	

,	^ 	^ . ^	

0% 

Yes, very familiar	Yes, I do it, but not	No, not sure	

Ahvays	ORen	Sometinies	Rarely	Never	Not Sure 

sure why 

ri Catalytic Owners	 I~( Catalytic Owners 

(n=114)	 (n=114) 

Page 4

dIr hearthstone
Comments to EPA's NSPS Proposed Rule 40 CFR Part 60 

Maintenance and repair is lacking. Simplicity is necessary. Catalysts or any "technology" added will 

need maintenance and up keep. unless the 

consumer can see some real benefit to 

maintaining these "devices", they will 

degrade in time and air quality will suffer. 

The older the product, the less likely it will be 

maintained. 

Catalytic Replacement By Age of Product 

_ 53%	 47% 

i _ --- —

— t --------^,^ 

6396	

I ^	589J




I 

^ • • a8%	

( )	

52% ( 

Cat 0wners t	r^	42%	I ( 

(n=114) 	 . 3b% ) 	37%

-_I, 

Yes, havereplaced	 No, haven't replaced 

6%<5 Yrs	Id 5 to <10 Yrs	e4 10 to <20 Yrs	n 20+ Yrs 

( n '54)	('n=29)	(•n=19)	(•n=11) 

Summary to likely consumer response: 

HearthStone and other quality companies in this industry have manufactured non— catalytic residential 

solid fuel room heaters exclusively. The simplicity of a single lever air control LOW-to-HIGH, rugged 

stainless steel components and a lifetime warranty on most components affecting air quality has been 

the best solution. These staves perform economically for many years at reliable, undefeatable levels of 

emissions in the real world. Extreme EPA certification levels that push the industry to make more stoves 

to "pass the test" with no real world benefit are self defeating to our shared goal of improved emissions. 

As long as the inventory of dirty, pre EPA, exempted or other unregulated solid fuel burning devices 

continue to exist in the clear majority, over regulating the part of the industry that has evolved already is 

fruitless. 

Page 5

Footnote: Wood is a local!y harvested, completely renewable energy source that is abundant and either!ow cost or free with a very 

low carbon footprint. Through out their lives, trBes convert the stm's 

energy and CO2 into wood (biomass). When a tree rots naturally or 

burns, the carbon contained in the wood is released back to the atmosphere. 

Encotiraging the use of this resource is the right thing to do! 

4o hearthstone
The extra data point 

here is for a "fan 

confirmation ru-" 

The four basic 

the graph are fc 

Category 1 (<1 

...thru... 

Category 4 (wi( 

This stove perfi 

best on high 

The worst run 

3.13 g/hr

3	1.15	2.59	 13867

. 

Comments to EPA's NSPS Proposed Rule 40 CFR Part 60 

Repeatability and variability in the methods is a barrier to the 1.3 g/hr proposal, or 

any proposal <4.5 g/hr. I will share some data from HearthStone experience. Burning wood is not a 

precise science. While the current (1988) test method can distinguish a good stove from a bad one, it 

cannot distinguish better from best. Repeatability is impossible. The physical components of modern 

stoves are made with laser, from fixed molds or other precise methods. The variability is not due to 

manufacturing variability. The way a stove is loaded, the way the wood falls in on itself during the fire, 

the knots, the temperatures, the nature of each individual piece of wood all have an impact. When the 

crib method was developed, it was in an effort to have repeatability in the method. At least, wood shape 

and mass could be controlled. Here is an example of an existing (HearthStone) certified product and 

some data points over a 9 year period. These are EPA Certified Laboratory results. 

zaz-^x.-.z-acsaasr ^rn^aazzaazz-=x^zaaaz--aae^zr_ .ras z zz^ecszaaza¢^ a a—aaa^axr-rc— 

&rru Eanbtlon HOa1 Wttf Avq 

Run Rate IZato UtiNput ({pihr) 

no. (kyRir) (gf`hr) (Btrdhr) 2.68

_ ........... ._. ___.. 

1

...._,___. ...... 

097

..	_ _.... 

160

__.. w. ..,.... ... 

116$8

_____..__..._ 

2 11g 313 1049 

d 1.69 260 20238 The "EPA number" on 5 272 t.ar 32788

this test is 2.60 g/hr.

Model A, Test 1 

These tests were 

performed in the same 

laboratory, with the 

same technician. 

Page G

i 

O.b i

	

..__	.	......_4	_«__...u^.	.... ..	I 

0S	 ^	 ^ •f	 7

	

tn	a 

Dy Uuni Rate {tyhij

do hearthstone 
Comments to EPA's NSPS Proposed Rule 40 CFR Part 60

©urn Lmistion Neat WYtdAvp ---^--y^ 

Model A, Test 2 "n R°t° aAte °°tp"t (whr> 

1 kUmrl 40410 (13tulho 4.30 

1 099

........... 

7 29 11413ri

__._...._,._..__ - 

2 1.20 3.01 14470 

3 1 t1'l. 1.62 18534 

In comparison, this test run 4 251 2YN Y)2ts 

has a"EPA number" of 4.30 NA 

and a worse case of 7.23 g/ NA 

hr on one run. G 

Under the existing standard,

the weighted average is 

what matters.

A ; 

If 4.5 is adopted, and each 

category must pass, this ^ ' ` + 

stove goes away in thls ir 

test.

r

i

i 

05 1 1.5	 ? 7F 

' 

i'

[llY hUln (ttllA (t:^i^ll l ' ^ 

--_ .--_...r.-wwaec^e .... ._.... ^_..._.^wuncs ,c,anrrw.r-xsxarnc^^s^aa:.sxrramrtamsaaxc_ce=-_dr.: 

Hurn [niissiqn Fiaat Wtd Avg 

Model A Test 3 Run Rato Rt+to Output (uA'u) 

, no. (Hglhr) tplhry (Btuff,r) 5.78 

_._	._.____. 

1 p R 771 

.. .._____.__.__..._._._____....,...,. 

11853

..._._..__.N._..__.._......	_ ..	.. 

3 114 633 197:i8 

4 187 206 22565 

2 256 7.15 30711/ 

NA 

This third test run has a NA 

"EPA nurnber" of 5.76 and a 

worse case of 7.71 g/hr on p ^ 

one run.

^	I Under the existing

standard, the weighted

keeps this stove viable. ^	1 

Under any standard that 

looks at category specific

numbers, this stove goes ^ ^ 

away in this test.

r 

a^ I us

. OIY taurro ti p la I1,01rr 

Page 7

du. hearthstaie
SIONE. 

1 c3b^^ 

I ^

3 

a

21

♦ 

Comments to EPA's NSPS Proposed Rule 40 CFR Part 60 

Another example. 

Model B, Test 1

r,va.aza^asc=aseECa^^ca_=sx^e^c_,sc -xc_zaam»smxc.s^c^cca^-,-.mxsusaearso—ssassr.sa=^aa^— 

Eiurn Emlccion Meat Wtd Avg 

Run Rxte Rate outpw (tilhr) 

no. (kglhr) (g0ir) (8tulhr)

___.

	..... __

3.03 

....._	,	............	._._.. ,_. 

1

.......................... 

0.88 2,66

..... 

10011 

3 1.09 4,30 13143 

4 1.85 2.07 19690 

2 235 307 28337 

5 1.20 2.32 14470 

^ 4S t t5	 2	 25 

`_ _. _ _ _ ._ .. _ _.

. __

_ lbY ^3^m Rn!n tkgLY_r) . __ _

_._ __ _.__, _ . ^ 

Model B, Test 2

8urn t:fniaalun )teat	 Wid Avg 

IZurr Ratu Rate output	 (glhr) 

no, (kgrlx) (glhr) (Btuftfr)	 1.85 

.__,____._..,. 

i 005 

_.......^.r.....-

1&t 

......__.__..._.__-_......... __	...___..._.__ ...	....	......-•— 

11455 

2 t.15 740 131li37 

4 1-35# 142 t6701 

3 2.09 232 24599

I@	1 

Summary: The lack of repeatability demonstrates a 

variability inherent in wood 

testing makes any standard 

below 4.5 g/hr a game of 

chance. The cost associated means repeating the 

test until a good one happens. These products are 

10X cleaner as manufactured today than in 1988. 

f'age 8

7e 

:^ t ^	ttt 

^	,hf 

;	

I 

^

r.. ^ 

f	"^ G fi

`

,t 

f	1!	L4	If 

t:t 1 Nwn R:GC tkphx I

c	^ ;f 

I	? 

d4 heartt>tstone 
Comrnents to EPA's NSPS Proposed Rule 40 CFR Part 60 

Cost to re design stoves and inserts: HearthStone uses as manufacturing materials; a mix of 

cast iron, soapstone and steel components. There is a CBI attachment that will address the cost of 

designing a stove, certification and bringing it to market. It will range from $450,000- $1,000,000. Cast 

Iron molds take a year or more to get from concept to prototyping to mold to production. None of this 

has been considered. 

We currently sell products under 17 distinct EPA certificates. (we will be responsible for 16 of these) 

While all meet the proposed Phase 1 of 4.5, they meet it in a weighted average scheme. Not in the 1 

and 4 categories only EPA 

as proposed. Certifi- Certification 

E 

L 

^ 

E 

i 

E 

c 

1C 

11 

1^ 

14 

1E 

1E 

17 

Using EPA's conservative data; HearthStone has 16 owned certificates x $356,250 =$5,700,000 

or $9,140,0001 year/ 14,400,000(annual solid fuel sa/es)= 8% of sales. This exceeds profitability. 

We cannot survive this, even in this ideal/zed scenario. In the 2 step approach, th/s lnvestment 

is obsolete ln 5 years. 

Following is a complete consideration of the cost for this company to 


create and evolve a Certified Residential Room Heater. I was 


intending to keep this private as Confidential Business Information 


(CBI), but that would limit the audience. A few of these numbers are 


estimated, none are exaggerated. 

HearthStone certificate Name/ 

Number

cation 

/hour

Expiration 

Date 

Phoenix 8612 2.40 1/31/2018 

Mansfield I 8011 & 8012 2.90 6/1/2014 

Homestead 8570 1.90 7/13/2015 

2.5 ZC Series Fire lace Cert. riot owned 4,40 7/5/2014 

Shelburne 8370 & 8371 2.10 9/5/2016 

Herita e I 8021	& 8022) 2.70 6/26/2017 

Mor an 8470 4.30 6/12/2018 

CI desdale 8490 & 8491 3.20 12/29/2014 

Tribute 8040 3.00 5/21/2014 

Craftsbu	8390 & 8391 3.78 5/21/2014 

Bari 8170 & Lima 8150 3.57 4/5/2017 

E uinox 8000 3.10 11/1/2017 

Tula 8190 2.55 9/30/2014 

Herita e 8090 Manchester 8330 Pellet 1.30 2/4/2015 

Manchester 8360 3.01 6/16/2017 

Castleton (8030) 2.71 9/10/2017

Page 9

4bp hearthsbone 
Comments to EPA's NSPS Proposed Rule 40 CFR Part 60 

The Creation and Evolut:ion of a Cast Iron	 Hearth5tane QHHP Inc, Morrisville Vt 

Wood Stove 

Designing and bringing a cast iron stove to 

market is a risky venture. The process invoives 

many more steps to produce a product than a 

stee! stove. Once tooiing (molds) for prototypes 

are made, any changes at all require a retooiing 

to accomodate them. Modifications for emission 

irnprovements, aesthetics or any other reason 

are very costly. It typically takes a few 

generations to "get it optimized. This is a short 

summary of the life cycle of one of our cleanest 

burning (non-cat) stoves. HearthStone stopped 

making catlaytic stovesin 1996 as they were 

good in the laboratory, but custorners defeated 

them and their real world performance was iess 

than our customers expect for a premium 

product.

In 2001, HearthStone introduced its first all cast iron 

non-cat wood stove, the Bennington. This was the 

first fully built from 3-d models stove. There were 

many innovations included to improve efficiency and 

hook customers with features. A 14 pound cast iron 

finned heat exchanger sat in the secondary 

combustion area, the entire stove was convective 

and it had a side downward opening fuel load door. 

An engineering marvel that didn't work ver}r weff. 

Consumers and retailers aiike voted with their 

wailets. Cost to Market in 2001: $376,000, 4772 

sold, R&D each: $78.80 each. EPA 3.51 glhr. Due 

to its poor perforniance, the gross margin on this 

stove was forced to be marginal (<10%). 

Development cost: 376,000.00 

4bk hearthstone
1200 -' __	_._. 

1000 

800

._ 

__._...__ ^ . A S les '

^	UNITS

i

9enntnston 

Comments to EPA's NSPS Proposed Rule 40 CPR Part 60 

In 2008 we started deslgning a new 

model to replace the Bennington. 

Similar features, but with niore careful 

attention to the user friendliness, 

reliability and performance. This 

became the Manchester. 2.9 Cu Ft 

with ail the features of the Bennington 

Pius either side loading, more useful 

loading area and soapstone refractory 

lining and most important; it work very 

well. In the first year it had instant 

sucess, > 1000 sold. AII clean burn is 

done passively, no confusing user 

controls. One user control lever.

t ^

t 

,

a 

^•,<^	

^^x : 

^ 

Builciing a cast iron stove requires customized making of molds. First a 

"prototype" set for initial testing, modifying It during testing and tinally casting a 

steel plate and applying a thin plastic layer with the exact details. Once this 

"pattern" is built, it will rellably last 10,000 sets before needing to be rebuilt. 

during its life, the "k list" dimensions can be relied upon unless there is a 

complete failure. AII 16 stoves and insert models currently wearing the 

HearthStone label carry an EPA label and meet Washington State 4.5 glhr. 

AII have a singie lever air control that does not ailow for any errors or confusion 

on the part of the user. No bypasses or gadgets designed to make testing 

results better but add no value in the "real worid". This philosophy of Certified, 

practical, user friendly and simple is what we do. Our Pellet stove was Method 

28 Certified since its inception.

4i hearthstAne
Comments to EPA's NSPS Proposed Rule 40 CFR Part 60 

Manchester 8360 Wood Stove Development	 2008 EPA 3.01 g/hr

Compietion Description Resources Hrs $ 

Dec-08 Design Presentation 1 External Designer 1/12 year 5,000.00 

1an-09 Design Presentation 2 External Designer 1/12 year 5,000.00 

Sep-09 Initiai 3D Development External Designer 5/12 year 25,000.00 

Sep-09 Initial 3D Deveiopment H.S. - Design Engineer 2 months 11,700.00 

Dec-09 Layout/produce prototype moids Taiieres Nocti (Spain) 70,997.06 

1an-10 Cast and ship prototype 1 parts to HS Hergdm/Nippon/Deringer 2,000.00 

SAP - Design Engineer Of Materials creatii H.S. - Engineering Manager 1 week 1,950.00 

Miscellaneotis prototypes, air pipes, bafflei RSI, NSA etc 300.00 

Mar-10 Assemble and test prototype H.S. - Design Engineer 2 months 11,700.00 

Ship stove to Lokee H.S. 142.62 

May-10 EPA combustion deveiopment Lokee Testing 6,757.60 

Jtin-10 EPA conibustion deveiopment Lokee Testing 6,771.95 

1u1-10 EPA combustion deveiopment Lokee Testing 2,975.00 

1un-10 Deslgn Engineer make and send revision t H.S. - Design Engineer 3 months 17,550.00 

Sep-10 EPA combustion deveiopment Lokee Testing 7,480.00 

Sep-10 EPA combustion deveiopment Lokee Testing 2,040.00 

Ship prototype back to HS 181.99 

Design Engineer continues with combustio H.S. - Design fngin®er 6 months 35,100.00 

Oct-10 Certified wood for testing Dunn Lumber, Seattle WA 1,000.00 

Oct-10 Ship certified wood from WA to V,T YRC BOL 642-838280 1,716.93 

Mar-11 Certified wood for testing Country Home Center 2/3 of order 1,060.80 

Atig-11 Derek Anders runs tests at Hearthstone Ferguson/Anders 1,063.12 

Sep-11 Modify AshLip moid Talleres Nocu (Spain) 996.15 

Design Engineer continues with combustio H.S. - Design Engineer 1 month 5,850.00 

SAP updates H.S. - Design Engineer 1 week 1,950.00 

Nov-12 Revise tooiing / moids Taileres Nocu (Spain) 1,624.93 

Photo shoots, ad production, 1/30 of total t Hergdm, H.S. 

Dec-12 Design Engineer travels to testing at LokeE H.S. - Design Engineer 1,950.00 

Flights, lodging ®nd labor 1,368.00 

1an-12 EPA testing 1/10-2/3/2012 Lokee Testing 15,633.20 

!an-12 EPA testing 1/10-2/3/2012 Lokee Testing 13,625.70 

Feb-12 EPA testing 1/10-2/3/2012 Lokee Testing 3,160.00 

Mar-12 Data Interpretation, interacting with Lokee H.S. - Design Engineer 1 week 1,950.00 

May-12 Design Engineer traveis to Hergom Flights, lodging and iabor 1 week 3,430.00 

lun-12 Safety Testing Intertek 9,900.00 

Jun-12 Create and approve manuai, labeis et al H.S. - Design Eng'r/Designer 3 weeks 5,850.00 

Aug-12 French transiation of manuai Fernande 2,000.00 

Sep-12 Build final Manchester Molds Taileres Nocu (Spain) 108,914.41 

2009-2012 R&D Management H.S. - Engineering Manager 20% 33,800.00 

2012-2014 R&D Management H.S. - Engineering Manager 20% 20,800.00 

- Overhead and administrative support 10,920.00 

IEPA 3.01	/hr Subtotal $$ 461,209.36 

(Manchester) 

The 5H EPA test run (in 2012) on this stove had a very bad Cat 4 burn 

and excellent lows. We saw an opportunity to improve It and strategized 

an approach by adding a tertiary, passive air induction system that would 

maintain a single user interface (control).

46 hearthstone 
Step II

Comrnents to EPA's NSPS Proposed Rule 40 CFR Part 60 

sep-13 Develop tertiary burn systeni to alleviate hi H.S. - Design Engineer 80 hours	3,900.00 

oct-14 Prototyping H,S. - Design Engineer 160 hours	7,800.00 

Nov-13 Testing, Hearthstone H.S. - Deslgn Engineer 120 hours	5,850.00 

Nov- 13 Ship to Lokee 210.00 

Dec-13 EPA high burn verification Lokee Testing 4,400.00 

lan-14 Update 3-D models and documentation 1,950.00 

Feb-13 Modify patterns Talleres Nocu (Spain) 1,360.00

Mar-14	Safety test re-verification	

Intertek	5,981.00 

The subsequent EPA test run (in 2014) on this stove had a much 

improved Cat 4 burn. The nunibers are looking like a weighted average 

of 2.1. No additional controls or consumer (nteraction is required, 

EPA 2.10 /hr	 Subtotal $$	31,451.00 

Grand total $$ 492,660.36 

(Manchester Onlyl) 

Hearthstone's cost to have a cast iron stove in this Category $$ 868,660.36 

These are the direct (overt and obvious) costs and do not include the many meetings, strategic, 

sales and technicai. 

Cost to benefit analysis 

The HPBA commissioned NERA to study the cost / benefit of attempting to make the 

changes suggested in the new rule. This graph clearly shows the diminishing return of this 

effort for cordwood heaters. These are average industry numbers and the numbers for 

HearthStone would be higher. 

Bigure E-1. Cost-Effectiveness of Alternative Wood Stovo NSPS Based Upon Calendar Xear Beneftts 

$600,000 

$500,000 

e 

^$400,000 

^$300,000 

$200,000 

$100,000 

$0

Step I

^ 

^ 

^ 

^ 

, 

i ^

$200,700 

$33,900	! 

7.6-+4.6g/h ; 4.5-+2.6g/h

4., heatthstone 
Cornments to EPA's NSPS Proposed Rule 40 CFR Part 60 

Fotlowing is a complete consideration of the entire pro- 


posed rule from the perspective of this manufacturer of


Certified Residential Room Heaters. 

Some of the concerns previously brought forth will be 

named again here, just to keep this list complete. As for 

the testing protocol details, I leave those to the EPA Certified Labs to complete. I only refer here to the obvious concerns and this list is not meant to be completely inclusive. 

& hearthstone
Comments to EPA's NSPS Proposed Rule 40 CFR Part 60 

HearthStone	

May-14 

NSPS Revlew 2014 40 CFR Part 60 

Pa o From proposal	conce t Comment (regarding Solld Fuel Room Heater: 

P 12 More than one representative sampie shouid be Variability from test to test Is not caused by the 

tested... representative sampie. It Is caused by fuel 

varlations(a reality with unprocessed soild fuel) and 

operator variatlon. Modern nianufacturing 

processes do not allow for signiflcant physical 

variatlon. Adding tests will resuit in a huge testing 

cost increase and few stoves that win the game of 

chance. 

Licensed peilets Greatl Europe has done this for years. It wiil need 

to be mandatory. Bad pellets fiood the market and 

cause combustion prabtems. 

PP33 Existing wood heaters are not affected by this rule. Existing heaters couid be troubied by recertification 

In addition due to the long life span of wood- or RCA and the short life left if not certified this 

burning appliances and siow turn over, It may be year. Concern that HS stoves were all tested with 

years before the full beriefits of these reguiations the now obsolete 5H method. This was an 

on new appiiances will be shown., some areas approved protocoi at the time and consideration 

have restricted the resaie of stoves.. should be made for "grandfathering" 

PP37 ...it Is also Important to avoid unreasonable Grandfathering existing certified stoves Is 

economic Impacts on those manufacturers (mostiy necessary. There wll) be hundreds of formerty 

small (PP38) businesses) who need additional time uncertified protlucts floodtng the iabs. Starting "ali 

to deveiop a fuil range of cieaner modets... over" across the board is an untenabie burden. 

Requesting comment on grandfathertng step 1... Existing certified stoves shouid "run their course" 

for 10 years (half of the 20 years EPA says they 

have for a Iifespan) or until the next phase. Even 

with the supposed 5 year phase 1, no stove will 

have 5 years uniess It is certified or renewed on 

December 31, 2014. Some will run out as soon as 

January 2015 since renewal Is not possibte.	The 

manufacturers have certifled these products 

according to the laws In place and shoutd not be 

robbed of their Investment. 

Options: Two Step approach A reasonabie "hurdie" for the second phase, using 

a protocol known today is possible. If the standard 

is draconian, the new "standard and test protocol" 

must me deveioped BEEFORE any standard can 

be set. Setting up any passing grade for an 

unknown protocol is impossible to agree to. Solid 

Fuel roorn heaters have already spent 25 years 

capturing the low hanging fruit. At this time, 

Improvement can oniy be a smail margln over time. 

The biggest Improvements have been captured for 

this cate or . 

Three step a	roach; see above.. 

Step 1: ...affects products manufactured on or aRer The proposal wouid effectiveiy stop the industry. 

the effective date of this ruie or soid at retail 6 This is a seasonal business, Dealers construct 

months after the effective date of this rule. 4.5 displays with inventory in the spring for fall and 

gm/hr. winter sale.	Dealers would surely have unseilabie 

inventory and they may be "stuck" with it. 	In this 

industry It Is common and typical for retaiiers to 

carry display and burn models for up to two years. 

General Inventory may sit for a year or two. 

(Please visit an existing retailer and see the 

manufacture dates on the displayed products. do 

some homework here, please) We do not sell 

lettuce!

4o heartfistone 
Comments to EPA's NSPS Propased Rule 40 CFR Part 60

NSPS Revlew 2014 40 CFR Part 60 

Pe e From proposal conce t Comment (regarding 5olid Fuel Room Heaters 

Step2: ...manufactured OR soid 5 years after the We have no acceptable protocol, we cannot set the 

effective date..1.3 gm/hr. goal. A new protocol as outlined wiil require 5 

years of data collection before any "passing grade" 

ean be Set, 

3 Step: 4.5, Step 2: 3 years after ... 2.5 gm/hr., If the protocol was proven and data coilected, this 

Step3: 5 years later (8 years from efFective date)„ could make sense. As it is, we cannot set a 

1.3 gm/hr, passing grade on an unknown protocol. 

PP41 Cat and non cat, same standard ... No Requlred cat Catalytic stoves test better In a laboratory but there 

repiacement, warranty on all stoves. Law on is no intrinsic motivator for a consumer to operate 

operation WITH a cat, lf so equipped...	...Report them correctly, maintain them correctly or In fact, 

Crib and Cordwood results for step 1, choosethe use the catalyst at ail. Current testing requires 

result, cord wood only in 5 years. "'worst case" testing, e.g. Top exit option, as it will 

be dirtier. If a stove has a user control that may be 

misused, it should be tested with the control ln the 

misused posltion.	A single lever controiled stove 

with no opportunity for by pass shoufd be given 

eredit for that, or the alternative stoves shouid have 

a handicap. 

PP42 ...Cord wood more closely resembles what a typical Cordwood testing will be a less consistent Indicator 

homeowner .,.requesting data on comparable of a repeatable result. Cribs are as close to 

performance. ... Requesting reporting of CO and repeatable as we have. Of the variabies; fuel 

feedback on CO reduction costs. dimensions, fuel consistency, fuel density, operator 

interface, and operating conditions, we need to 	• 

eliminate as many as possible to get repeatability. 

Have we ever considered a"manufactured" fuel 

that is 100% consistent to remove at least some of 

the variables? 

PP43 Requesting data on testing multiple units vs. a Stoves today are manufactured with lasers, robots, 

representative unit. flxed molds and high levels of precision. Variation 

ls In the methods have allowed other variables (see 

above). With the wide variability that exists in the 

test, additional units will only add cost and more 

confusing data points. Testing costs will be 

multiples. 

PP45 Instailed, permanent, visible labels, no more Consumers will not pay attention to visible 

hangtags hangtags and more likely will remove them as 

unsightly. A label visible during sale and installation 

Is adequate. The " permanent label" should have 

more data on it. This Information can )ust as easily 

be in the manual. Manuals are now available 

forever, on line. Cluttering the stove with labels is 

only appropriate for litigators. 

PP46 Voluntary labeling for the cleanest of the clean... to A stove thatis simple to operate and has no 

reduce exaggerated ciaims. Give the industry a gadgets could be recognized. This Is a passl fail 

measurement as pa►t ofthe test and marketiorces test as it exists today. Any better/ best distinction 

wiil do the Job encourages the use of glmmicks and gadgets in 

testing to create 8n art{ficia) (laboratory) result. 

These gadgets are not useful.or productive ln 

improving alr quality. A weli informed operator that 

understands fuel, loading and draft Is more likely to 

have beneficial results. There Is not test that can 

make this distinction, good or bad- yes.. Better and 

best: not until there Is a protocol wlth some 

repeatability. We have no method. Again this is an 

opportunity for manufacturers to abuse the system, 

as It Is today.

416 hearttvstone 
Comments to EPA's NSPS Proposed Rule 40 CFR Part 60

NSPS Review 2014 40 CFR Part 60 

Pa e From proposal conce t Comment (regarding Solld Fuei Room Heatern 

PP47 Licensed pellets, regulate chimney height, draft P®Ilets have as much variability as wood. Chininey 

specs, moisture content and limlts on visible heights and draft Is a htrge varlable. Hard to 

emissions. Use the grade tested to, or better.., manage. Maybe a clearer publication and more 

Infonnatlon in the manual would be good. Most 

consumer complaints that come back to us (as a 

manufacturer) go back to the chimney. 

PP49 ASTM E2525-10 Standard Method for determining The ASTM method was developed to create a 

particulate matter /n a di/utlon tunnel for sampling ciearer, less cumbersome option to method 28 and 

and analysis of emissions, . ASTM E2779-10 should be adopted, until there is some better 

Standard Method fordetermin/ng Particulate niethod that has been demonstrated. It also 

Emissions from Pellet Heaters and ASTM 2780-10 addressed larger fireboxes which are ignored In this 

Standard Method for determining Particulate proposal. 

Emisslons from Wood Heaters for fueling and 

operation (confusing) 

PP51 the states and EPA are concerned about changing The current grams/ hour/stove Is not relevant to the 

any burn rates becatrse the low is the highest actual "power per hour". Is It better to have two 

emitting and least efficient. Asking for comments: small 3 g/hr, stoves or one bigger 4 gram/ hour 

(no provision for larger stoves.	If a single burn stove? There shouid be a low burn rate and g/hr. 

appliance is acceptable, so shouid a larger stove result appropriate for firebox size. The existing rule 

with a low > 1kg/hr.) has discouraged the manufacture of larger, more 

appropriate stoves. 

Burn rates for each category stand aione, no This Is a whole new test protocol. No produet today 

averaging. is there. Existing data become lrrelevant. We 

must conslder actuai test runs today PLUS the 

inherent variability In the test methods. 

We propose to not ailow the 5 minute startup There is one company that has a patented gadget 

before ciosing doors because startup Is often the to simulate a 5 minute door opening. It is a gadget, 

highest emitting..	"again, relatively Inexpensive not a technology, and it Is restricted by patent law. 

means exist to reduce these emissions". (Patented Gadgets that help in test results oniy shouid be 

approach, unavailable, consumers leave ) handicapped by bypassing them. The "new" 

proposed barometric gadget to regulate primary 

and secondary air will only work if you have no 

carpet, cats, dogs, or dust. We wiil not improve air 

quality with this. Consumers leave the door or ash 

pan open for 5 minutes. It is what they do. Ask 

them. 

PP52 No Conversion between 5G and 5H. After final AII stoves legally tested to 5H and with emissions 

rutemaking, 5H will not be allowed below the 4.5 gr/hr. should be grandfathered for the 

duratlon of the Step 1 

Fuel Moisture range of 19-25% will be changed to It Is nearly impossible to keep wood at a 5% 

22,5% +/-1 % variatlon. It will be Impossibie to manage +/- 1% 

and this cannot help simulate "real worid" wood. 

100% impossible. This is a naive concept. 

PP53 Fuel load from 7#/ft3 +/-10% to +/- 1%, coal bed Makes testing more difficult. A consistent fuel in 

from 20-25% of fuel load weight to 22% +/-1 % density, moisture, consistency and dimension wilt 

improve repeatabifity, all other tinkering adds 

complexity only. 

CSA B415.1-10 for efficiency, each run reported. Makes sense.	Require that If a manufacturer 

wishes to ciaim efficiency anywhere, this is the only 

data allowed to be published. One step more, if a 

single number Is to be published; define what it will 

be (high, low, average?). Aiternately we will see 

ciaims tike "up to 88°10". Let's be ciear... please.

46 heatthsbone 
Comments to EPA's NSPS Proposed Rule 40 CFR Part 60

NSPS Revlew 1014 40 CFR Part 60 

Pa e From proposal conce t Comment (regarding Solld Fuel Room Heaters 

Alternate methods forfuel Moisture testing: With Makes testing more difficult adds compiexity only. 

a probe, averaging or alternately by sllcing samples A sample that has been thoroughly tested wiN not 

and heating the water out, be used so the precision is out the window. Probes 

work weli, we have them and know how to use 

them. Lets not solve non-problems. 

PP55 11. We propose to require two Step 1 tests, one We have no data today suggesting this will work, 

crib, one cordwood and reasonable non binding different fueis may have different oxygen 

tests with a range of fuels for which the appliance requirements. Increasing testing cost by 100% 

is designed for warranted/ advertised operation. ' again for each fuel tested. Suggestion: Come up 

Step 2, cordwood only with a consistent hybrid fuel and make its standard 

in 50 states. If we go down the road of selecting 

wood types, the states will each want their own and 

the testing cost wili become prohibitive. Cordwood 

will oniy add to inconsistency. 

PP73 IThe EPA estimates annualized costs of $15.7mm Unsupported data. Even the NERA data Is 

from 2014 to 2022,,. impaots to Industry range conservative. 

from 4.3% for wood heater/ stove models..: 

PP77 See tabie 71 (Wood Heaters reduce 163 tons vs. 47% of cost to cordwood stoves and pellet for 8% 

4825 for ali categories or 3°fo) 111 of the improvement. This category is being 

penalized despite being cieaned up for 25 years, 

PP84 $356,250/ stove fior R&D costs, provided by HearthStone was not asked about development 

manufacturers.	Requesting specific comment as costs. Thls varles widely based upon materlals 

to see if we should reduce emissions sooner... used and availabie technology. The $356k number 

is appropriate for a steel stove meeting 1988 

standards. We have no benchmark for testing to 

the new standard, this number cannot be 

calculated. (see "The Creation and Evolution of a 

Cast Iron Wood Stove") 

Continued from above (assume asserted cost is correct, assume the cost 

was spread over 5 years). HearthStone has 16 

owned certificates x $356,250 = $5,700,000 or 

$1,140,000/ year/ 14,400,000(annual solid fuel 

sales)= 8% of sales. This exceeds profitability. We 

cannot survive this, even in this idealized scenario. 

In the 2 step approach, this investment is obsolete 

In 5 years. 

Continued from above Pellet stoves require no R&D? Pellet stoves have 

been the "goiden chiid° despite ali maJor brands 

never being certified based upon ASSERTIONS of 

clean. HearthStone certified Its pellet stove and It 

was not as easy as we have been sald. We shouid 

also consider the "Carbon Footprint" of pellet 

production and credit wood stoves for having a 

significantly smaller one. 

PP 6 Table 9 The annualized cost of $4,212,303 for A wrong assumption, it should be 8 years since the 

wood heaters vs. $15,688,471 for all categories or standard is to be reviewed every 8. We have never 

26.8% this is based upon a 20 year life. had a stove run for 20 years, this badly skews the 

cost. Our average certificate is <10 years old. 

PP88 Incrementai cost increase of $24 for NSPS $ 24 estimate is an unfounded ludicrous assertion, 

certification. (due to testing over sales of 14283 too Irrelevant to respond to. A sales pitch taken In. 

units /$356k) Cost estimate not relevant to high quality product 

$859, another Irrelevant assertion. No one has 

asked us.

d6 hearthstone 
Comments to EPA's NSPS Proposed Rule 40 CFR Part 60

NSPS Review 2014 40 CFR Part 60 

Pa e From	ro osai	conce t Comment Improllng Solid Fuel Room Heaten 

PP96 BSER..the fact that top-performing models for each No stove has been tested to the proposed protocol 

appllance type are aiready achieving the proposed so this assertion is 100% wrong. Pubiished 

emissions level... certification numbers are weighted averages. 

20 years life is based upon the historical data that We are not aware of any and do not have any In 

non cosmetic aspects of wood heaters designed to our certification pool.	Data or assertlon? 

meet the 1988 NSPS are stlll being used In some 

modeis. 

PP100 The Median emissions for all certlfled stoves today Data source? A certificate In place in NO Indication 

is 3.4 gr/hr, of any sales volume in the field. The cheaper, 

easier to use stoves have higher volume. A 

certificate in place is no Indication of sales. 

PP101 11 non cat and 16 cat stoves meet 1.3 g/hr. Asking No consideratlon is included for larger fireboxes 

for comment and emission data to support a which have been discriminated against due to the 

different emisslon level for cord wood vs. cribs. low burn rate, 1 kglhr. No consideration for how 

consumers operate the products( complexity, bypasses etc.). No data for a correlation between 

cordwood and cribs exists and will take years of 

collectlon to become useful.	No data available Is 

reievant to the category 1 and 4 proposal. 

...recent study of 4 catalytic combustors in two There were two catalytic combustors selected with 

PP103 separate heaters ... the combustors malntained no documented use history. Many cats last a long 

substrate integrity without substantlal PM time as the owner runs the stove In bypass, 

performance reduction... combustors that are not engaged do not have any 

limit to life. (See the Stevenson Survey) 

PP106 Data showed a variability in test date of 2.9-5.4 The EPA Is asserting that the Ferguson test a 

s107 g/hr., reproducibility was +/-4.5 g7hr. (this is scam. Is there alteroate data? HearthStone's 

completely discounted by the EPA citing that "they actual data supports Ferguson. (examples given In 

intentionaily staged the test to demonstrate that text) 

variabillty was Possible within t e Protocol 

PP111 Single burn rate heaters. "tamper proof settings" No one uses a stove at a single burn rate. If the 

required on some modeis. stove has no Internal control, an external one is 

needed and will be Installed e.g. a flue damper. 

PP113 2. Central heaters. ..any central heating, wood Larger firebox residential wood heaters should be 

burning appliance" included or have some provision. Existing 

reguiations have encouraged other exempted 

technologies and prevented the development of 

whole house wood stoves. 

PP131 Justification for a three stage approach. (The The labs are aiready log Jammed, as is the EPA. 

population of stoves currently crib tested between 

4.5 and 2.5 g/hr. have time to achieve a higher 

standard. Sta e 2 must be crib 

PP133 Efficlency and CO. These numbers are aiways tied to emissions and 

&134 are not necessary. Excesslve efficiency In a 

laboratory will result In a poor performance In the 

field. It is Important to remember that energy glven 

up by a wood stove drives the chimney. Excessive 

efficiency wlll require external energy (Electric) in its 

ac . 

PP135 PFI Pellets are not generally available. True and a problem. 

PP137 ..requlring commercial owners to provide a A moisture meter will not change a consumer's 

moisture meter at the time of sale... (a consumer burning habits. It will not last the iife of the stove, 

can reference a meter, but cannot control moisture there is no Intrinsic motivation to use one. 

coritent. A moisture meter is only useful If used, Consumers need to be educated as to how to burn 

how can this be accomplished?) wood.

4o hearthstone 
Comments to EPA's NSPS Proposed Rule 40 CFR Part 60

NSPS Revlew 2014 40 CFR Part 60 

Pe e From proposal conce t Comment (regarding Solld Fuel Room Heaters 

PPtss ...1 year between date of thls proposal and final Given the weight of this rule, any certified stove 

rule to meet proposed compiiance standards and today meeting Step 1 should be allowed to be 

lilrits...	If a stoves certlfication is almost up, this extended through the time of the current phase. 

causes a time frame as short as 1 year to recertify I.e., we have several stoves that run out In less 

it. than 1 year. Manufacturers developed these 

models in good faith to a standard In piace for 

many years. Now they are being penalized 

because EPA failed to make the necessary 

6 months "sold at retail" see above.. 

PP147 Testing in Step 1 Manufacturers will have to test Very expensive and a waste of time untii there is an 

with cribs and cordwood and choose the listing. appropriate standard developed and a date set 

(effectively doubling the cost of testing, "round robin collected and analyzed. 

testing will also, eventuaily be paid by the 

manufacturer) Step2 testing will be with cordwood 

and weighted average is gone, replaced with Cat 1 

and 4 actual #'s 

PP164 C. Regulatory Flexiblilty Act: Small Entity This rule has a substantiai Impact on this entity. 

Devastatinq, in fact. 

PPt61 The Panel (of SER companies) recommended that Many signlficant manufacturers are foreign or 

the EPA should consider focusing efforts first on foreign owned. The parties at the tabie did not 

Emissions sources that have the greatest potential represent the Industry. 

to impact pubiic health through magnitude of 

emissions and Population exposure. 

PPi82 This proposai emphasizes that it does not affect Not true, if a stove certificate expires between 

existing units. January 2015 and 2020, R is in trouble before the 5 

years. As soon as March of 2015 in some cases. 

PP189 Drawings provided to Identify critical parts ... Air SubJective and difficult to regufate 

tubes ... can be readily inspected and replaced 

PP200 (Iv) The Certifying Entity must conduct quarterly (additianal costs) The variability does not exist in 

unannounced audits... the products, it exists In the protocol. Passing the 

cost to the manufacturers will not create a better 

protocoi. 

PP201 an audit test wili be conducted using either the This will only increase variability and needs to have 

method originally tested with or another method as data collected before becoming part of the rule. 

determined by the administrator. Also, the 

administrator may seiect ANY lab for the audit test.

&i hearthstone 
46 heardisrone

Comments to EPA's NSPS Proposed Rule 40 CFR Part 60 

In closing, with reference to Solid Fuel Certified Room Heaters... 

There is a great need to update this 25 year old rule. And while the new found 

sense of urgency is laudable, it should have been done incrementally over the years 

as was mandated, and well intended manufacturers and consumers should not be 

made to pay the price. The quantum change proposed, while also well intended, is 

not feasible without a proven method and some actual data sets at this time. A 

change from 7.5-4.5 grams/hour with the existing protocol represents a 40% improvement. With the protocol unable to provide precision >+/- 4 grams/ hour, this 

means a 4.5 gram/ hour stove may be from 0.5-8.5 grams/hour. 

The 83% reduction from 7.5-1.3 grams/hour with an unknown protocol and no data 

is just not logical, affordable or worth the risk. There is not a certified stove in the 

world today that meets these numbers under this proposed, semi complete protocol. 

This is a green industry. No nukes, no oil, no fracking, carbon neutral, local fuel and 

jobs for primarily rural Americans. We need to embrace changing out the 7 million 

pre-EPA or exempted from EPA products that smoke up our communities, and not 

kill the segment of the industry that replaces 140,000-200,000 of them annually. 

Thanks for reading our comments! 

David Kuhfahl 

President