F'ETEFi l'VE:LCt I

,., ^.,F

### ..,:r .,rw",,,, 

## ,lE E DFP,,,Y :,,HIT t^^itgre,^^ of tll^e ^ztttexl ` ^ttt^eti ^-i,i^,^;r ^^,-ti^^xRaiic ^; ^E:E^:Ri^;c aPOi- icv cONIrv^i r E;E IlLltwe Df lgk}it'E"liktltFtfittl'!i CQMM1T'1"F:E C)N ENER(3v allo rOnnMFRCE Ifla,6`iljilitjXi?ti. DC 

### r ' N15 1 5—"451111 c0n,-innrrrEr- oN c.vFRSie {T ^,Nti c;ovr:nNnnEN r

{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 That the current regulations are seriously out of date is evidenced by the fact that ceilified wood stoves currently sold by Hearthstone, Vermont Castings and other high quality manufactui•ers typically exceed the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_ ^ 220 Io 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 00 $150,0 to < $199,000 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 CO2into wood 

### (biomass). When a 

### tree rots naturally orburns, the carbon contained in the wood is released back to the at

### mosphere. Encotiraging the use of this 

### resource is the right thing to do!

4o hearthstoneThe 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 hearthstoneComments to EPA's NSPS Proposed Rule 40 CFR Part 60

---^--y^ ©urn Lmistion Neat WYtdAvp Model A, Test 2 "n R°t° aAte °°tp"t (whr> 1 kU mrl 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 ofchance. The cost associated means repeating thetest until a good one happens. These products are10X 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 hearthstone1200 -' __ _._. 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 hearthstoneStep 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., heatthstoneCornments 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 forthe 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 EPA estimates annualized costs of $15.7mm Unsupported data. Even the NERA data Is IThe 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 ifwe 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 howconsumers 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) variabilltywas 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. Devastatin q , 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 hearthstone46 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. Achange 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