EPA Action Alert

The Issue:

Last January the EPA issued its proposed New Source Performance Standards (NSPS) for residential and light commercial wood heating equipment. This standard is set to take effect in January 1, 2015. During a 90 day period ending on May 5, 2014 the EPA will accept comments from the public regarding the proposed new rules.  This proposed new standard:

  • Defines specific emission limits for all wood heating equipment manufactured after January 1, 2015.
  • Defines how wood heating equipment is to be tested.
  • Defines what wood is to be used in testing.
  • Etc., etc.

If this new rule becomes Federal law, it will essentially continue the existing EPA Phase II Voluntary Program regarding outdoor wood heaters. In this Voluntary Program the EPA insists that all testing be in accordance with EPA Method 28 and that all testing use crib wood (expensive sanitized bark free, dirt free, dried 4 x 4 oak with ¾” oak spaces), rather than standard readily available oak cordwood. During the past few years it has been shown that the EPA Method 28 does not correlate well with field performance when standard cordwood is burned. In fact, the EPA on May 9, 2013 directed manufactures, who tested their equipment using EPA Method 28 with crib wood, to remove all efficiency numbers from any advertising as the ratings were grossly overstated (http://tinyurl.com/qhmvqzk).  Crib wood test fuel is NOT a good predictor of field performance.

The American Society of Testing and Materials (ASTM) also developed a test protocol for hydronic wood heaters (all models including modulating, full thermal storage and partial thermal storage). It is ASTM Standard 2618-13 and has been vetted by Engineers, manufacturers, regulators, test labs and scientists. It is fundamentally different from EPA Method 28 in that the ASTM test requires the use of cordwood as the test fuel. The test results of this method correlate well with actual field use and should be the test that the EPA requires for wood heating equipment.

If you want to learn more specifics about crib wood vs cordwood, go to this link https://www.garn.com/media/articlesnews/ and then click on the GARNews issue titled “GARN EPA Testing – 1-3.”

Why You Should Care:

FIRST – As an existing user of wood burning equipment, it is important to recognize the damage that crib wood tested, EPA Phase II qualified boilers do when they burn “dirty” in actual field operation. The general public is increasingly intolerant and distrustful of all wood boilers because so much of the so called “EPA phase ll qualified equipment” continues to create a smoke nuisance when burning cordwood.

SECOND – Anyone looking to purchase new equipment should have accurate information available about equipment they are considering. It is impossible to draw any conclusion about the way equipment performs unless it has been tested with real fuel, cordwood. Real efficiency numbers should be reported on the EPA website (the EPA was forced to drop what they knew to be ridiculous numbers based on faulty testing as noted above).

FINALLY – The EPA’s refusal to drop the crib wood test as a means of testing guarantees that additional polluting equipment will be manufactured, sold and operated. We will all pay for this when the general public becomes fed up and all wood burning boilers are outlawed.  Don’t for a minute believe it can’t happen….it’s already happening in numerous counties throughout the US. Is that what you want?

What You Can Do:

So what can you do as a concerned wood heating enthusiast? It’s imperative that you contact you elected US Senator and Representative and voice your concern about the EPA’s approach to the emission and efficiency testing of wood heating equipment. A list of all US Senators and Representatives can be found at (http://www.apatheticvoter.com/CongressionalReps.htm). Specifically, let you Representative know that:

  • Any testing should use with real cordwood and NOT crib wood.
  • Testing should be according to ASTM 2618-13, not EPA Method 28.
  • The EPA must remove any unit tested with crib wood from its Qualified List.

And you can submit your thoughts directly to the EPA. In any communication with the EPA you must refer to document EPA-HQ-OAR-2009-0734, Section 3B, pages 6344, 6345 and 6346. Submit comments by:

  • Fax to: 202-566-9744, Attn: Docket ID # EPA-HQ-OAR-2009-0734.
  • Online at: www.Regulations.gov
  • By mail to: Air and Radiation Docket and Information Center, EPA, Mail Code: 2822T, 1200 Pennsylvania Ave., NW, Washington, DC, 20460
  • Hand delivery to: EPA Docket Center, Room 3334, 1301 constitution Ave., NW, Washington, DC, 20460.

Respond no later than May 5, 2014. If you want reasonable limits and reproducible good test methods, you really must respond to this NSPS. It is imperative that you let the EPA, your Senator and your Representative know what you think. If you want to read the full EPA document a PDF is available at: www.federalregister.gov/articles/search under EPA-HQ-OAR-2009-0734.

                           © March 2014 DECTRA Corp