Comments due Jan. 14 on EPA’s residential wood heater proposal

By Erin Voegele | January 08, 2019

Members of the public who wish to weigh in on the U.S. EPA’s proposed rule to amend new source performance standards (NSPS) for residential wood heaters have less than a week to do so. The public comment period closes Jan. 14.

On Nov. 21, the EPA released a proposed rule that aims amend NSPS for residential wood heaters that were established in 2015. The proposal aims to provide retailers additional time to sell existing inventories of hydronic heaters and forced air furnaces. A 45-day public comment period on the matter opened Nov. 30.

The 2015 NSPS for new residential wood heaters updated standards enacted in 1988 to reflect advancements in wood heater technologies and design. It also broadened the range of residential wood-heating applications covered by the regulation.

The 2015 rule requires manufactures to redesign wood heaters to be cleaner and lower emitting. These improvements also make the heaters perform better and increase efficiency. The action applied to adjustable burn rate wood heaters, pellet stoves, single burn rate wood heaters, outdoor hydronic heaters, indoor hydronic heaters, wood-fired forced air furnaces and masonry heaters.

The standards finalized in 2015 phase in over a five-year period. For woodstoves, pellet stoves and hydronic heaters, the rule is being phased in in two steps, with the first set of requirements in effect May 15, 2015 and the second limit taking effect in 2020. For wood-fired forced air furnaces, the final rule required wood practice standards beginning on the effective date of the rule, with emissions limits phased in in two steps between 2016/2017 and 2020, to give manufacturers the time they need to develop cleaner models and conduct emissions testing. Small forced air furnaces were required to meet step one emissions limits by 2016. Large forced air furnaces were given an extra year to meet step one requirements, with compliance required in 2017. All forced air furnaces are required to meet the step two emissions limit by 2020.

The new proposed rule released by EPA would amend the 2015 NSPS for new residential hydronic heaters and new forced-air furnaces by adding a two-year sell-through period for all affected new hydronic heaters and forced-air furnaces that are manufactured or imported before the May 2020 compliance date to be sold at retail through May 2022. Within the rulemaking, the EPA explains this will allow retailers additional time after the May 2020 effective date of step two standards for the sale of step one compliant hydronic heaters and forced-air furnaces remaining in inventory.

The EPA is also seeking comments on whether a sell-through period for all affected new residential wood heaters is appropriate following the May 2020 compliance date. And, if so, how long a sell-through period is needed and why. The proposed rule also seeks comments on whether the current minimum pellet fuel requirements should be retained, and if so, whether they should be revised.

A public hearing on the proposed rule was held in Washington, D.C. on Dec. 17. Past Pellet Fuels Institute and American Wood Fiber President and CEO Stephen Faehner testified at the event. In his testimony, Faehner stressed PFI’s opposition to the inclusion of minimum pellet fuel requirements within the regulation and reiterated the PFI’s position that the organization is not opposed to the aims of the Clean Air Act.

“Pellet fuels offer one of the cleanest burning alternatives in the wood heating sector; they have been used in a number of communities to reduce particulate matter and are often part of wood stove ‘changeout’ programs, designed to spur replacement of older equipment,” Faehner said in his testimony.

Faehner explained that the PFI’s opposition to the rule is that its inclusion would place a compliance burden upon wood pellet manufacturers that would be unique amongst their peers in the broader wood heat category. Faehner said, “EPA’s current regulations define 34 different requirements for pellet fuel, compared with just seven requirements for chip wood and no specifications at all for cord wood, by far the largest fuel source in the NSPS category. EPA illogically applies the most onerous regulations to the cleanest fuel.”

Comments on the proposed rule can be submitted online through under docket number EPA-HQ-OAR-2018-0195 through Jan. 14.

Also on Nov. 21, the EPA issued a separate advanced notice of proposed rulemaking (ANPR) pertaining to the 2015 NSPS for residential wood heaters. The ANPR seeks comments on several aspects of the regulation in an effort to inform future rulemakings and improve the standards and related test methods. A 75-day comment period on the ANPR opened Nov. 30. Comments on the ANPR are due Feb. 13 and be filed online through under EPA-HQ-OAR-2018-0196.