WASHINGTON, D.C. – U.S. Senators Susan Collins and Angus King today sent a letter to Environmental Protection Agency (EPA) Administrator Gina McCarthy expressing concern with the agency’s proposed revision of rules regarding wood-burning stoves.  EPA has proposed a rule updating its 1988 standards for new wood stoves and heaters.

In the letter, Senators Collins and King express support for efforts to improve air quality and human health, but write, “The purpose of the rule is to lower particle pollution levels and diminish the associated health risks. The proposed rule, however, fails to fully consider practical, economic, and environmental realities and could end up impairing its own laudable objectives. Rather than reduce harmful emissions, the new standards would make it prohibitively expensive for many homeowners to purchase new, more efficient stoves.”

Last month, the EPA held a public hearing in Boston on the proposed standards.  The public comment period ends May 5^th.

The full text of the Senators’ letter is as follows:

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March 27, 2014

Ms. Gina McCarthy

Administrator, US Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, DC. 20024

Dear Administrator McCarthy:

We are writing to share some concerns regarding the EPA’s proposed revision of the New Source Performance Standard (NSPS) for Residential Wood Combustion, which regulates emissions of solid fuel burning appliances. First, however, we would like to point out that we support the EPA updating its regulations on particulate matter emissions from wood stoves for the first time since 1988. Woodstoves on the market today greatly exceed the current EPA standard for emissions. These new standards are of significant interest to our Maine constituents who share your Agency’s concern for improvement in air quality and human health.

The purpose of the rule is to lower particle pollution levels and diminish the associated health risks. The proposed rule, however, fails to fully consider practical, economic, and environmental realities and could end up impairing its own laudable objectives. Rather than reduce harmful emissions, the new standards would make it prohibitively expensive for many homeowners to purchase new, more efficient stoves. 

The proposed rule would not affect existing woodstoves and other wood-burning heaters in peoples’ homes, and many will continue to use their pre-1988 stoves, which are one of the primary sources of particulate matter emissions in the country. Results of a 2008 study in Maine showed 77 percent of respondents had woodstoves over 24 years old. It would be appropriate for EPA to consider, as part of this rule, implementing incentives that would encourage homeowners to remove their old stoves. Greater emission reductions would be realized with such an approach. 

Unlike the current rule, which has been in effect since 1988, the proposed standard provides no distinction between catalytic and non-catalytic woodstoves. Yet, there are significant differences between catalytic and non-catalytic woodstoves, and those differences play a dominant role in the woodstove marketplace. Non-catalytic stoves are both less expensive and easier to maintain. Not surprisingly, therefore, many Maine residents have purchased non-catalytic woodstoves. If, as the proposed rule contemplates, both catalytic and non-catalytic woodstoves were held to the same standards, it would create a very real risk that non-catalytic woodstoves would simply be eliminated from the marketplace.   

In considering the proposed rule, we sought the views of a Maine woodstove manufacturer which is concerned that the standards in the proposed rule will substantially increase manufacturing costs – costs that must be passed on to the consumer, thus increasing retail prices. Increased retail prices, of course, will discourage new purchases and have the contradictory effect of causing existing owners of old woodstoves to simply hold on to their older stoves longer. As we have noted, the available data on woodstoves indicate that these purchases have staying power – once a woodstove has been purchased, it may stay in place for a quarter century or more. Given this marketplace reality, great care should be taken to help consumers use their wood stoves properly. Consumers making small changes in operation of their stoves can greatly reduce emissions. 

For emissions to be reduced in the foreseeable future the woodstove standards need to be reasonable; they should take into account and reflect the practical realities of the marketplace. They must not result in new stoves that are prohibitively expensive. The consumer must view newer, cleaner stoves as an economic benefit both in the short term and the long term. Without that, neither the EPA nor the woodstove industry will be able to achieve the health objectives we all share. 

Thank you for the opportunity to comment on the proposed rule.

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