Why you don't want an outdoor wood boiler

From Cornburning

September 2, 2005

Mr. Stephen L. Johnson, Administrator Environmental Protection Agency Ariel Rios Building 1200 Pennsylvania Avenue, N.W. Washington, DC 20460

Subject: Outdoor Wood-fired Boilers

Dear Administrator Johnson:

I'm writing to request your assistance with a national strategy to address problems associated with Outdoor Wood-fired Boilers (OWBs). OWBs are becoming increasingly common in Wisconsin and with increasing energy costs, we expect their numbers to continue to increase. As a result of their increasing numbers, citizen complaints and public health concerns with emissions from OWBs have been multiplying in Wisconsin. While Wisconsin has attempted to address this problem on it?s own, OWBs are sold nationwide and numerous states are facing similar problems with them. I believe it?s a national issue that requires federal action.

A Significant Public Health Concern. For a number of reasons, OWBs present emissions problems not normally observed with indoor wood stoves, wood furnaces, or fireplaces. For example, an OWB commonly has a very short stack that emits smoke near the ground and allows for little dispersion. The majority of units are designed for large fuel capacities and to operate with automatic damper controls. They also typically incorporate primitive combustion designs. This combination frequently results in poor combustion, heavy smoke, noxious odors, and high concentrations of fine particulates and other air pollutants associated with low temperature combustion of wood fuel. For neighbors that are continuously exposed to the smoke, OWBs are a very real and significant public health concern.

Petition from States for Federal Regulation. Since 1988, the design and performance of indoor wood-fired stoves has been regulated nationally by the U.S. Environmental Protection Agency under the ?Standards of Performance for New Residential Wood Heaters? (40 CFR Part 60, Subpart AAA). However, despite polluting at a significantly higher rate than residential wood stoves, OWBs are exempt from federal regulations and are not required to meet any testing, performance, or emission standards. On August 11, 2005, the Attorneys General for the States of New York, Connecticut, Maryland, Massachusetts, Michigan, New Jersey and Vermont, and the Northeast States for Coordinated Air Use Management (NESCAUM) petitioned you to use your authority under the Clean Air Act to list OWBs as a category of stationary sources and to establish standards for emissions from new OWBs. I support that petition and hope that you will respond in the affirmative. A broader national strategy is needed, however, and federal emission standards should be just one component of that national strategy.

A National Strategy. A national OWB strategy consider both regulatory and non-regulatory needs related to new and existing OWBs. One component of the strategy should be national emission standards for new units. Federal emission standards alone, however, won?t solve the problem. The strategy should cover the roles of federal, state and local governments as well as the role and responsibilities of manufacturers. Such a strategy would best be prepared under EPA leadership and through a collaborative effort between the states, the manufacturers, EPA and perhaps representatives of local governments. You might also want to invite the participation of interest groups like the American Lung Association and the Outdoor Furnace Manufacturers Caucus of the Hearth, Patio and Barbecue Association. Perhaps the states could be involved in development of a national strategy through the participation of state executive branch organizations like STAPPA or ECOS. Elements of a national strategy could include the following:

   * Federal emission standards for newly manufactured units. EPA should
     proceed rapidly to develop federal emission standards.
   * State and local regulations. Identify the role of and provide
     guidance for state and local regulations on OWBs.
   * Informational materials for owners and prospective buyers of OWBs.
     Identify educational information needed for prospective buyers so that they
     are cautioned when an installation might cause problems for neighbors.
     Examine informational needs regarding operation of OWBs to minimize
     emissions. Recommend priorities. Identify roles and responsibilities for
     federal, state and local governments and for manufacturers. Examine funding
     needs, sources and alternatives.
   * Research and monitoring needs. Identify needs and establish
     priorities for research and monitoring related to OWBs. Examine funding
     sources and alternatives.
   * Information for affected citizens. Examine informational needs and
     establish priorities for information on who to contact if you're adversely
     affected, what regulations apply to your situation and where to obtain
     health effects information. Examine funding needs, sources and alternatives
     to cover costs for development and dissemination of materials.
   * Information for local governments. Consider what information needs
     local governments need regarding OWBs. What are their alternatives in
     responding to citizen concerns or complaints.

I urge you to proceed with federal emission standards and to begin the development of a national strategy to deal with emissions from OWBs. If you or your staff would like to discuss our ideas for a national strategy, you may contact me, Lloyd Eagan, Director of our Bureau of Air Management at 608-266-0603 or Kevin Kessler, our Open Burning Team Leader at 608-266-5207. Thank you for your consideration of this important request.

Sincerely,

Scott Hassett Secretary