Posted on 02/03/2014 4:33:29 PM PST by dynachrome
The impacts of EPA’s ruling will affect many families. According to the U.S. Census Bureau’s 2011 survey statistics, 2.4 million American housing units (12 percent of all homes) burned wood as their primary heating fuel, compared with 7 percent that depended upon fuel oil.
Local governments in some states have gone even further than EPA, not only banning the sale of noncompliant stoves, but even their use as fireplaces. As a result, owners face fines for infractions. Puget Sound, Washington is one such location. Montréal, Canada proposes to eliminate all fireplaces within its city limits.
Only weeks after EPA enacted its new stove rules, attorneys general of seven states sued the agency to crack down on wood-burning water heaters as well. The lawsuit was filed by Connecticut, Maryland, Massachusetts, New York, Oregon, Rhode Island and Vermont, all predominately Democrat states. Claiming that EPA’s new regulations didn’t go far enough to decrease particle pollution levels, the plaintiffs cited agency estimates that outdoor wood boilers will produce more than 20 percent of wood-burning emissions by 2017. A related suit was filed by the environmental group Earth Justice.
(Excerpt) Read more at forbes.com ...
1. We do not agree with the ASTM changes to the burn rate categories, low burn rate requirement, and weightings in Method 28. Several states are very concerned that easing these items would create the potential for backsliding. Also, we are aware of several design changes being considered by a number of manufacturers that are relatively inexpensive (i.e., less than $20 dollars) and will reduce the emissions during periods when operated at low burn rates. We instead propose that the original provisions in Method 28 be retained for the burn rate categories and low burn rate requirement. We considered the weightings and believe that if weightings are to be used, they should be the same as the original requirements in Method 28. We are also proposing that the burn rates not be weighted at all for the Step 2 standards but rather that the emission limits be separate for Burn Rate Category 1 (lowest burn rate category) and Burn Rate Category 4 (maximum burn rate category) and that compliance for each be shown...
2. We propose to not allow 5 minutes for startup before closing the doors because startup is often the highest emitting part of the wood heater operation, and manufacturers need to ensure that startup emissions are also reduced. Again, relatively inexpensive means exist to reduce these emissions.
3. We are not proposing to use the new ASTM equation for converting the emission test values between the EPA Reference Method 5G âDetermination of Particulate Emissions From Wood Heaters From a Dilution Tunnel Sampling Locationâ and the EPA Reference Method 5H âDetermination of Particulate Emissions From Wood Heaters From a Stack Locationâ currently allowed in the NSPS. Rather, we are proposing that Method 5G(3) test values be reported as tested for heaters that have valid certifications prior to the effective date of this rule and ASTM E2515-10 for all other heaters and that Method 5H not be used for testing for certifications after the effective date of this rule. We request data to help inform our decision for the final rulemaking.
4. We are not proposing to allow manufacturers to specify a smaller volume of the firebox for testing because of our concerns about how to ensure that homeowners do not circumvent such a specification during operation, thereby increasing emissions beyond the levels that are measured during testing.
5. We are proposing several tighter specifications on the test fuel moisture content, fuel load and coal bed depth in order to improve the reproducibility and repeatability of the certification tests. This part of the proposal is based on recommendations from one of the original EPA-accredited laboratories. We specifically request comments and supporting data regarding the following proposed tighter specifications for the laboratory test: (a) tightening fuel load dry-basis moisture content tightened from the Method 28-allowed 6 percentage-point range from 19 percent to 25 percent to a reduced range of 22.5 percent +/â1 percent; (b) tightening the Method 28-allowed range for fuel load weight from 7.0 lb/ft 3+/â10 percent of the fuel load weight (or 7 lb/ft 3+/â0.7 lb/ft 3) to 7 lb/ft 3+/â1 percent (or 7 lb +/â0.07 lb) of the fuel load weight, calculated in accordance with Method 28; and (c) tightening the Method-28-allowed range for the test-initiation coal-bed weight from 20 percent to 25 per...
6. We propose to require efficiency testing according to CSA B415.1-10 (17) using the stack loss method. That is, during each test run, data must be obtained and presented for the purpose of calculation of overall efficiency as specified in CSA B415.1-10. This would include CO and carbon dioxide (CO 2), flue gas temperature and appliance mass. CSA B415.1-10 was developed by a âconsensusâ process, but no states were part of the process. Thus, we specifically request comments on our proposal to require use of this method.
7. We propose that electronic test report submittals include the locked spreadsheets so the formulas used and relevant calculations can be evaluated in detail. We request comments on this specific proposal.
8. We propose that the test report include a narrative detailing specifics about test conditions and operations, such as how the test was run, operating conditions, issues and special procedures.
9. We propose that each individual moisture content reading must be in the range of 18 to 28 percent on a dry basis and the average moisture content of each piece of test fuel must be in the range of 19 to 25 percent. Also, we propose the following procedure for the moisture measurements: âUsing a fuel moisture meter as specified, determine the fuel moisture for each test fuel piece used for the test fuel load by averaging at least five fuel moisture meter readings, one from each of three sides, measured parallel to the wood grain. Penetration of the moisture meter insulated electrodes shall be1/4(one-fourth) the thickness of the fuel piece or 19 millimeters (mm) (3/4 in.), whichever is less, for 3 of the measurements made at approximately 3 inches from each end and the center. Two additional measurements at approximately one-third the thickness shall be made centered between the other three locations.â
10. We also propose this alternate procedure developed by Brookhaven National Laboratory: (18) âSelect three pieces of cord wood from the same batch of wood as the test fuel and the same weight as the average weight of the pieces in the test load ± 1.0 lb. From each of these three pieces, cut three slices. Each slice shall be1/2â³ to3/4â³ thick. One slice shall be cut across the center of the length of the piece. The other two slices shall be cut half way between the center and the end. Immediately measure the mass of each piece in pounds. Dry each slice in an oven at 220 °F for 24 hours or until no further weight change occurs. The slices shall be arranged in the oven so as to provide separation between faces. Remove from the oven and measure the mass of each piece again as soon as practical in pounds. The moisture content of each slice, on a dry basis, shall be calculated as:
MC slice= 100 · (W SliceWetâW SliceDry)/W SliceDry
Where: W SliceWet= weight of the slice before drying in pounds; W SliceDry= weight of the slice after drying in pounds; [and]MC Slice= moisture content of the slice in % dry basis.â
11. We propose to require two Step 1 tests, one using crib wood and one using cord wood and reasonable additional non-binding tests with a range of fuels for which the appliance is designed for warranted and/or advertized operation. These tests are needed to show how emissions and efficiency vary according to test methods, operating scenarios, wood species and density and other variables such as cord wood versus crib wood. We believe that such testing would help assure consumers, neighbors and other stakeholders that the appliances perform as well on all manufacturer-listed fuels and operating scenarios as they do for the EPA laboratory test scenarios. Proposed Step 2 tests will use cord wood and not crib wood. The EPA, industry and states believe that moving to cord wood testing will help address concerns about actual emissions from heaters/stoves in home use versus test laboratories. We are working with states and industry on a cord wood test method and evaluating potential revisions to the current version
The QC on Forbes contributors doesn’t appear to be much higher than that on “Examiner” writers.
They won’t be happy until people start burning garbage inside their house for heat.
Thanks!
(f) Prohibited Fuel Types. No person is permitted to burn any of the following materials in an affected wood heater:
(1) Residential or commercial garbage;
(2) Lawn clippings or yard waste;
(3) Materials containing rubber, including tires;
(4) Materials containing plastic;
(5) Waste petroleum products, paints or paint thinners, or asphalt products;
(6) Materials containing asbestos;
(7) Construction or demolition debris;
(8) Paper products, cardboard, plywood, or particleboard. The prohibition against burning these materials does not prohibit the use of fire starters made from paper, cardboard, saw dust, wax and similar substances for the purpose of starting a fire in an affected wood heater;
(9) Railroad ties or pressure treated wood;
(10) Manure or animal remains; or
(11) Salt water driftwood or other previously salt water saturated materials.
Note by palmer: I routinely violate #8. In fact that is how I generate a lot of my heat. I have perfect burning paper over coals with an air gap that allows complete burning down to a small handful of ash.
That is specifically prohibted in the proposed regulations.
OK. Please give us an example of what an average citizens response to all this technical BS should be if you are against the EPAs proposals.
I haven’t been through the whole thread yet, but the next step is to make it illegal to sell a house with a non-complying stove. This is already happening in some places.
http://www.deq.state.or.us/aq/burning/woodstoves/questions.htm#What_is_required
I figured. I guess they will start heavily taxing blankets.
1,000,000 average citizens responding to this will make it die completely. Even 100k would make it highly quesstionable.
Their goal seems to be Obamacare for stoves (the two labels of iii are in the original)
(l) Criteria for Revocation of Certification.
(1) The Administrator may revoke certification if it is determined that the wood heaters being manufactured or sold in that model line do not comply with the requirements of this subpart. Such a determination will be based on all available evidence, including but not limited to:
(i) Test data from a retesting of the original unit on which the certification test was conducted or a similar unit;
(ii) A finding that the certification test was not valid.
(iii) A finding that the labeling of the wood heater model line or the owner's manual or marketing information does not comply with the requirements of section 60.536;
(iii) Failure by the manufacturer to comply with reporting and recordkeeping requirements under section 60.537;
(iv) Physical examination showing that a significant percentage (as defined in the quality assurance plan, but no larger than 1 percent) of production units inspected is not similar in all material respects to the representative affected wood heater submitted for testing; or
(v) Failure of the manufacturer to conduct a quality assurance program in conformity with paragraph (m) of this section.
They can do worse than taxing wood, they can regulate it. Here's some text from the proposed regulation
Some advocates have suggested that we only allow use of wood certified to a certain moisture level and that we include visible emission limits as a tool to help with practical enforceability of the requirements for proper operation and maintenance. Manufacturers typically include in their owner's manuals information on proper maintenance and operation and state that the wood must be properly seasoned so that the moisture content is not too high for proper operation. Some manufacturers include moisture meters for the operators. We are proposing to require commercial owners (direct distribution manufacturers and retailers) to provide a moisture meter with the wood heater at the time of sale, along with the owner's manual and a copy of the warranty. We request specific comments on whether we should include more specific requirements on proper operations, such as the moisture content of the wood and visible emission limitations.
Burning garbage is specifically prohibted in the proposed regulations.
Look at the windows...
what did people think was going to happen when Obama won a second term? fewer regulations?
>>> If the federalies try to shut me down, I might be heating it with spent heat leftover from gunpowder rounds!!
I understand the taxpayer-funded lard found under the skin of a well-fed bueaurocrat burns long and hot.
Not that I have room to talk about anybody’s fat, just that mine wasn’t paid for by the labor of the unknown and unwilling, LOL!
Do you really think those in the rural parts of those states who will be screwed by this vote liberal? Buy a clue and quit lumping us all in with the cities that control the states.
You must be responsible for Obama. After all, he is your president. See? Same logic.
Since when does the EPA give a rats patootie about what the majority of Americans think? They have proved themselves to be liken to a bunch of Nazis that do whatever they like. Didn't they just override a Congressional law and hand over the Wyoming town of Riverton to the Wind River Indian Reservation? Aren't they controlling the fate of the Keystone Pipeline even though the majority of Americans want to see it built and the jobs that come with it? Aren't they closing down coal powered power plants raising electric rates and losing jobs of which people are against? How about their confiscation of and or control of personal property wherever they deem a wetland?
I think it's naive to think that even if 100% of America is against their decision it would change a thing because they know they have the same kind of power as the IRS and they will do exactly as they wish.
It started with cigarette advertising, then smoking bans, and people letting the stinking government tell them how many gallons to flush and what kind of light bulbs they can have, along with thousands of nigling regulations which only affected a few, so few complained.
People don't have enough sense or gumption to stand up for things on a matter of principle, then scream when their ox gets gored.
I have a 100 year old house, the fireplace and chimney are structural elements. That same fireplace saved our butts when we had a blizzard which knocked out power to the region for days a few years back.
The EPA should be disbanded, and not just for this stunt.
Exactly as I said, ‘boiling the frog slowly’.
You and I must be kindred spirits. I also have a 100+ house but it has no central heat or air. I have used a wood stove for 30+ years now.
I totally agree. The EPA should be dissolved.
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