Standards » “There won’t be a target, but it will be measured. And it will be on the hang tag for the consumer to see.” Other possible features in discussion for the new rule may be more problematic. There are indications the EPA could include emission caps on different levels of heat output, possibly in four steps from low- to high-heat output, for example. “That could force changes in appliances that might surprise people,” says Crouch. Manufacturers of pellet boilers are concerned that there may be some features in the NSPS that reflect the European handling of thermal storage, and may be difficult to transfer to the U.S. market. If a pellet boiler, for instance, is certified for emissions using thermal storage and a consumer opts to not buy the separate thermal storage component, the appliance would not be in compliance with EPA rules. The details of how a situation like that may be handled in the rule is the cause of some concern, Crouch explains. Since many pellet stoves already meet the new emission targets, there is also the possibility the EPA may tighten the standards for pellets. “There’s no reason that we would legally be prohibited from doing it,” says Wood. “But as we look at these units that are competing with each other— wood stoves, pellet stoves—is there a great benefit for squeezing the number tighter, if they’re already doing it?” Issues surrounding the idea have included the potential for backsliding by those now exceeding the standard and the relative cost of the appliances. “We’ve asked for comment on that issue—should we set a tighter limit for pellet stoves?” Other issues may emerge when the proposed rule is finalized. The Clean Air Act does require that regulations be costeffective, Wood says. “It looks achievable; it meets the cost-effectiveness test.” At the time of the webinar, during which Wood spoke in early May, the agency was still working on the cost-effectiveness report and Wood couldn’t comment on specific numbers, but he says that the benefits EPA has monetized for this rule are far greater than the cost. The cost/benefit analysis will be scrutinized by the industry. “We’ll be looking closely at what the cost effectiveness of the
various levels will be, and in pellet stoves particularly,” says Crouch. “We are interested in levels that allow appliances to be made that meet consumers’ needs at a price that consumers think is reasonable. That includes not being so carefully tuned that they can only burn perhaps very specific grades of pellets.”
Remaining Steps The agency expects to get the draft submitted to the Office of Management and Budget this summer, which would lead to getting the proposed rule published in the Federal Register by the end of summer, Wood says. A 90-day comment period will be followed by an agency review. “Typically, it takes a year before the final rule is promulgated,” he says, giving mid-2014 his best estimate for the NSPS to take effect. Crouch cautions that with the large number of regulations the OMB reviews, the process is likely to take longer. Once the rule is in final form, the industry will be re-
viewing it closely to see what changes have occurred since Wood began making the rounds to outline the agency’s current thinking and solicit more input. “We think pellets will be well-served by being uniformly certified, depending on what the final regulations look like,” says Crouch. “Until the rule is published in draft form, there’s still speculation on what exactly it says. The devil is always in the details. We want to see the details.” “We think the first step is going to be pretty good,” Crouch adds. “The Washington state number of 4.5 is certainly doable.” Some manufacturers will need to get appliances certified, of course, he points out. “The details are down the road.” Author: Susanne Retka Schill Senior Editor, Pellet Mill Magazine 701-738-4922 sretkaschill@bbiinternational.com
Q2 2013 | PELLET MILL MAGAZINE 27