2011 Dec. 9: MN & WI: Contact NRDC and say No OWBs in Senate Bill 1914 “Cut Energy Bills at Home Act”!
As you all probably know, NRDC (Natural Resources Defense Council) is heavily promoting Senate Bill 1914, which would give a huge tax credit to OWBs. Note that Meg Waltner is a big player at NRDC on this issue. Here’s her blog posting that some of you have commented on: http://switchboard.nrdc.org/blogs/mwaltner/new_senate_bill_will_reduce_ho.html
See this memo showing NRDC staff meeting with the Dept. of Energy about this bill: http://energy.gov/sites/prod/files/Memo_10_21_11_Meeting.pdf
From what I’ve found, Ms. Waltner is a major player in the wording of this flawed bill.
I just sent Ms. Waltner the e-mail below. Feel free to use any content from my e-mail if you want. But please remove my name and contact info. Send her your personal stories and photos so she can see the human side of this issue. I can’t imagine that she would be working for the manufacturers. She’s probably just good intentioned without understanding that this bill is promoting the sale and use of OWBs.
Please take a few minutes to send her your story. Here’s her e-mail: mwaltner
Dear Ms. Waltner:
Thank you for your work on promoting energy efficiency in homes through supporting Senate Bill 1914. However, Outdoor Wood Boilers (OWB), should not be eligible for tax credits under this bill. This bill would create a new tax code section 25E that would allow tax credits for polluting and hazardous OWBs.
Your blog posting does not mention OWBs (http://switchboard.nrdc.org/blogs/mwaltner/new_senate_bill_will_reduce_ho.html), so I can only assume that you’re not aware of these devices and how your support of this bill including supporting the sale and use of these defective devices.
What’s particularly disturbing about NRDC’s support of this bill is that the original wood stove New Source Performance Standards (NSPS) regulations in 1988 resulted directly from a NRDC lawsuit against the U.S. Environmental Protection Agency (EPA) (see: NRDC v Alm, No. 84-1473, D.C. Cir. file Sept. 18, 1984). I have repeatedly asked NRDC to pressure EPA to update the NSPS as required by law to regulate OWBs, but NRDC refuses to help. And now, through your support of Senate Bill 1914, NRDC is promoting the sale and use of OWBs by offering a tax credit! How can NRDC go from a leader in protecting public health from the hazards of wood smoke, to promoting the most polluting wood-burning device ever used in this country?
OWBs, also called Outdoor Wood-fired Hydronic Heaters (OWHH), are highly inefficient wood-burning devices that have been banned in the state of Washington and countless municipalities from Maine to Alaska. OWBs generate enormous amounts of smoke that fumigate large areas with criteria air pollutants, including PM2.5, resulting in health hazards for those living near OWBs. Below is a photo of smoke from my neighbor’s OWB that fills our valley with haze and toxic air pollutants. This is smoke from a residential wood stove, but it looks like smoke from a factory smoke stack!
OWBs are not regulated under federal wood stove certification rules under the Clean Air Act NSPS. This is because EPA failed to update the NSPS over 20 years ago as required under federal law. If EPA had done its statutory duty to update the NSPS, OWBs would have been regulated and required to meet certification standards for allowable emission levels under federal law.
In 2005, in response to complaints from six states attorney general and regional air administration agencies (NESCAUM and WESTAR), EPA began a manufacturer’s voluntary program instead of updating the NSPS to regulate OWBs. The result of this program is Phase II “qualified” OWBs. These devices are not certified, like indoor wood stoves currently regulated by the EPA. The EPA used an unvetted testing method for emission tests to qualify OWB models. EPA then made false claims about the efficiencies and emission testing results of these “qualified” devices and posted this information on its Web site. After much criticism, EPA removed this information from its Web site this year.
Janet McCabe, Principal Deputy Assistant Administrator, Office of Air and Radiation, USEPA, wrote the following explanation about the problem with the data and efficiency claims: “When we realized there was a problem with the efficiency numbers, we also took a close look at the emissions. We are making revisions to the test method and, as much as the law allows, we are going to continue to require the industry to make further reductions in these units.” (personal email, June 9, 2011).
EPA gave credibility to Phase II OWBs through its voluntary program, in spite of knowing that the emissions still exceed federal Clean Air Act National Ambient Air Quality Standards (NAAQS) levels, resulting in health hazards. Because of EPA’s endorsement of these unproven devices, state and local governments and individuals seeking relief from smoke, are often forced to allow Phase II OWBs.
I can tell you from personal experience that Phase II OWBs smoke just as much as the old non-qualified units. Nothing can explain this to you better than photos. Here are two photos of smoke from my neighbor’s new Phase II OWB (Central Boiler E-Classic 2400). It smokes continuously at this 100% opacity level for over two hours straight every morning, and then on and off all day until refueled again in the evening. The smoke fills our valley with haze and toxic air pollutants, which we are forced to breathe.
As you can see from the photos, the Phase II OWB smokes just as much as the non-qualified OWB shown in the first photo. EPA’s OWHH program did not result in clean-burning devices!
Even the OWB manufacturer of the Phase II unit shown above (Central Boiler) includes the following warning in its owner’s manual (2010 E-Classic 2400): “Improper use or failure to maintain the hydronic heater may cause nuisance conditions. The person(s) operating a hydronic heater is/are responsible for operation in a manner that does not create a public or private nuisance condition. Meeting the distance and stack height recommendations from the manufacturer and requirements in applicable State and local regulations may not always be adequate to prevent nuisance conditions in some areas due to terrain or other factors.”
Senate bill 1914 has good intentions and will help people with their home energy needs, while promoting clean energy. It’s important to promote clean, efficient energy from proven and certified devices. However, the bill would create a new tax code section 25E that would allow tax credits for these polluting and hazardous OWBs.
OWBs should not receive a tax credit! Instead, they should be banned in all states, not just the state of Washington. Please don’t allow any more people to suffer and be injured from breathing smoke from these defective devices! Please continue the leadership tradition of NRDC in shaping public policy to promote environmental and public health through NSPS regulations that set emissions standards on all wood-burning devices; especially OWBs!
Photo Courtesy of: Fairbanks Daily News-Miner, 2010
Thank you for your consideration of this request.
Washington State Ban: http://www.ecy.wa.gov/programs/air/outdoor_woodsmoke/Wood_boilers.htm
EPA Wood Heater Regulations:
– NSPS for Residential Wood Heaters: 40 CFR Part 60 Subpart AAA: http://www.epa.gov/compliance/resources/policies/monitoring/caa/woodstoverule.pdf
– EPA NSPS update overview: http://www.epa.gov/burnwise/workshop2011/NSPS-DraftRevisions-Wood.pdf
Attorneys General EPA petition to EPA to regulate OWBs: http://www.vtwoodsmoke.org/pdf/NYS-EPA8-05.pdf