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Wednesday, June 24, 2009

Comments

Samuel Walbert

This information is both misleading and factually inaccurate. If an emissions limit of 0.32 lbs/million Btu heat output is established you will not see emissions as high as 71 g/hr. In fact, 6 of 7 EPA HH Phase 2 Qualified appliances that meet the 0.32 lbs/million Btu of heat output emissions limit produce 1.6 to 6.4 g/hr with only one appliance emitting above the 7.5 g/hr emission limit for EPA Certified Phase II non-catalytic wood stoves. Since the EPA HH Phase 2 Program was just introduced in October 2008, you will see an industry producing cleaner and cleaner appliances as time progresses.

Built into the EPA HH Phase 2 Program is a g/hr cap on emissions at 18 g/hr. Why? Because EPA Certified woodstoves are allowed the same g/hr cap of 18 g/hr, not 15 as you suggest.

EPA Certified Phase II woodstoves (non-catalytic) appliances have to meet a 7.5 g/hr requirement. Catalytic appliances have to meet the 4.1 g/hr requirement.

EPA does not support taking away people’s existing woodstoves. That is why literally millions of “conventional” woodstoves are still in operation in people’s homes today even though they have been regulated for 20 years. EPA does not support taking away people’s appliances.

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