Tulikivi Petitions EPA for Reconsideration
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The Honorable Gina McCarthy
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Ave, N.W.
Mail Code: 1101A
Washington, D.C. 20460
Re: EPA Wood Heater NSPS, EPA-HQ-OAR-2009-0734
Dear Administrator McCarthy:
Enclosed please find a Petition for Reconsideration of EPA's Final Rule, Standards of
Performance for New Residential Wood Heaters, New Residential Hydronic Heaters and
Forced-Air Furnaces, 80 Fed. Reg. 13672 (March 16, 2015) EPA Docket No. EPA-HQ-OAR-
2009-0734. Please let me know if you or your staff have any questions.
Sincerely, Wiliam Pedersen /KH
William F. Pedersen
Tulikivi U.S., Inc. is a subsidiary of Tulikivi Corporation, an international company based in Finland. We will refer to them both as Tulikivi. Tulikivi is the world’s largest manufacturer of wood-fired masonry heaters.
On February 3, 2014, the Environmental Protection Agency (“EPA”) proposed to establish new or revised emissions standards for a wide range of new wood heating devices. In particular, EPA proposed to set emissions standards for the first time for masonry heaters. 79 Fed. Reg. 6330 (Feb. 3, 2014).
However, in March 2015, EPA reversed its proposed position and decided not to establish emission standards for masonry heaters. 80 Fed. Reg. 13672 (March 16, 2015).
Tulikivi believes this decision was legally unjustified, and that it will be damaging both to the environment and to the masonry heater industry. Tulikivi has filed a petition for judicial review of this decision.
EPA has acknowledged that by their design, most masonry heaters are inherently low emitting and very generally have lower emissions than the heat sources that would otherwise have been used.
EPA is also aware that many States and local jurisdictions forbid the installation of new wood heaters that do not comply with EPA emission standards.
Yet by failing to establish emission standards for masonry heaters, EPA has left masonry heaters subject to those bans, despite their low emissions.
EPA’s justifications for this failure do not even mention such installation bans, and are unpersuasive even taken on their own terms.
Accordingly, Tulikivi hereby petitions the Administrator to reverse this decision, and announce her intention to promulgate masonry heater emission standards as soon as practicable.
Tulikivi understands that this will take time. To avoid having masonry heaters shut out of the market in the meanwhile, Tulikivi therefore also petitions the Administrator to issue guidance to States and local jurisdictions explaining that since masonry heaters are inherently clean-burning, they should not be subject to installation bans even in areas where wood smoke emissions present an air pollution concern. In appropriate cases, emission reduction credits should be awarded for the use of masonry heaters instead of dirtier older appliances.
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