NACAA Comments on Wood Heating Device NPRM

January 14, 2019 - NACAA submitted comments to EPA on the agency's November 30, 2018 Notice of Proposed Rulemaking (NPRM) on Standards of Performance for New Residential Wood Heaters, New Residential Hydronic Heaters (HH) and Forced-Air Furnaces (FAF).  In the NPRM, EPA proposes to amend the 2015 New Source Performance Standards (NSPS) rule to provide a two-year "sell-through" period, until May 15, 2022, during which retailers may continue to sell Step 1-compliant new residential HHs and FAFs manufactured or imported before the May 15, 2020 Step 2 compliance date.  Further, EPA seeks comment on whether to amend the 2015 NSPS rule to also provide a sell-through period for the sale of Step 1-compliant wood heaters after the May 15, 2020 Step 2 compliance date.  In its comments, NACAA opposes any changes to the current NSPS, adopted in March 2015, to allow for any sell-through and, instead, supports full compliance with the Step 2 NSPS by all new residential HHs, FAFs and wood heating devices, with no exceptions, by May 15, 2020.  In the NPRM, EPA also seeks comment on whether the current minimum quality pellet fuel requirements should be retained and, if so, whether they should be revised.  NACAA recommends in its comments that minimum quality pellet fuel requirements be retained but wth revisions.