2010 Feb. 22: RAWSEP Letter to Residents of Indiana on Comment Period for Outdoor Wood Boiler Regulations, deadline Feb. 22, 2010‏

RAWSEP Letter to Residents of Indiana on Comment Period for Outdoor Wood Boiler Regulations, deadline Feb. 22, 2010‏
Sunday January 24, 2010
Letter to Citzens of Pennsylvania from Residents Against Wood Smoke Emission Particulates (RAWSEP)
 
Dear Indiana Citizens,
The Indiana Department of Environmental Management (IDEM) ( http://www.in.gov/idem/5275.htm or FAX comments or model letter to phone 800-451-6027) is reviewing regulations for Outdoor Wood Boilers (OWBs).  IDEM is taking Public Comments on Draft Rule LSA#05-332 Outdoor Wood Fired Boilers/Hydronic Heaters until February 22, 2010.  Speak up now or forever hold your breath!  As a group of residents concerned about the health hazards and climate change effects of wood smoke, we ask you to take this time to contact the IDEM and tell them your story of harmful smoke from wood burning.
A citizen from Laporte Indiana has listed the most important points left out of the current Indiana draft regulations for Outdoor Wood Boilers.  They can be summed up this way: 
 
l.  The requirement for less than 20% opacity of smoke doesn’t go far enough.  Opacity can be measured only in daylight.  Much wood burning takes place in the middle of the night, or on cloudy days where opacity measurement is compromised.
 
2.  Stack height of 5 feet or higher than neighbor’s roof top within 150 feet of the stack, does not go far enough.  Stack height is almost irrelevant during a temperature inversion when smoke that comes out at a certain height is then plunged to the ground.  Smoke comes down.
 
3.  Cannot operate May to September, does not go far enough.  Smoke enters homes even through closed windows and doors.  People spend more time indoors and travel less away from their homes in winter.  Being trapped in a house that smoke is entering on a continous basis during the winter is not a viable option.
 
4.  Citizens’ health is affected by these units operating 24/7.  Nuisance and the rights of neighbors are affected by these units 24/7.  The U.S. EPA states “No person shall cause or allow emissions of air contaminants to the outdoor atmosphere of such quantity, characteristic or duration that are injurious to human, plant or animal life or to property, or that unreasonably interfere with the comfortable enjoyment of life or property.”
 
5.  These guidelines should be followed:
 
5.A.  Outdoor wood boilers should never be installed ina minor or major subdivision unless they meet U.S. EPA certified wood stove and fireplace particulate emissions limit of 7.5 grams per hour, or 4 grams which is expected in most new regulations.  U.S. EPA standards for stoves will be stricter this year.  Don’t forget to contact the EPA on the New Source Performance Standards for wood stoves they are now working on, and soliciting public comment for.
 
5.B.  Outdoor Wood Boiler set back distance from a neighbor should be at least 500 feet.
 
5.C.  Property values are affected by Outdoor Wood Boilers installed in neighborhoods.  Would you live next to one?  Geothermal heating is an example of heating that no one would have a problem living next to.
 
The following is what RAWSEP believes:

You are about to have a new regulation in the State of Indiana that is going to provide each of you new protections against harmful smoke which by many scientific studies is proven to cause heart and lung damage.
1. Although wood is a fuel that has been used since the beginning of recorded history, emission of particulates from wood burning is a hazard to health.  Wood burning contributed to shortened lifespans of earlier generations, and today causes multiple health problems including early death, circulatory problems, heart and lung problems, cataracts, and asthma.
2. Wood burning and wood smoke harm the environment.  Wood smoke is a form of Black Carbon.  Black carbon (soot) is the second leading cause of global warming and stopping particulates is the quickest way to slow climate change.   Black Carbon is on the U.N. list of greenhouse pollutants
, and  is proven by many scientific studies to act as harmfully as many greenhouse gases, surpassed only by CO2.  The U.S. house of Representatives recognizes it as an agent harmful to the environment in the Black Carbon Reduction Act contained in the Climate Bill (ACES) passed in June 2009, and the U.S. Senate recognized the harm it causes by passing the Black Carbon Study Act in September 2009.   Most climatologists agree.  In saying this, we do not dispute that fossil fuels do harm the environment.   Like fossil fuels, wood also adds greenhouse gases to the environment, notably CO2, just as fossil fuels do.  The State of Massachusets has a 2010 ballot question to forbid biomass burning to get a "renewable" label if it generates too much CO2‏.

3. The proposed regulation was prepared using extensive scientific data which has been ignored for too long because of lobbying of outdoor wood boiler sales departments.  The dollar should not be allowed to trump human health.  We will pay many dollars in health care expenses for every dollar we put in the pockets of the outdoor wood boiler industry.
4. This regulation will NOT damage the economy of Indiana by killing jobs.  Those who work for the outdoor wood boiler industry may lose jobs if they do not diversify, but many outdoor wood boiler manufacturers also manufacture natural gas furnaces, which could replace outdoor wood boilers, so the economic cost to the manufacturers who anticipate future use could be breaking  even.  The new green economy of geothermal, solar and wind power for heat is vital to the future economic growth of Indiana.   As mentioned before, supposedly low cost heating for the few should not determine a policy of high health care costs and debilitating illness for their many neighbors.    The cost of natural gas has gone down dramatically in the last year, and reserves ensure the low cost of natural gas as a "bridge" to the future better residential heating energy sources of geothermal, solar and wind.  Natural gas prices will continue to remain low because of vast reserves of natural gas recently discovered in the United States.   In the event electrical power lines are down, electricity can be generated by a natural gas backup generator.
5. The State of Indiana consists of heavily-wooded, rural areas.  These trees are a valuable natural resource when alive, and of much less value when cut.   Trees provide oxygen and naturally cleanse the air.  Tourism is hurt when smoke fouls the air.  It makes no sense to apply clean air regulations ONLY to those in densely populated areas.  Air moves freely and affects everyone, which is why a statewide rule must be written.  The procedure leading to regulation of local outdoor wood boilers in Indiana and across the nation by local municipalities of densely populated areas and rural areas alike has been long and difficult for neighbors whose health has been affected by outdoor wood boilers.    Local outdoor wood boiler owners have sat on boards that determined the outcome of complaints about their own boilers, with resulting conflict of interest, and with resulting inaction or weak laws.  Outdoor wood boiler manufacturer sales representatives have met with local boards to try to shape legislation so that local outdoor wood boiler laws are weak and unhelpful, all in the name of making a profit.  Advertising for outdoor wood boilers is not countered by public service announcements on the health hazards of wood smoke.  Those kinds of public service announcements have been made about cigarette smoking for decades, and outdoor wood boiler wood burning smoke has been unaddressed, to the detriment of public health and peaceful enjoyment of property.

This new regulation is being proposed by the Office of Air Quality of Indiana.   For the sake of ourselves, our friends and our neighbors, let our voices be heard.

 
1. Send a quick email to the Office of Air Quality, and
2. Forward this email to any and all friends who would be interested in this issue and would also like to have their voice heard by sending an email to the Office of Air Quality.

For your email to the Office of Air Quality, please follow these simple steps:

1. Copy the "Sample Letter to Office of Air Quality" below into a new email.
2. Make any changes or additions you wish to make. (Alternatively, you can just write your own letter – we only provide the Sample Letter below to simplify this for you.)
3. Put in the Subject Line the following: "Public Comments on Draft Rule LSA#05-332 Outdoor Wood Fired Boilers/Hydronic Heaters"

4. Make sure to add your name and address so the Office of Air Quality knows you are a IN constituent.
5. Send the email to the following email address: http://www.in.gov/idem/5275.htm

6. If you do not receive an acknowledgement of electronic comments within 2 working days, please resend your email to ensure the Office of Air Quality receives the email.
7. Alternatively, you can mail your comments to the following address:Mailed Comments: #05-332 (APCB) Outdoor Hydronic Heaters
                                    Susan Bem Mail Code 61-50                                   (phone 800-451-6027)
                                    Rule and SIP Development Section
                                    Office of Air Quality
                                    Indian Department of Environment Management
                                    100 North Senate Ave
                                    Indianapolis, IN 46204

http://www.in.gov/idem/5275.htm

8. YOUR EMAIL OR LETTER MUST BE RECEIVED BY FEBRUARY 22, 2010!!

A sample of a letter you could send to the Office of Air Quality is attached below. If you have any questions on this matter, please do not hesitate to contact RAWSEP- you can reach us at rawsep@live.com.  Visit http://woodsmokenuisance.spaces.live.com, http://woodsmokeworld.spaces.live.com ; and http://rawsep.spaces.live.com
And don’t forget to forward this email to your friends!

Thanks, and warm regards,

Residents Against Wood Smoke Emission Particulates (RAWSEP)

—Sample Letter to Board—
Mailed Comments: #05-332 (APCB) Outdoor Hydronic Heaters
                                    Susan Bem Mail Code 61-50                                   (phone 800-451-6027)
                                    Rule and SIP Development Section
                                    Office of Air Quality
                                    Indiana Department of Environment Management
                                    100 North Senate Ave
                                    Indianapolis, IN 46204

TO:

Susan Bem Mail Code 61-50

Rule and SIP Development Section

Office of Air Quality

Indiana Department of Environmental Management

100 North Seante Ave

Indianapolis, IN  46204

FROM:
(your name)
(your address)
(your city, state, zip)

Re: Public Comments on Draft Rule LSA#05-332 Outdoor Wood Fired Boilers/Hydronic Heaters

Dear Office of Air Quality:

l.  The requirement for less than 20% opacity of smoke doesn’t go far enough.  Opacity can only be measured only in daylight.  Much wood burning takes place in the middle of the night, or on cloudy days where opacity measurement is compromised. 

2.  Stack height of 5 feet or higher than neighbor’s roof top within 150 feet of the stack, does not go far enough.  Stack height is almost irrelevant during a temperature inversion when smoke that comes out at a certain height is then plunged to the ground.  Smoke comes down.

3.  Cannot operate May to September, does not go far enough.  Smoke enters homes even through closed windows and doors.  People spend more time indoors and travel less away from their homes in winter.  Being trapped in a house that smoke is entering on a continous basis during the winter is not a viable option.

4.  Citizens’ health is affected by these units operating 24/7.  Nuisance and the rights of neighbors are affected by these units 24/7.  The U.S. EPA states “No person shall cause or allow emissions of air contaminants to the outdoor atmosphere of such quantity, characteristic or duration that are injurious to human, plant or animal life or to property, or that unreasonably interfere with the comfortable enjoyment of life or property.”

5.  These guidelines should be followed as a minium:

5.A.  Outdoor wood boilers should never be installed ina minor or major subdivision unless they meet U.S. EPA certified wood stove and fireplace particulate emissions limit of 7.5 grams per hour, and newer regulations call for 4 grams per hour.  U.S. EPA standards for wood stoves will be stricter this year.  Don’t forget to contact the EPA on the New Source Performance Standards for wood stoves they are now working on, and soliciting public comment for.

5.B.  Outdoor Wood Boiler set back distance from a neighbor should be at least 500 feet.

 5.C.  Property values are affected by Outdoor Wood Boilers installed in neighborhoods.  Would you live next to one?  Geothermal heating is an example of heating that no one would have a problem living next to.

Please proceed with your proposed rulemaking regarding outdoor wood-fired boilers. I believe this is long awaited and would be acceptable for our State of Indiana for the following reasons:
1. Although wood is a fuel that has been used since the beginning of recorded history, emission of particulates from wood burning is a hazard to health.  Wood burning contributed to shortened lifespans of earlier generations, and today causes multiple health problems including early death, circulatory problems, heart and lung problems, cataracts, and asthma.
2. Wood burning and wood smoke harm the environment.  Wood smoke is a form of Black Carbon.  Black carbon (soot) is the second leading cause of global warming and stopping particulates is the quickest way to slow climate change.   Black Carbon is on the U.N. list of greenhouse pollutants
, and is proven by many scientific studies to act as harmfully as many greenhouse gases, surpassed only by CO2.  The U.S. house of Representatives recognizes it as an agent harmful to the environment in the Black Carbon Reduction Act contained in the Climate Bill (ACES) passed in June 2009, and the U.S. Senate recognized the harm it causes by passing the Black Carbon Study Act in September 2009.   Most climatologists agree.  In saying this, we do not dispute that fossil fuels do harm the environment.   Like fossil fuels, wood also adds greenhouse gases to the environment, notably CO2, just as fossil fuels do.  The State of Massachusetts has a 2010 ballot question to forbid biomass burning to get a "renewable" label if it generates too much CO2‏.

3. The proposed regulation was prepared using extensive scientific data which has been ignored for too long because of lobbying of outdoor wood boiler sales departments.  The dollar should not be allowed to trump human health.  We will pay many dollars in health care expenses for every dollar we put in the pockets of the outdoor wood boiler industry.
4. This regulation will NOT damage the economy of Indiana by killing jobs.  Those who work for the outdoor wood boiler industry may lose jobs if they do not diversify, but many outdoor wood boiler manufacturers also manufacture natural gas furnaces, which could replace outdoor wood boilers, so the economic cost to the manufacturers who anticipate future use could be breaking  even.  The new green economy of geothermal, solar and wind power for heat is vital to the future economic growth of Indiana.   As mentioned before, supposedly low cost heating for the few should not determine a policy of high health care costs and debilitating illness for their many neighbors.    The cost of natural gas has gone down dramatically in the last year, and reserves ensure the low cost of natural gas as a "bridge" to the future better residential heating energy sources of geothermal, solar and wind.  Natural gas prices will continue to remain low because of vast reserves of natural gas recently discovered in the United States.  In the event electrical power lines are down, electricity can be generated by a natural gas backup generator.
5. The State consists of heavily-wooded, rural areas.  These trees are a valuable natural resource when alive, and of much less value when cut.   Trees provide oxygen and naturally cleanse the air.  Tourism is hurt when smoke fouls the air.  It makes no sense to apply clean air regulations ONLY to those in densely populated areas.  Air moves freely and affects everyone, which is why a statewide rule must be written.  The procedure leading to regulation of local outdoor wood boilers in Indiana and across the nation by local municipalities of densely populated areas and rural areas alike has been long and difficult for neighbors whose health has been affected by outdoor wood boilers.    Local outdoor wood boiler owners have sat on boards that determined the outcome of complaints about their own boilers, with resulting conflict of interest, and with resulting inaction or weak laws.  Outdoor wood boiler manufacturer sales representatives have met with local boards to try to shape legislation so that local outdoor wood boiler laws are weak and unhelpful, all in the name of making a profit.  Advertising for outdoor wood boilers is not countered by public service announcements on the health hazards of wood smoke.  Those kinds of public service announcements have been made about cigarette smoking for decades, and outdoor wood boiler wood burning smoke has been unaddressed, to the detriment of public health and peaceful enjoyment of property.

Thank you. 

(Your Name) 
 
 
 
FROM THE IDEM WEBSITE
 
In every way "a hot topic," outdoor hydronic heaters (also referred to as outdoor wood boilers or outdoor wood furnaces) are front and center in a current effort to protect the air you breathe. Indiana is proceeding with rulemaking that will regulate the purchase and use of outdoor hydronic heaters, joining other states that have already adopted similar rules.
Emissions from an outdoor hydronic heater can cause air pollution problems when not sited, installed or operated properly. U.S. EPA has not developed national legislation at this time, but is relying upon voluntary measures and state and local regulation to control emissions from outdoor hydronic heaters.
This Web site offers information on hydronic heaters in an effort to inform you of the issues surrounding them and on Indiana’s rulemaking efforts on the subject.

Table of Contents

Outdoor Hydronic Heaters: General Information and Fact Sheets

Outdoor hydronic heaters are known by many other names like outdoor wood boilers, outdoor wood furnaces, wood heaters and water stoves. In general they are used to heat homes or businesses but they have also been used to heat swimming pools and hot tubs. Indoor wood stoves and fireplaces are not considered outdoor hydronic heaters.

Indiana Rulemaking

IDEM has started rulemaking to regulate outdoor hydronic heaters. The draft rule language includes stack height requirements for existing units and emission standards for units installed after the rule is effective, plus additional operational and fuel restrictions.

      • Second Notice of Comment Period:
        • The second notice of comment period has been published in the Indiana Register and is now available on the Indiana Register Web site. The LSA number for this rulemaking is #05-332. The deadline for submitting comments on the second notice is February 22, 2010. The notice includes information for submitting comments by fax, mail, or hand delivery.

          Summary of Proposed Requirements

          • Applies to units designed for a thermal output of less than 350,000 Btu/hr.
          • Newly installed units must be certified to meet ‘phase 2’ emission limit – certification of model line is through U.S. EPA’s Voluntary Partnership Program.
          • Existing units may not be operated outside the normal winter heating season unless they have been certified to meet the emission limit.
          • Existing units that do not meet emission limit must have a permanent stack extending 5 feet higher than the peak of any roof structure located within 150 feet of the unit and not located on the property on which the boiler is installed.
          • All units must meet a twenty (20%) opacity limit and follow fuel use restrictions.
          • Sellers of outdoor hydronic units must provide notice to buyers of operating restrictions and notify IDEM of transaction.

          U.S. EPA List of Cleaner Outdoor Hydronic Heaters

          U.S. Environmental Protection Agency (U.S. EPA) maintains a list of certified models of outdoor hydronic heaters that meet the phase 2 emission standards proposed in the draft rulemaking.

          NESCAUM Model Rule

          IDEM has considered what other states have done and are doing about outdoor hydronic heaters. This research included study of a model rule authored by Northeast States for Coordinated Air Use Management (NESCAUM).
          NESCAUM is a 501(c)(3) nonprofit association of air quality agencies in the Northeast. Their Board of Directors consists of the air directors of the six New England states (Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont), New Jersey, and New York. Their purpose is to provide scientific, technical, analytical, and policy support to the air quality and climate programs of the eight Northeast states.
          NESCAUM formed a workgroup to address a variety of issues concerning the unregulated emissions from outdoor hydronic heaters. With funding and participation by the U.S. EPA, the workgroup developed a model rule to promote common regulatory standards across state and local areas. The model rule is based on meeting existing federal air quality health standards set by the U.S. EPA.
          A major aim of the rule is to meet current federal air quality standards for particulate matter (PM) that are based on PM’s extensively documented adverse health impacts to the heart and lungs. In order to achieve this goal, the model rule establishes emission limits and labeling requirements for new outdoor hydronic heaters and contains the following components for both new and existing outdoor hydronic heaters:

          • setback requirements from property lines, structures, and homes;
          • stack height requirements; and,
          • distributor and buyer notification requirements.

          To view the model rule and for other related information, visit NESCAUM’s Web site.

          What Do Other States Have to Say About Hydronic Heaters?

          Many states do not have specific information related to outdoor hydronic heaters on their Web sites. The following states have information about outdoor hydronic heaters, including regulations:

           
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