2010 Feb. 19: IN: RAWSEP Letter to the State of Indiana Concerning Outdoor Wood Furnaces

February 19, 2010
Letter to the State of Indiana Concerning Outdoor Wood Furnaces

#05-332 (APCB) Outdoor Hydronic Heaters
Susan Bem Mail Code 61-50
Rule and SIP Development Section
Office of Air Quality
Indiana Department of Environmental Management
100 North Senate Avenue
Indianapolis, Indiana 46204
(Also sent via FAX: (317) 233-5967)
Re: Proposed Rulemaking [326 IAC 4-3] Outdoor Wood-Fired Boilers

Dear IDEM:

The following comments are being provided in response to Proposed Rulemaking on Outdoor Hydronic Heaters (“OHH”) 326 IAC 4-3.

In summary, we strongly urge the board to adopt the proposed rulemaking (“Proposal” or “Regulation”) for the following reasons:

1. The Proposal was prepared using scientific data.

2. The Proposal will improve the economy of the State of Indiana by preserving tourism industry jobs, decreasing health care needed by sickened residents, and by steering residents including businesses and homeowners toward cleaner, domestically produced and low price natural gas and the clean technologies of wind, solar and geothermal.

3. The Proposal will reduce the exposure of the board and the State to a potentially enormous legal liability associated with deaths and injuries resulting from outdoor wood boiler shed fires and asociated house fires, as well as the legal liability for harm to neighbors from soot, smoke and fire.

4. The Proposal will not increase the emissions of greenhouse gasses, since Outdoor Wood Boilers emit CO2 and particulates.

5. The State consists of rural areas and non-rural areas, where outdoor wood-fired boilers (OHHs) impact anyone, even those driving through the area when smoke obscures the roadways. Broad regulation of OHHs throughout the entire State would be not be burdensome to citizens of the State. Any regulation should be established at all municipal levels in densely populated areas and rural areas alike.

This Proposal Was Prepared Using Scientific Data.  Result of this Regulation? INDIANA CITIZENS WILL NOT BE BURDENED WITH ADDITIONAL COSTS FOR THESE CLEANER UNITS AND THEY WILL BE ABLE TO AFFORD THEM, and certainly be able to afford a natural gas furnace. Natural gas costs are now lower than biomass (wood) cost. Our State consists of heavily-wooded, rural areas and metropolitan areas. It makes sense that these rules apply equally to all citizens of our entire State when protecting the air that we all breathe.

2. Cost of Chimney Stack ExtensionsL The proposed rulemaking convinces a reasonable person that the cost of becoming compliant with their new stack height requirements would be minimal.  Result of this Regulation? This minimal cost of compliance with the ordinance, and its positive impact will result in better communities throughout Indiana.  If citizens to ignore the Regulation, shut off their OHHs and use natural gas furnaces as a bridge to the better future use of solar, wind or geothermal sources of heat, Indiana will benefit.
3. NESCAUM makes statements of fact regarding OHHs which are completely accurate.  The photo shown on the cover of the NESCAUM report shows wood smoke coming out of an OHH in a manner that has been documented thousands of times (search the internet, or look at an Outdoor Wood Boiler in use). 
The reasonable person knows of no EPA data which shows that the rate of particulate emissions from OHHs is similar to the rate of emissions from certified woodstoves.  Low stack heights for OHHs is correct.  The fact that OHHs are not designed to achieve secondary combustion is correct.  An OHH with proper stack heights do not comply with national ambient air quality standards.

4.  The Proposal Will Benefit the Economy of the State of Indiana.  Natural Gas Furnaces Save Money for Businesses and Homeowners.  Indigent homeowners can receive government subsidies such as food stamps and energy subsidies.  Indiana residents can stay warm in their homes by budgeting, insulating, using the heating alternatives that are thousands of dollars cheaper than Outdoor Wood Boilers of natural gas furnaces, or solar, geothermal or wind power.  By passing this law, Indiana should be looking for ways to provide its citizens a to stay safe from air pollution because a neighbor’s particulate emissions invade their neighbor’s homes even when windows and doors are closed.

5. Burning Wood Harms the Indiana economy by raising health care costs and causing health problems for citizens.  The harvesting and burning of wood depletes an important natural resource, forests in Indiana. Natural gas is produced domestically and its use as a bridge to the cleaner residential energy sources reduces our dependence on foreign energy companies and it supports our local economy. There is a million dollar Outdoor Wood Boiler industry that will have to diversify to natural gas furnaces, to the benefit of Indiana residents.
The proposed rulemaking indicates that this action is being taken because of only 41 past complaints through 2009 which is only a drop in the bucket of residents harmed.  Clearly Outdoor Wood Boilers put many residents’ health in jeopardy, and harm the environment.  Those 41 "canaries in a coal mine" show what unregulated wood burning would do the environment if left unchecked at the whim of greedy market forces.  Wood smoke is a form of Black Carbon.  Black Carbon is the second leading cause of global warming, and stopping Black Carbon is the quickest way to slow Climate Change.

6. Legal Liability: Given the health costs and environmental costs of Outdoor Wood Boilers on citizens of our State, this regulation is long-overdue.  Outdoor wood boilers take combustion outdoors and move it closer to their neighbors. Out of sight is not out of mind unless one does not care about his neighbors, and inhalation of wood smoke is not without consequences.

7. Wood burning is not green. Wood is not renewed if a tree is not immediately planted for every tree harvested.  Wood has been used as a fuel since the beginning of recorded history, and the short lifespans of earlier generations attest to its use.  Fossil fuels have been used for heating since the early 1900s in an attempt to escape the early death from particulates emissions.  We should be planning for using new ideas and new, clean technologies to avoid the primitive mistakes of using wood burning and fossil fuel burning for energy in the past.  Wood is a highly imperfect fuel.  When a tree is cut down, the material obtained no longer can manufacture oxygen or naturally cleanse the air as a living tree does.

8. Fossil Fuels Produce CO2 and Particulates, just as Wood Does.  Unlike claims of some Outdoor Wood Manufacturers wood burning is far from completely safe in terms of Greenhouse Gases.

9. Common Sense: Natural gas is a reliable fuel as a bridge to the cleaner energy sources of solar, wind and geothermal.  In the midst of a winter storm when the power goes out through downed lines in an ice storm, homeowners can use a natural gas generator.  As the grid improves few will be far soon from natural gas pipelines.  If homeowners invested in solar, wind or geothermal instead of an expensive Outdoor Wood Boiler they would have the entirely reliable sources of sun, wind and geothermal, not subject to power outages. 


Residents Against Wood Smoke Emission Particualtes (RAWSEP)

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