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