2010 April 22: NY State: COMMENT PERIOD NOW OPEN on Proposed Part 247, Outdoor Wood Boilers, and Part 200, General Provisions
The Department is proposing to adopt new Part 247, Outdoor Wood Boilers and revise Part 200, General Provisions, to conform to the new rule. Emission limits and siting requirements will be established for new outdoor wood boilers (OWBs) along with stack height and operating requirements for both new and existing OWBs. Further, the Department is proposing to phase out existing OWBs by August 31, 2020. A new OWB is a unit that commences operation on or after April 15, 2011 and, conversely, an existing OWB is a unit that commenced operation prior to April 15, 2011.
- Express Terms Summary
- Express Terms Part 247, Outdoor Wood Boilers
- Express Terms Part 200, General Provisions
- Regulatory Impact Statement Summary
- Regulatory Impact Statement
- Job Impact Statement
- Rural Area Flexibility Analysis
- Regulatory Flexibility Analysis for Small Businesses and Local Governments
Written comments are accepted through 5pm, July 2, 2010 and should be directed to:
John Barnes, P.E.
New York State Department of Environmental Conservation
Division of Air Resources
625 Broadway, 2nd Floor
Albany, New York 12233-3251
Telephone (518) 402-8396
To: John Barnes, P,E. New York State Department of Environmental Conservation
Re: Proposed Part 247, Outdoor Wood Boilers, and Part 200, General Provisions
Comment: Ten Reasons I support New York State’s Rule on Outdoor Wood Boilers (Part 247, Outdoor Wood Boilers, and Part 200, General Provisions)
1. Don’t burn wood, period. Particulates from wood smoke (Black Carbon, soot) cause lung cancer, heart attacks, asthma and cataracts.
2. Black Carbon is the 2nd leading cause of global warming and stopping it is the quickest way to slow climate change. Burning wood creates the same amount of CO2 and more particulates than coal burning.
3. Health trumps money. Don’t exchange health for heat. Your neighbor’s short-term savings on heat will cost all of us long-term costs for health care. Responsible public servants see this, and health departments certainly do.
4. "Hurting the air" (phrase used an OWB user in a newspaper article, referring to the environment, apparently) is the 2nd reason for regulating or banning Outdoor Wood Boilers. The 1st reason is because wood smoke pollution hurts people’s health. In articles such as this, the lung damage, cardiovascular damage, asthma and cataracts caused by wood smoke is ignored. It is very clever to ignore the primary reason for the rule if you are opposed to it.
5. Cost. In newspaper articles we see quotes from OWB owners who are opposed to regulation because they assert it will cost them money to stop polluting. Adults know that everyone has to pay for heating their homes in the winter, but OWB owners want their neighbors to additionally exchange their health for the OWB owner’s heat. The neighbors of OWB owners also have to pay more for health care when they develop heart and lung problems, asthma and cataracts.
6. A legislator from Harrisvile wants to add pollution from stationary sources like Outdoor Wood Boilers to pollution from cars. Two wrongs don’t make a right. It isn’t logical to say that particulates from automobiles is bad, but particulates from Outdoor Wood Boilers is not bad.
7. The fact that old Outdoor Wood Boilers that don’t meet emission standards will be retired is a good thing. It will give New York residents relief from the pollution they have had to endure so far. It is not right to keep doing something that is known to be polluting and harmful to health and the environment. The Boilers have to be out of use by 2020, which is really not soon enough, but makes the point about the undesirability of the units.
8. Mr. Hathaway is trying to change the subject from measurement of particulates to whether he has anecdotally seen thick black smoke. There are instruments for measuring particulates which do not require him to stand at that location and subjectively verify (or deny what is right before his eyes) the color of the smoke every few minutes. The measurement of particulates tells what is in the air which can harm human cardiovascular systems, pulmonary systems, and eyes. When an OWB owner burns in the dark of night thinking he can get away with it because no one can see it, particulate monitors can detect it. That is a relief to neighbors of OWB owners, because wood smoke can seep into neighbor’s homes even when doors and windows are closed, and residents often wake up in the middle of the night in their homes gasping for breath.
9. BP building top hats and junk shots now is like starting to build a fire truck on the day the house fire has started. We have to look at the consequences of what we do before we do it, and regulate and plan accordingly. If an Outdoor Wood Boiler starts spewing black smoke, and the neighbor is breathing it in, would the legislator then decide that’s when to regulate? That is too little too late. Justice delayed is justice denied.
10. Higher smokestacks and seasonal prohibitions are not enough, and ultimately prohibition are going to happen. Look to the future to the bridge of natural gas for heat and better insulation, and further ahead to the clean energy sources of wind, solar and geothermal. Any other advice to OWB owners would be a temporarily reassuring lie.