Melding of the minds between industry and air agencies on NSPS

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John Ackerly

Burning Hunk
While many of us thought industry and air agencies were at a stand-off, they were secretly meeting and agreeing on lots of important things. HPBA, NESCAUM and WESTAR agreed that cord wood testing should be delayed, that qualified boilers should have a healthy sell-through, along with stoves - and maybe most surprising - that all compliant stoves and boilers would not have to re-certify for next 5 years. Some of biggest issues are still totally unresolved but we think its a real step forward and support the recommendations.

The EPA is not bound by any of this, but will probably adopt most of it and it shows the spirit of common sense, practicality and compromise are alive and well. Check out the details:
http://forgreenheat.blogspot.com/2014/09/private-talks-yield-consensus-on-key.html

Would be interested to hear what folks think.
 
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I'm glad they are making progress. Kudos to all parties for coming to the table and working on compromises. I hope these talks will continue and make progress on some of the stickier issues.
 
secretly meeting haha. interesting way to put it. seems like standard sharing of info to me. great to hear though.
 
Stove manufacturer's reading that they are represented by HPBA have to be crapping a brick. They have been moving away from HPBA participation in droves for a long time.

Now if it was standards for emissions from The Big Green Egg...
 
I find it interesting that this had to be done behind closed doors. Maybe an attempt to keep out special interests?? Dunno.
 
Stove manufacturer's reading that they are represented by HPBA have to be crapping a brick. They have been moving away from HPBA participation in droves for a long time.

Now if it was standards for emissions from The Big Green Egg...

If only the stove manufacturers had a lobby group or representation of their own that could better speak for them.
 
I would like to add my two cents here. First, no trade association is perfect and the challenges faced by having so many interests is difficult to say the least.

Over the past 4 1/2 years, there have been dozens of industry meetings organized by HPBA for all manufacturers to attend. Many companies participated at these meetings, many did not. But they were open to all manufacturer members. Candidly, if you are a manufacturer and you had a chair waiting for you and you did not attend or you did not send someone in your stead, that was a decision not made by HPBA. I personally attended 99% of these meetings for the express purpose of making certain our interests and concerns were being voiced. For each of these meetings, there has also been a dial-in number for those unable to attend, so that they might be able to still participate. Due to the cost of travel, this would benefit smaller companies or those with scheduling conflicts.

Just over a year ago, HPBA brought fourth a new format for membership challenges. There are now multiple sections, made up entirely of manufacturers for specific product categories. If you make wood stoves, you belong to a section for that product category and only others with the same interests are in that section. This format seems to be a vast improvement in that it permits every single member manufacturer to voice their opinions or concerns and if necessary make their case if there exists differences in opinion. The opportunity is there for all to attend, no member is being excluded.

I don't think manufacturers are fleeing in "droves". I know for degree of certainty the number one reason folks leave HPBA is the cost of attending the annual EXPO. I have made some great friendships over the past 18 years and I speak with these friends whether they are members or not. They have stated with the costs of the annual exposition so high, they see no other reason to maintain a membership.

That is quite short sighted in my opinion. For example, the meeting that was recently held, the one Johnis referring to in the blog, was only "top secret" to the public. Any manufacturer that claims they were unaware of the meeting chose not to be involved in the planning stages prior to the meeting date or attend industry meetings. It was as simple as dialing a phone number.
 
John,

I'm interested to know on what basis you say that the EPA will probably adopt most of the common ground. The 5 year blanket extension could be a huge benefit to the small guys like KUMA.

Thanks,
Jason
 
One point is that with the total population of manufacturers, ex HHT and Travis, a "drove" consists of one or two manufactures. I know of no industry where "we hang together or we surely hang separately" applies more.

And not actively participating just lets HHT and Travis rule your roost.
 
John,

I'm interested to know on what basis you say that the EPA will probably adopt most of the common ground. The 5 year blanket extension could be a huge benefit to the small guys like KUMA.

Thanks,
Jason

Jason - Its must my opinion, based on some input from others. Here is what a NSPS lawyer who is tracking this rule said: "the risk of litigation on these points will decline significantly. To the extent that grandfathering and sell-through issues are resolved favorably for manufacturers, however, the rule will be more manageable and so with the right adjustment of timing for compliance, risk of litigation from industry may further decrease." I think EPA lawyers and leadership will want to do these that might make the rule go more smoothly and reduce the number of really tough, contentious issues that they have to decide. They may have already been leaning in this direction anyway. However, they may feel they have more cover to be tough on emission standards if they are a bit lenient on sell-through, grandfathering and certification extensions. I just wish if they do decide to adopt the recommendations, that they could tell everyone sooner rather than later. Even if Gil, David Cole and Greg Green want to adopt the recommendations, they could be overruled by higher ups in Washington who want to be tougher. I think the fact that these three groups sat down really created some good will at EPA that did not exist before, so I think they will be more disposed to adopting them. The one recommendation I thought EPA may shy away from is setting up a working group to establish a cord wood fueling protocol under FACA. But then I heard EPA liked that idea because many states feel strongly that the ASTM committee was problematic because its commercial. Anyway, that is my 2 cents.
 
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