Did anyone else receive this?

[trumpeterb]

Did any other Pennsylvania resident receive information from Hawkin Energy regarding legislation in the state regarding OWB's? Apparently, they want to regulate these across the state, and only allow EPA approved units to be sold. Current owners would have to add additional height to their stacks. If this is true, it concerns me...if they can regulate these furnaces, how much longer before they regulate my gasification boiler or someones wood burning stove inside their homes? Here is the exact email I recieved...give me your thoughts.

Andy

PENNSYLVANIA PROPOSED RULEMAKING ON OUTDOOR WOOD-FIRED BOILERS

December 29, 2009

Dear Pennsylvania Citizens,

You are about to have a new regulation in the Commonwealth of Pennsylvania that is going to cost each of you a large sum of money - at least $800 each immediately, and then several thousands of dollars each year in the future. Will you be able to vote on this? NO.

Will you be able to even vote an elected representative out of office for passing this new regulation? NO.

This new regulation is being proposed by the Environmental Quality Board of Pennsylvania. And we cannot do anything to stop them, except let our voices be heard. More on that later.

This "Board" has decided to attempt to regulate how citizens of PA use wood as a fuel. If you currently use wood to heat your home with an outdoor wood furnace, the Board wants to regulate you. We find this mystifying because of the following reasons:

1. Wood is a renewable fuel that has been safely used since the beginning of recorded history.
2. Wood does not harm the environment. Fossil fuels DO harm the environment. Wood does not add greenhouse gasses to the environment - Fossil fuels DO.
3. The proposed regulation was prepared using grossly flawed data.
4. This regulation will damage the economy of Pennsylvania by killing jobs, and by increasing the heating cost of many homeowners by over 400 percent.
5. The Commonwealth consists primarily of heavily-wooded, rural areas. It makes no sense to burden the citizens of our entire Commonwealth with a rule that really only applies to densely populated areas that constitute a tiny portion of the Commonwealth.

Here is what the proposed regulation will require:

1. If you do not yet have an outdoor wood furnace but want to purchase one, you will have to purchase one of the "EPA Approved" furnaces that were developed for use in densely populated cities - even if you live in the country or on a 100-acre farm!

2. These "EPA Approved" furnaces cost approximately 400 percent more per BTU of output than traditional outdoor wood furnaces. Because of this high cost, very few people are purchasing these "EPA Approved" furnaces - one company that sold them has even gone bankrupt.

3. If you currently own an outdoor furnace, but it gets old and needs to be replaced, you will be required to pay 400 percent more for the higher cost, "EPA Approved" furnace.

4. If you currently own a furnace, you will automatically and retroactively be forced to spend roughly $800 to install a chimney stack extension that extends your furnace chimney to a height 10 feet above the ground. If another home is within 500 feet of your furnace, the regulation retroactively requires you to extend your chimney even higher.


I have prepared a 9-page letter to the Board to outline for them why such regulation is a bad idea. I have attached this letter to my company blog for you to read if you are interested. The link to the letter is as follows: http://blog.hawkenenergy.com/2009/12/letter-to-environmental-quality-board.html.

The bottom line is that we believe that any needed regulation should be left to local municipalities. Accordingly, we recommend that the Board NOT adopt the proposed, or any regulation of OWBs. Such regulations can be easily managed by local municipalities of densely populated areas.

But I doubt they will listen to just me. Here is where we need to work together. If you agree that PA citizens should have the freedom to choose to burn wood, you can help to preserve our freedom by doing two simple things:

1. Send a quick email to the Board, 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 Board.

For your email to the Board, please follow these simple steps:

1. Copy the "Sample Letter to Board" below into a new email.
2. Make any changes or additions you wish to make. (Alternatively, you can just write your own letter - I only provide the Sample Letter below to simplify this for you.)
3. Put in the Subject Line the following: "Comments on Proposed Rulemaking - Outdoor Wood-Fired Boilers".
4. Make sure to add your name and address so the Board knows you are a PA constituent.
5. Send the email to the following email address: [email protected]
6. If you do not receive an acknowledgement of electronic comments within 2 working days, please resend your email to ensure the Board receives the email.
7. Alternatively, you can mail your comments to the following address: Environmental Quality Board, PO Box 8477, Harrisburg, PA 17105-8477.
8. YOUR EMAIL OR LETTER MUST BE RECEIVED BY JANUARY 4, 2010!!
9. The Board will not accept faxed letters. Send it by email or mail only.

A sample of a letter you could send to the board is attached below. If you have any questions on this matter, please do not hesitate to contact me - you can reach me at [email protected].

And don't forget to forward this email to your friends!

Thanks, and warm regards,

Warren W. Walborn
President & CEO

 

[trumpeterb]

Here is the sample letter if anyone is interested.



<<Sample Letter to Board

TO:
Environmental Quality Board
PO Box 8477
Harrisburg, PA 17105-8477

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

Re: Proposed Rulemaking [25 PA. Code CHS. 121 and 123] Outdoor Wood-Fired Boilers

Dear Board:

Please do NOT proceed with your proposed rulemaking regarding outdoor wood-fired boilers. I believe this would be unacceptable for our Commonwealth for the following reasons:

1. Wood is a renewable fuel that has been safely used since the beginning of recorded history.
2. Wood does not harm the environment. Fossil fuels DO harm the environment. Wood does not add greenhouse gasses to the environment - Fossil fuels DO.
3. The proposed regulation was prepared using grossly flawed data.
4. This regulation will damage the economy of Pennsylvania by killing jobs, and by increasing the heating cost of many homeowners by over 400 percent.
5. The Commonwealth consists primarily of heavily-wooded, rural areas. It makes no sense to burden the citizens of our entire Commonwealth with a rule that really only applies to densely populated areas that constitute a tiny portion of the Commonwealth. We believe that any needed regulation should be left to local municipalities. Accordingly, we recommend that the Board NOT adopt the proposed, or any regulation of OWBs. Such regulations can be easily managed by local municipalities of densely populated areas.

Thank you.




<<end of sample letter

 

[deerhntr]

A quick search of the Pennsylvania DEP web site yields the proposals open for comment,
Pennsylvania DEP Proposals.

The third open for comment proposal is the one you refer to for OWBs, OWB proposal. I read the proposal over quickly, and it seems to say most of what was stated in the mail you received. The biggest concern for me would be the retroactive portion on stack height. The phase 2 EPA requirement is being adopted by many states and municipalities already, so this is no surprise. It is very easy to prove the argument that a more efficient OWB will pay for itself in reduced wood fuel cost very quickly, so the 400% cost quoted by "Hawk energy" is more for shock value than anything. They go on to say it cost 400% more per BTU for an efficient OWB, which could not be further from the truth. We all are aware of the inefficiencies of the standard OWB that smolders instead of burns. At best, they are a 30% efficient BTU converter. By just moving to a phase 2 OWB, the gain in efficient BTU conversion of the wood fuel will far outweigh the upfront cost for the boiler. The major cost of any boiler, is the operating cost of fuel, and if you burn less, it costs less. So, my personal opinion is, Hawk Energy isn't helping our cause by not providing all the facts. Phase 2 is not such a bad thing.

I do feel that more regulation from BIG BROTHER is not a good thing, so I will send in a email during this public comment period.

Thanks for the heads up!

 

[Chris Hoskin]

this kind of thing is becoming pretty common at this point. Strict limitations and even outright bans on OWB have been around for a while now at the municipal level and becoming more common at the state level. The EPA has regulated woodstove emissions since 1990 and will be regulating ALL biomass burning appliances by 2012 with the development of new (long overdue) federal standards.

 

[deerhntr]

Agreed!

I see no real problem, as long as efficient biomass boilers are allowed, and we all don't get "Painted with the same Brush".

 

[StackedLumber]

so my question is would an "indoor" boiler that is placed outside in an insulated shed be considered an outdoor boiler?

 

[pybyr]

Agreed!

I see no real problem, as long as efficient biomass boilers are allowed, and we all don't get "Painted with the same Brush".

Therein lies the concern- if existing boilers are "grandparented" and standards are ramped up to allow efficient low-emission devices, that'll be one thing - but viligance and active involvement will be needed, as the broad brush is never far away in politics, and you never know what final form legislation will take until it is actually enacted and signed into law.

 

[Chris S]

I have seen regulations in my area that consider lump any boiler not in the building being heated with OWBs. I think an argument could be made for a gassifier by installing some sort of heat in the building where the boiler is, then...

 

[pybyr]

I know that some will differ on this-- from the standpoint of wanting no regulation for as long as possible-- but I think that for those folks in areas where the regulation is increasing (and that's going to be more and more places as time goes on), some pro-active effort to put forward a standardized definition of lower-emissions units to be exempted may be a way to avoid the broad brush.

Legislators and their drafting staff are rarely technically oriented people, so if they hear outcry about smog from wood boilers, they're not aware that there's such a wide range- and different characteristics among- wood-burning hydronic heating units. Education-- and an effort to get some legislators to take a "pro-efficient renewables" position may make a big difference.

 

[91220da]

One of the deciding factors in my purchase of a Greenwood 100 was the fact that in all of Greenwoods, brochures, literature, manuals etc. it is called an indoor hydronic furnace. INDOOR. I did place it in my garage and according to my municipality, if a whole house heating source is placed in an outbuilding that is inhabited by livestock or domestic animals than it would not be considered an outdoor appliance. I simply placed an additional dog bed in the corner of the garage. If and when the inspector ever shows up the bed is for my chocolate lab who lives in the garage. Yeh...... that's it, he lives in the garage.

 

[lexybird]

looks like ~change ~ you can believe in