Comments to EPA on Delay of Emissions Rule for Wood Heaters
The Environmental Protection Agency (EPA) is proposing to amend the 2015 New Source Performance Standards (NSPS) for residential wood heating devices. This change would allow retailers to sell non-compliant wood heaters for two years past the original 2020 compliance date. We submitted comments explaining that the proposed rule imposes net costs on society and is not justified by EPA’s faulty analysis.
EPA’s assessment of the health effects of the two-year emissions compliance delay is flawed in several ways and significantly underestimates the societal benefits that would be forgone by amending the 2015 NSPS. For example, the agency departs from how forgone emissions are typically calculated, and presents only a truncated three-year analysis of the emissions effects of the rule rather than tabulating its effects over the 20-year lifespan of wood heating devices. Even under EPA’s problematic analysis, the agency concedes that the proposed rule will generate more societal costs than benefits. Delaying 2020 compliance forgoes significant reductions of fine particulate matter emissions, which the agency estimates will impose human health costs ranging from $250 million to $860 million in the first three years alone. EPA does not adequately justify the delay, and the proposed rule should not be finalized.