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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, purporting to respond to retailer needs in the wake of the COVID-19 pandemic. The proposed delay would allow retailers to sell non-compliant wood heaters for an additional six months past  the original 2020 compliance date. 

Our comments detail how how the proposal contradicts the Clean Air Act’s mandate and longstanding agency guidance. The proposed rule will, even under the agencies’ own analysis, cause net harms to the public without providing any reasonable justification. As a result, the rule fails to provide a reasoned explanation for the rule.