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October 25, 2014
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EPA NSPS Draft Proposal
EPA Regulations - Questions and Answers

FYI...
As you may be aware – On January 3, 2014 the Environmental Protection Agency (EPA) issued proposed emission standards for new residential wood heaters, including wood stoves, pellet stoves, hydronic heaters, and forced air furnaces.

All YUKON products fall under the forced air furnaces category of this proposed standard, in which have never been under review by the EPA. Since the EPA published the NSPS in 1988, forced air furnaces have been exempt from the Title 40 Rule of the standard. 
 

Here are some Questions and Answers that may help in your decision to purchase a multi-fuel or add-on wood furnace for your home before the EPA’s Final Rule comes into effect. The anticipated final ruling is in February of 2015.  

Q: To what products does this rule apply?

A: The new rule would, of course, amend the current New Source Performance Standard for residential wood heaters and for the first time would include standards for new residential forced air furnaces, hydronic heaters and masonry heaters that are designed to burn wood.

Q: Is this rule in effect now?

A: No – there was a 90 day comment period that ended May 5, 2014. The comments that were submitted may challenge the EPA to modify this proposal as a result. EPA must issue a final rule by February 3, 2015. The final rule may be changed from the proposed rule and the EPA must explain the reasons for any major changes. Plus the EPA, upon promulgation of the final rule, must provide a response to all significant comments and criticisms that were submitted during the public comment period.

Q: Would the proposed rule affect existing forced air furnaces that burn wood that are already purchased or in use?

A: No. The proposed rule would only apply to new wood stoves, forced air furnaces, hydronic heaters, pellet stoves and masonry heaters that are sold after the final rule’s effective date. However, the proposal does not extend the effective date for a transition period or provide for a “sell through” period of these products. Therefore, the effective date for the newly added forced air furnaces could potentially be as soon as 60 days after February 3, 2015 upon promulgation of the final rule.

Q: Who is affected by this proposed rule?

A:
1. All manufacturers of wood burning stoves and other wood heaters, including indoor forced air furnaces, indoor and outdoor hydronic heaters, pellet stoves, single burn rate heaters and masonry heaters.
2. Distributors and retailers.
3. You - The owners and operators
               
      3.1    Specifically, the proposed rule sets requirements for the type of fuel that may be used in forced air furnaces and hydronic heaters, and it would be against federal law to operate the equipment in a manner inconsistent with operating instructions in the owner’s manual, such as burning treated wood, cardboard, solvents, trash and garbage.

Q: What is the industry reaction to the proposed rule?

A: The EPA has proposed to implement a two-step compliance rule. There is general consensus that step one will be attainable on all or at least most all affected product types. However, the step two rule – out five years – will not be attainable by most product types. EPA assumes that the technology that is used in wood stoves and hydronic heaters can be transferred to the forced air furnaces and it is that simple. However, since the newly added products have never been under review and are not already tested for emissions, it now becomes a guessing game as to whether they will be able to comply. There are only a few EPA certified laboratories that have limited experience with the proposed test method using the CSA B415.1-10 standard.

Q: Will Alpha American Company continue to offer the YUKON furnace products after the emissions rule comes into effect?

A: All YUKON furnace products are either UL or c-UL Listed and have been rigorously tested by Underwriter’s Laboratories to meet the stringent consumer safety standards that both the U.S. and Canada have in place for safe operation of household appliances. In modifying either raw materials in the construction or by adding controls and/or technology to our products in order to comply with the new emission standard proposed by the EPA, the furnaces, in turn, will be subject to review by UL for testing of the units with the new build or controlling methods to ensure that any modifications will also meet the requirements of the UL Safety Standard(s) that the furnaces are tested to.

As a result of this daunting task of meeting both the U.S. and Canadian Safety Standards and this new Proposed Rule for emission by the EPA, that will be Federal Regulation, we are currently conducting in house R&D. Our strategy is to ensure that any changes made to comply with the EPA standard for emission will also comply with our UL Procedure that is the protocol in manufacturing.

After the R&D stage is completed and we have conferred with the engineers at UL, we will begin testing on the emissions of the individual units. The contents of the EPA draft proposal does not address multi-fuel furnaces that are designed to light the wood with the gas or oil burner. This is a unique feature on our Husky and Polar furnaces that has been overlooked by the authors of the proposed emissions rule and that we are also currently seeking clarification.

There are well over 50,000 YUKON multi-fuel furnaces installed and in use by homeowner’s in the U.S. and Canada and we are taking considerable measures in R&D to account for replacement of the YUKON Husky and Polar furnaces to retrofit seamlessly now and in the future. We are also adamant about the ease of operation by homeowner’s that own and operate a YUKON. It is important to us that your furnace does not become a burden or cumbersome to run.

Updates on any and all progress in research, design and testing of our furnaces will be added to this page. Check back to find out how we are doing in our efforts to continue to offer safe and efficient multi-fuel and wood furnaces that also comply with the EPA’s emissions rule.

Feel free to contact us with any questions you may have regarding the EPA’s proposal and how this will affect our products and you.  

See our comments submitted to the EPA on their draft proposal of the NSPS rule 
Open PDF file » 
Docket ID No_EPA-HQOAR-2009-0734-COMMENTS.pdf

 

Read the NSPS Draft Proposal published by the EPA on the Federal Register website. 
https://www.federalregister.gov/articles/2014/02/03/2014-00409/standards-of-performance-for-new-residential-wood-heaters-new-residential-hydronic-heaters-and#h-13