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EPA Proposed Biomass Boiler Emission Standards

UPDATE: On July 22, the U.S. Environmental Protection Agency (EPA) extended the comment period on its Proposed Rule for Area Source Boilers, a potential regulation that threatens to place prohibitively expensive emissions requirements on existing equipment and severely harm the future growth of the biomass thermal industry. 

EPA is now accepting public comments on the proposed rule until August 23, 2010.
We still need your help in getting your state officials and elected representatives to voice their support for common sense boiler regulations. Click here for a template letter and contact information for your state.


Background

On June 4, 2010, the U.S. Environmental Protection Agency (EPA) released a Proposed Rule for Area Source Boilers that threatens to severely curtail the future growth of the biomass thermal industry and place prohibitively expensive emissions requirements on existing equipment. EPA is inviting public comments on the proposed rule until August 23, 2010.

A working group of BTEC members has spent a considerable amount of effort in developing BTEC's public comments to the EPA. Those comments are now finalized and can be downloaded here:

BTEC Comments to the EPA on the Proposed Rule for Area Source Boilers


Under these proposals, new and existing biomass boilers at area source facilities would be required to meet new emission limits for carbon monoxide (CO) and particulate matter (PM):

Status
Size
PM (lbs./mmBtu)
CO (ppm @ 7% 02)
Existing >10mmBtu/hr
N/A
160
Existing <10 mmBtu/hr
N/A - Biennial tune up
N/A - Biennial tune up
New >10mmBtu/hr
.03
100
New <10 mmBtu/hr
.03
100

Unachievable and Unrealistic Standards

EPA’s proposed emissions limits rely on a data set that is not representative of real-world technologies.  Biomass boilers that achieve EPA’s particulate matter (PM) standard are not the same boilers that achieve its carbon monoxide (CO) standard.  Using EPA’s own data set, it is obvious that there is no biomass boiler tested that can achieve both the proposed levels for PM and CO.  Requiring new biomass boilers to meet standards that no single biomass boiler has ever achieved in testing is unreasonable. 

High Compliance Costs and Economic Consequences

Under EPA’s new annual emissions testing requirement, testing expenses would add an estimated $8,000- $15,000 per boiler system. That added cost likely surpasses the biomass fuel bill for smaller systems and is a major budget consideration for larger biomass boiler systems.  Also, proposed compliance technology requirements could cost more than the biomass systems themselves.  Such costs negate the monetary and environmental advantages of using renewable, local biomass fuel, thus encouraging continued fossil fuel use and discouraging investment.

EPA’s unachievable emissions limits will reduce biomass boiler use and fuel demand, which will incur widespread economic losses in industries that rely upon this low cost fuel, such as the wood products manufacturing, forestry, and agriculture sectors.

BTEC Recommendations

BTEC recommends initial and interim data-driven limits and practices that are representative of real-world technologies:

  • Initial minimum performance standards of (CO) – 1,164ppm (@ 7% O2) and (PM) - 0.23 lbs/mmBtu for all boilers, with reductions thereafter based on data collected during the first two years of the Rule’s implementation;
  • Initial third party boiler certification test with required annual tune-ups without ongoing costly stack testing. Once a boiler (or range of boilers) is tested, that boiler would be approved for installation until a change was made in the boiler design.

Take Action

The deadline for comments is August 23, 2010. There are two ways that you can help influence the rule making process:

  1. Submit your own comments to EPA on the proposed rule. Use BTEC’s comments as a starting point. Email or fax your comments to EPA at a-and-r-Docket@epa.gov or 202-566-1741. Include Docket ID# EPA–HQ–OAR–2006–0790 in the subject line of your comments

  2. Notify your Senators, Representative, and other state officials. Ask them to support realistic EPA emissions limits for biomass boilers. A template letter and contact information for your officials can be found below.

Contact Your State Officials

  1. Download our template letter. BTEC has created a template letter to help you communicate the impact of this damaging proposed EPA rule to key policymakers in your state. Please add your own letterhead or customize as you see fit. Download here:


       BTEC Template Letter to EPA (33K MS Word file)


  2. Find your key policymakers. Locate contact info for your state's key policymakers through the following links:


  3. Finalize the template letter for each official. Use the contact information determined from the previous step and fill out the necessary fields in the letter.

  4. Send the letter via email, fax, or web form. Timing is important--we need these officials to get the message as soon as possible. For Members of Congress, the preferred method of contact is via web form or fax. For state officials, the contact will most likely be via email or fax.

  5. Follow up. Make sure your officials hear the message by following up by phone!

More Info

BTEC Comments to the EPA on the Proposed Rule for Area Source Boilers

www.epa.gov/airquality/combustion/actions.html

How You Can Get Involved

Join BTEC today to learn more about the impact of the proposed rules or to get connected to BTEC's efforts in this area.

 

BTEC Members

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Phone: 202-596-3974
info@biomassthermal.org

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BTEC SUSTAINING MEMBERS

Marth
New England Wood Pellet

 

 

BIOMASS THERMAL ENERGY COUNCIL
1211 Connecticut Ave NW, Suite 650 Washington, DC 20036
Phone: 202-596-3974   Fax: 202-223-5537   info@biomassthermal.org

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