|Vermont Castings combustion engineer |
Doug Fongeallaz uses cord wood to test
a stove instead of Doug fir cribwood,
according to the Valley News.
An attorney who specializes in NSPS law and is familiar with this case says that "the EPA could, in theory, set a legally defensible emission limit for both cat and non-cat stoves that relies on emission rates that are achievable by catalytic stoves but that may not be achievable by non-cats. EPA can’t require a specific technology under section 111, but it has the discretion to set the emission standard at a level that has only been achieved by one type of technology. I suspect EPA would probably win on this point if challenged, however at this early stage, such predictions are still very speculative. Ideally, there will be more data points than just 2 stoves, but I don’t think that’s going to be fatal to EPA, especially if industry isn’t willing or able to produce cordwood test data contradicting EPA’s data."
(The Alliance for Green Heat does not support a cordwood standard such as 1.3 grams per hour that some cat stoves appear to be able to meet, but regularly consults legal experts to see what EPA can do. The danger may be that regardless of the recommendations from the EPA's stove experts based in North Carolina, far more senior EPA officials in Washington may take a much harder line.)
|Tom Morrissey, back row, 2d from|
right and the team that built the
Ideal Steel Hybrid that emits less
than 1.3 grams an hour with
cordwood and cribs.