Letter to EPA: Advocacy Recommends that EPA Revise the 2015 Wood Heaters Rule to Reduce Burdens on Small Manufacturers
The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Environmental Protection Agency’s (EPA’s) November 30, 2018 notices on the New Source Performance Standard (NSPS) for Residential Wood Heaters, New Residential Hydronic Heaters and Forced-Air Furnaces. Advocacy supports the amendment to add a sell-through provision for new hydronic heaters and forced-air furnaces, but strongly encourages EPA to include new residential wood heaters as well. Further, Advocacy encourages EPA take additional measures to reduce the burden of the NSPS on small businesses in order to encourage a vibrant market in these products and encourage customers to replace their older dirtier heaters.