MEMORANDUM
To:		Gil Wood, USEPA
		David Cole, USEPA
From:		Jill Mozier, EC/R Inc.
Date:		November 30, 2012
Subject:	Notes from the November 8, 2012 Q&A session of the National Educational
      Forum on the Residential Wood Heater NSPS in Minneapolis, MN
____________________________________________________________________________________

The presentation documents and slides are available for download from the Basecamp website. Therefore presentation notes are not included in this memo, which focusses exclusively on the question and answer (Q&A) portion following each group of presentations.

Welcome, Overview and Goals of the Meeting
 David Thornton, MPCA
 Molly Mayo, Facilitator

Public Health and Environmental Impacts of Woodsmoke
 Dr. Ryan Allen, Simon Fraser University
 Dr. Philip Hopke, Clarkson University
 Judy Abbott, NY DOH
 
 Question (Brian Toll, Connecticut Health Dept): What are the health effects under 24 hours? How do we set a reference number for shorter term exposures?
 Answer: Judy Abbot responded that it's a good question but that we're not there yet, and further that county health dept staffs are being cut by 30%. Dr. Hopke commented that we are stuck with FRM measurements which only obtain a third of the data (i.e., only every 3[rd] day), with no time resolution. FEM continuous monitors are needed.
 
 Question (Ed Miller, VP of American Lung Association of the Northeast): Commented that since there may never be enough monitors and because there appears to be no safe level of PM2.5, it may be more effective to approach this from a property rights perspective (e.g., smoke crossing property line for more than 12 minutes in an hour). Videotaping of such may hold up in court and the definition of the violation may be able to be extended beyond OWHH to other sources.
 Answer: Judy Abbot responded that this is a legal question but her understanding is that this would be considered a private rather than a public nuisance in NY.
 
 Question (Dick Valentinetti, Vermont Air Quality DEC): Are there different health effects based on different particle sizes?
 Answer: Dr. Allen responded that a probable driver in toxicity is PM size (e.g., health effects from traffic linked to ultrafines), but attribution cannot yet be made definitively. Dr. Hopke commented that there aren't enough measurements of particle size to know definitively. The 11-year study Dr. Hopke is involved with is the longest particle size study in the US and the second longest in the world, but there aren't enough studies.
 
 Question (Molly Jacobs, UMASS Lowell Center for Sustainable Production): Regarding woodsmoke particle size, are the initial start-up particle size emissions in the nano to ultrafine range, and are there surrogates similar to diesel surrogates? What should be inferred from the extent of combustion and particle size?
 Answer: Dr. Allen responded, regarding the first particle size question, that an epidemiological study can't be done without measurements (and ultrafines can't be measured on a filter; optical equipment is necessary), so instead proximity to major roadway has been used. Related to diesel, there are no equivalent surrogates for woodsmoke. Regarding the extent-of-combustion question, Dr. Allen responded that low temperatures versus high temperatures and incomplete versus complete combustion produce different particle sizes and toxicities. In general, the toxicity decreases with higher temperatures and more complete combustion (based on in vitro cell structure studies rather than epidemiological studies). 
 
 Question (Tomas Carbonell, Environmental Defense Fund): What do the studies say about indoor air quality related to woodsmoke?
 Answer: Dr. Hopke responded that there have been indoor air quality studies on asthmatic children using personal filters, but most indoor air quality studies regard tobacco smoke; not much has been studied regarding the indoor effects of biomass burning. Dr. Allen responded that infiltration studies indicate that 30% to 70% of outdoor PM2.5 infiltrates the house  -  that the issue is generally not woodstoves emitting directly to the indoors but rather the woodsmoke going up the chimney and coming back indoors. He further noted that HEPA filters help. Dr. Abbott noted that a home's typical running of the dryer and furnace creates a negative pressure (which draws outside air in).
 
 Question (unidentified person): What are the established links between birth defects and woodsmoke?
 Answer: Dr. Allen responded that exposure to PM2.5 from traffic during pregnancy has been linked to more pre-term births and low fetal birth weights. There are no studies pointing to woodsmoke in particular, although in general PM2.5 in urban areas is associated with certain pregnancy health outcomes. Dr. Hopke added that similar outcomes have been seen with tobacco smoke and cookstoves. 

Current and Emerging Technologies
 John Crouch, HPBA
 Chris Neufeld, Blaze King / Travis Industries
 Dr. Harry H. "Dutch" Dresser, Jr., Maine Energy Systems
 Nathan Russell, NYSERDA

Question (Arthur Marin, NESCAUM): Regarding retrofitting catalysts, what is the possibility for using this technology in an approach similar to the woodstove change-out effort?
Answer: Chris Neufeld responded that replacing old stoves with catalytic stoves would have limited success because of the higher cost of catalytic stoves, unless a strong incentive is attached (e.g., as in Fairbanks example, owner would need to be given something like $2,500 to exchange old woodstove for EPA-certified replacement). [Editor's Note: Chris has said on other occasions that adding a catalyst to an old conventional wood stove is generally not as simple as just adding a catalyst but rather that the catalyst, bypass, and shielding to protect against flame impingement should be integrated into the design for best performance.]

Question (Andy Ginsburg, Oregon Department of Environmental Quality): Compared to the NSPS, how important are issues like proper sizing, regular maintenance of catalysts, and thermal storage -- that is, how does industry see these compliance issues being implemented and improved in the field?
Answer: John Crouch responded that the NSPS is a small part of the process; the whole system includes aspects like dry and proper wood/fuel. Dutch Dresser commented that there should not be a one-size-fits-all NSPS, rather appliance-specific standards and differentiation are needed in the NSPS. Equipment should be tested for what it is, not for what it isn't. Nate Russell commented that thermal storage plus the boiler should be considered the regulated unit. Chris Neufeld commented that all appliance types need to be maintained, not just catalytic parts. Regarding Andy Ginsburg's follow-up question on how to get dealers to make maintenance happen, John Crouch commented that dealers don't want to put an appliance on the market that causes lots of phone calls. For example, with drafts varying so much it's difficult to design a system that works consistently in all settings  -  this is not a maintenance problem, rather it's a warranty problem. Furthermore, regarding maintenance, who would enforce?

Question (Martin Lunde, Garn Inc.): Are there any studies regarding oversizing (i.e., replacing oversized equipment with proper sized equipment)?
Answer: John Crouch responded that there are no such studies, that the sizing decision is a function of vendor and consumer interaction/discussions. Martin Lunde further commented regarding an example of an oversized pellet stove rated for 200,000 BTU for a 3,000 sq.ft. house in area with only 30 degree lows, and another example regarding a unit which was oversized by 50% but was now oversized by 300% due to caulking and re-insulation of house. He also commented that in Minnesota it's a code issue  -  a unit can't be oversized past 8%. Chris Neufeld commented that for catalytic stoves the option of turning down and burning (a bigger unit) lower is better because it's worse to operate a (too small) catalytic unit too hot. John Crouch commented that the weatherization programs are oblivious to wood stoves and that DOE should conduct stove change-outs in conjunction with improving weatherization of homes.

Question (Dick Valentinetti, Vermont Air Quality DEC): He agrees with John Crouch that federal regulations have unintended consequences. He commented that the new NSPS should include a process for allowing innovation, otherwise it'd be playing around the edges at the state level to improve upon good products. It's a chicken versus egg dilemma  -  for example, Chris Neufeld talked about hybrid models, but how do we get European technology here? What is the driver if it's not regulation?
Answer: Dutch Dresser responded that the Europeans have a stick/carrot/tambourine system. In Austria, the stick is the high tax on fossil fuel; the carrot is a government subsidy (30% of installed cost); and the tambourine is the bully pulpit of government officials talking up the latest technology. John Crouch commented that comparing Europe to the US is an apple to orange comparison.

Question (Dennis Brazier of Central Boiler Inc): Our customers want to save money, but old houses are hard to heat and on the opposite side of the sizing issue there are customers who have high heat load demands who don't want their houses to stay at 60 degrees. It's not acceptable for dealer to simply answer that it's windy today (so stove may not heat the house as well). Thus it's a complex problem. Furthermore some pellet systems are expensive.
Answer: Nate Russell responded that one can look at the building size to quantify heat load and that dealers need to pick-up on model sizing practices.

Case Studies
 Lisa Herschberger, MPCA
 Dr. Jim Conner, Fairbanks Alaska North Star Borough
 Dr. David C. Snyder, University of Wisconsin-Stevens Point
 Jim Hodina, Linn County Public Health Dept, Iowa
 Eric Merchant, Montana DEQ
 
Question (David Thornton, MPCA): What is the nature of the episodic control in Helena, Montana?
Answer: Eric Merchant responded that once 80% of the standard is reached in Helena, a call alert goes out stating that no one can burn solid fuel (unless they have a sole source of heat exception).

Question (Judy Abbott, NYS Department of Health): Did the installation of high tech indoor filters in the Fairbanks school improve asthma rates and/or other health issues? Also, is the public aware of the cost of heart attacks, etc (e.g., wondering about using BenMap perhaps)? Finally, is there CO monitoring (in Alaska)?
Answer: Dr. Jim Conner responded that the indoor filters did not make a big difference. There was a hospital admissions study but it was not broken down by area, and statistics broken down by local area would help because health costs motivate people. There is CO monitoring and Alaska is in compliance for CO, but CO is a nuisance complaint and needs to be addressed. 

Question (Christian Rakos, European Pellet Council): Top level products/appliances could solve Alaska's problem. Did anyone consider subsidizing the top units? There would be a huge incentive to dealers.
Answer: Dr. Jim Conner responded that the change-out should have been limited to top 2% of units, but it wasn't.  Had it been limited to top units, Alaska wouldn't have to ban burning on certain days.

Question (Dr. Ryan Allen, Simon Fraser University): There are real costs associated with health effects and almost invariably there is a net economic benefit [to lowering pollution levels].
Answer: Dr. Jim Conner responded that the public does not see dead bodies lying around the streets, so basically people are not motivated enough.

Question (Janis Denman, Michigan DEQ, Air Quality Division): Regarding the Iowa standard ("for heat inputs less than 10 million BTU, 0.6 lb/million BTUshall apply"), how does one get from input to output?
Answer: Jim Hodina responded that one would need to include the boiler efficiency and moisture content of the wood (and that they were working within the old standard).

Question (Tom Morrissey, Woodstock Soapstone): First, Tom Morrissey commented that he is stunned by the amount of wood burned outdoors for recreation in chimineas, and wondered if there was more data on this. Second, he noted the intersection of low income people with high fuel costs and wondered what the EPA and NSPS can do in this respect 
Answer: Lisa Herschberger commented that there is not much data around the country yet on outdoor recreational wood burning (e.g., chiminea use), but she is hoping Minnesota's new survey will provide better estimates. Outdoor recreational wood burning is a problem and is trending with the increases in sales of equipment, but more accurate data is needed. Lisa Herschberger commented that she has been questioned before regarding whether the current estimates are real, but it is at the very least clear that the amount of wood burned outdoors for recreational use is trending upwards. 
Answer: Regarding Tom Morrissey's second question, Dr. Jim Conner commented that Alaska wants EPA to get emission level down and also to address coal burning. Alaska needs to lean on federal standards because there's not enough political will locally. Eric Merchant commented that Montana needs a lower standard driving technology to address issues like elevations and inversions.

Market Impacts of Emission and Efficiency Standards
 Bob Ferguson, Consultant to HPBA
 John Ackerly, Alliance for Green Heat
 Christian Rakos, proPellets Austria

Question (Jack Goldman, HPBA): Did European governments subsidize higher cost units?
Answer: Christian Rakos responded that European governments such as Austria's use a carrot and stick approach and that governments did subsidize higher performing units. He suggested that the US should also subsidize renewable energies.

Question (Chris Neufeld, Blaze King): What about woodstoves in Europe (e.g., catalytic stoves)?
Answer: Christian Rakos responded that Europe does have woodstoves (in addition to pellet models) but that he hasn't seen many catalytic stoves, rather there are primarily ceramic tile masonry heaters in Europe (to the best of his knowledge).

Question (Tom Morrissey, Woodstock Soapstone): Will increased efficiency lead to decreased emissions?
Answer: Bob Ferguson responded that there is no guarantee of decreased emissions with increased efficiency because combustion efficiency and overall efficiency can work in opposite directions. Christian Rakos also responded that increased efficiency will not necessarily lead to decreased emissions because of the need to ensure that the combustion process has enough air  -  so both need to be pushed to work well together, for example with electric control of combustion. (John Ackerly agreed with this.)

Question (unidentified): What is the cost of fuel oil in Europe?
Answer: Christian Rakos responded that the cost of one European liter corresponds to a price of approximately $4 to $5 per gallon, and that 20% of cost is government tax.

Question (Lisa Rector, NESCAUM): Are there government subsidies for performance tiers?
Answer: Christian Rakos responded that there were different types of subsidies in each province and that provinces competed to have their subsidy make the largest effect. This competition among province subsidies drove the market.

Question (Dan Henry, 5G3 Consulting): What is the finished cost of the installed heat system (pellet boilers in Europe)?
Answer: Christian Rakos responded that the cost is approximately $18,000 Euro for pellet system and $12,000 Euros for gasified logwood (these numbers would be multiplied by approximately 1.3 to convert to US $ -- so $23,000 for pellet system and $16,000 for gasified logwood). Christian Rakos further commented that these numbers nonetheless pay for themselves because of difference compared to fuel oil prices, and that this is especially true for larger homes where the payback takes about 3 to 4 years.

Question (Judy Abbott, NYS Dept of Health): What is LHV versus HHV?
Answer: Bob Ferguson explained that water is produced in wood burning and that this water can go up the chimney, or heat can be recovered from condensation of this water vapor. HHV assumes that this heat can be recovered and so is a higher number of available BTUs per kilogram of wood (heating value) than LHV. LHV assumes that one will not attempt to recover the heat from the water vapor but rather that it will always go up the chimney so the heat of condensation is not counted, hence the smaller (aka, lower) number for available heat per kilogram of wood. Combustion efficiency is not affected by HHV or LHV, but overall efficiency is the heat output divided by the heat input  -  the smaller the denominator the larger the fraction  -  so LHV results in a larger calculated overall efficiency than HHV does. There is a 5% to 8% difference in the calculated overall efficiency based on whether LHV or HHV is used. John Ackerly further commented that European appliances are therefore not necessarily better/more efficient than US appliances (boilers are, but not other appliances) because Europe typically uses LHV and U.S. typically uses HHV. Nonetheless, the marketplace sometimes perceives that European appliances are more efficient because of this difference (of using LHV, not HHV). Wood burning uses LHV in Europe while fossil fuel uses HHV in Europe. Dutch Dresser commented later that a condensing pellet boiler was introduced in 2004 which recovers water vapor (4 to 8 kilowatt, 12,000 to 30,000 BTU small boiler versions which are good for low energy homes) and that demand for such small boilers is increasing. Thus, it is incorrect to say that condensing wood boilers are not in the marketplace. 

Question (Judy Abbott, NYS Dept of Health): Is there an issue with CO emissions from storage of pellets?
Answer: Christian Rakos responded that very large pellet piles can produce high concentrations of CO due to oxidation (e.g., people died in ship transport of bulk pellets)  -  consequently a cellar with a pellet pile needs to have good ventilation. But this is not an issue with bags of pellets, only with a pile on the order of magnitude of 100 tons.

Question (Jiggs Blackburn, Rising Stone Inc): What about CO as a surrogate for PM emissions -  is Europe measuring CO constantly? 
Answer: Christian Rakos responded that Europe is measuring CO emissions constantly and has found that low CO values mean complete combustion with hardly-measurable hydrocarbons. Europe has also found that the fine dust composition of the ashes differ in complete versus incomplete combustion, with complete combustion forming white ash (water soluble salts which do not lodge permanently in lungs as black carbon does).

Question (Tomas Carbonell, Environmental Defense Fund): In Europe, how does in-field performance compare with tested performance (in lab)?
Answer: Christian Rakos responded that this discrepancy is very important as long as the consumer can interfere and effect performance of stove/boiler. If consumers cannot effect the performance (as in the case of automatic boilers with electronic controls), then there is a very low discrepancy.

Question (Roger Holland, Supreme Fireplace Products):  Doesn't the Burnwise program already educate consumers? What more is needed?
Answer: John Ackerly responded that better education is needed regarding the efficiency confusion and the differences in American HHV and European LHV usage.

Question (Larry Sorrels, USEPA): Regarding HPBA's 1% annual sales increase estimate, how far in the future does this apply and what assumptions regarding fuel oil (other fuel costs) are inherent to this estimate?
Answer: Bob Ferguson responded that the projection is based on ~10-year history and rolling averages (included fireplace inserts). The saw tooth graph Bob displayed indicates that the trend is hard to predict, so he just assumed the historical sales would continue for 5 to 7 years in the future. [Question about other fuel costs was not answered.]


Pellet Fuel Supply and Fuel Quality
 Chris Wiberg, Timber Products Inspection
 Christian Rakos, proPellets Austria
 Lisa Rector, NESCAUM

Question (unidentified person from a Minnesota county): The question regarded the BTU listed on the pellet bags being based on HHV (which includes the heat of condensation) and whether this was the standard basis for the listed BTU seen by consumers on all pellet bags. 
Answer: Chris Wiberg responded that the reason the BTU is on the pellet bags is to help consumers compare (although the declared BTU is not necessarily dealing with the LHV versus HHV issue).

Question (Andy Ginsburg, Oregon DEQ): Is a better appliance needed for utility grade pellets? How can you stop consumers from using utility grade?
Answer: Chris Wiberg responded that the ash content can be as high as 6% (e.g., agricultural feed stock like switch grass pellets fall into utility grade). NSPS may rate stove as to whether it can burn utility grade pellets but consumers cannot be stopped from using the lower grade since there are no pellet police. Manufacturers may void warranties however. Dan Henry of 5G3 Consulting commented that this problem is self-regulating because the pellet stove will stop operating if using utility grade pellets.

Question (Gil Wood, USEPA): Is the EN Plus standard for residential units only (not power/utility)?
Answer: Christian Rakos responded that yes, EN Plus is for residential units only.

Question (Gil Wood, USEPA): What is in the European standard to measure/analyze (e.g., metals)?
Answer: Christian Rakos responded that every element is tested for in the ISO standard, so it's a complete system. Europe would like US to use the same standard system. Chris Wiberg commented that assuming the feedstock is clean, there would not be metals. Audit inspections rather than testing and analysis are the best chance of catching problems. Chris Wiberg further commented that he agrees the ISO standards are appropriate, but the limits may not be the same limits the US would have chosen  -  so while it's a good basis for comparison, it is not necessarily a good match.

Question (Molly Jacobs, UMASS Lowell Center for Sustainable Production): Is the variability within a single manufacturer part of the sampling? Can you track where the contamination came from (e.g., through labeling scheme)?
Answer: Lisa Rector responded that de-barked hardwood produced a consistent product with no methodological contamination. However, another supplier had multiple feedstocks with some contamination which was hard to track/identify. For example, one bag tested high and then 3 more bags from different states during the heating season were all off-the-charts as well. So this is an ongoing problem which is of concern, based on elemental analysis. Lot numbers are needed.

Question (Lisa Rector, NESCAUM): Is sampling of pellet manufacturers random or planned?
Answer: Christian Rakos responded that an EN Plus facility is informed of inspection several days before, so there is some warning, but the auditor would nonetheless catch a systematic use of waste/trash and serious contamination. Furthermore, serious contamination would cause the boiler to malfunction. Chris Wiberg responded that the first inspection (in the US) is planned but additional inspections are unannounced/random.

Question (Ben Myron, Myren Consulting Inc): Were there any split samples in data NESCAUM was referring to?
Answer: Lisa Rector responded that there were no split samples between labs, but 15% had duplicate samples analyzed.

Overview and Status of Current Draft of USEPA's NSPS for Residential Wood Heating Devices
 Gil Wood, USEPA
    
Question (Jack Goldman, HPBA): If EPA has a goal of completing a draft proposal by the end of the year, what is the deadline for sending information to EPA?
Answer: Gil Wood responded that information should be sent as soon as possible  -  that is, within weeks not months.

Question (unidentified person): What about limitations on operational requirements? For example, a stove can work well in the laboratory but not in the field  -  so how can EPA address boiler operation once it's installed and then operated poorly by a consumer?
Answer: Gil Wood responded that the current NSPS has a requirement that homeowners operate the appliance according to the owner's manual  -  so that requirement is potentially federally enforceable, although it has never been used to date. Warranty requirements need to be reviewed more closely. In the draft proposal, pellet stoves must certify with fuel(s) they advertize for burning and include in warranty.

Question (Lisa Rector, NESCAUM): Can energy audit/tune-up be included, like in the area source boiler rules? 
Answer: Gil Wood responded that legally yes, but he is not the EPA Administrator and she has not been briefed on the details of the draft proposal yet.

Question (Ed Miller of American Lung Association): Vehicle emission success story has gotten too little attention. Stoves have too long a shelf life (and he is concerned about legacy fleet).
Answer: Gil Wood responded that the CAA legal authority for motor vehicles is different than the CAA authority for stationary sources. The CAA authority (section 111) for new stationary sources requires EPA to base the standards on emission levels that reflect technology, that is best systems of emission reduction (BSER) considering costs and not health-based AQ levels. Looking over a longer lifetime (20 years) of the heaters is appropriate.
Question (Ed Miller of American Lung Association): Is there a role for an advocacy group  -  that is, should we look at modifying CAA instead of working within it?
Answer: Gil Wood responded that EPA cannot legally tell people to speak to their Congressman.

Question (unidentified person): An inexpensive way to measure [ambient air] particulates is needed  -  that is, a particle counter is needed for use in the residential setting to measure PM2.5 and other sizes (rather than the timely and expensive EPA [Federal Reference Method for the NAAQS and the] metric of ug/m[3]). Laser type counters offer easy, continuous checking but it would help if EPA had guidelines on what constituted a health threat.
Answer: Gil Wood responded that Region 5 is looking at this, as well as USEPA's ORD.

Question (David Menotti, Crowell & Moring): Woodstoves are being regulated under the NSPS because the NRDC proposed this as a settlement option in early 80's (i.e., using Section 111 for PM instead of 112 for PAHs since no one wanted a national standard to physically require removing all existing woodstoves from houses across the country). The challenge is to get existing non-certified appliances out of the inventory versus fooling around with tightening new source performance standards at the margins.
Answer: Gil Wood commented that Larry Brockman is the EPA lead for the Burn Wise program and leads EPA's team that has been working on public education/outreach and promoting change-outs. Other areas of opportunity and success (which do not fall under the NSPS) include: PM Advance [a new EPA program that will encourage states and local authorities to institute additional measures in "advance" of the revisions to the PM NAAQS compliance deadlines]; tools for PM measurements; burn ban days; promoting seasoned wood; energy audits; requiring change-out of stove when home is sold; etc. The Libby, Montana example points to improperly installed and unsafe stoves  -  so proper installation and DOE incentives are also being looked at.

Question (Chris Neufeld, Blaze King): In 1988 there were no Phase 1 and Phase 2 EPA stoves on the market, so original stoves were grandfathered in. But now Phase 1 and 2 stoves are available on (the secondary) market. Do original stoves still have to be grandfathered in, or can we promote secondary market stoves? When does someone say that the original impetus is no longer there? 
Answer: Gil Wood clarified with Chris Neufeld that he was referring to the re-selling of existing stoves, and then responded that having existing stoves in a new place is probably not enough to be considered a "new source" so it's doubtful that EPA can address the issue this way under the NSPS. OGC has already commented that such a stove is not a new source. EPA could restrict the sale of replacement parts but this could be problematic. Dick Valentinetti (Vermont DEC Air Quality) further commented that both new source performance standards and change-outs are required  -  a requirement for new products (to keep industry going) is not all that's required. State and local agencies need to do something as well, not just the USEPA.

Question (Tomas Carbonell, Environmental Defense Fund): EPA has lots of discretion with cost; he hopes that EPA considers that these [appliances] are unique since they are in residential areas and much of the emitted pollution is inhaled. Tomas Carbonell further commented that strict standards may stimulate a robust market (as in international/European example). 
Answer: Gil Wood commented that EPA does have discretion regarding what levels of cost effectiveness are appropriate. Regarding Tomas Carbonell's robust market point, a representative from HPBA commented that Europe, unlike the US, is subsidized.

Question (unidentified person): Why not regulate based on cleanest available fuel  -  for example, why consider allowing wood in a populated area if natural gas is cleaner? 
Answer: Gil Wood responded that this approach may be appropriate for state and local agencies to consider, but the USEPA has to look at residential wood heaters as a new source category listed under Section 111 and determine the emission levels for standards based on demonstrated best systems of emission reductions for those new sources. Dan Henry commented that in reality people will choose natural gas over wood because natural gas is cheaper  -  wood is not competing with natural gas but rather with more expensive forms of fuel.

Next Steps
 Dan Johnson, WESTAR
 
 The Multi-Jurisdictional Organizations (MJOs)  -  representing 40 states  -  have a purpose at this two-day educational forum to become better informed. The MJOs have sent a letter to the USEPA requesting that EPA move forward with the NSPS, including BSER and cost, considering test methods and costs, and in-home performance. The group has 4 weeks to continue the discussion on Basecamp. Please share ideas on Basecamp. EPA has to propose regulations with or without those shared ideas.


