From Magic City Morning Star|
A wood boiler company, headquartered in Michigan, responds to Maine's proposal to ban, or severely limit, the use of outdoor wood boilers, citing facts rather than rhetoric, as follows:
Mr. Ronald Severance
Dear Mr. Severance/Ms. Wheeler:
The purpose of this document is to provide comments in response to the "Chapter 150 Control of Emissions from Outdoor Wood Boilers" published in a board memo dated July 5, 2007.
Hawken Energy, Inc. is an outdoor wood boiler company headquartered in Michigan. We offer six models of outdoor wood boilers and a full compliment of parts associated with such boilers. We sell our products through a network of dealers in Michigan, Ohio, Pennsylvania, New York, Illinois, Missouri, North Carolina, Indiana, New Hampshire, West Virginia, Virginia, Wisconsin, Kentucky and most importantly, Maine. As far as we are aware, NO STATES HAVE ADOPTED STATEWIDE REGULATIONS of outdoor wood boilers.
The high cost of energy for home heating has financially crippled many homeowners nationwide. The mission of Hawken Energy, Inc. includes providing homeowners a way to stay warm in their homes, without facing financial disaster. We have never received a single complaint regarding emissions from any of our customers or their neighbors. Any claim of a high rate of complaints is simply untrue.
We are confused by your rationale for proposing this rulemaking. You state in the memo as follows:
"Children, the elderly and those with respiratory problems are most at risk from exposure to wood smoke."
Do you mean to state that wood smoke is somehow more harmful that petroleum fumes and emissions from fossil fuel burning heating devices? This is preposterous.
What is the real reason for your proposed rulemaking? What foreign oil interests are you serving? What lobbyists are making contributions to your campaigns? It is truly unbelievable that you would even attempt to make a claim that a little wood smoke is somehow more harmful than even automobile exhaust! You state that "Fine particulates can aggravate lung diseases such as asthma, emphysema and bronchitis." To be affected in such a way, one would have to get on a ladder and place their face over the furnace chimney. If someone were to do this with an automobile exhaust pipe, almost instant death would result. Does the State of Maine intend to outlaw automobiles?
Let's forget for a moment that wood has been used as the primary fuel for the human race since the beginning of recorded human history, that it is the world's most abundant natural RENEWABLE fuel, and let's forget for a moment that the world's supply of fossil fuels is running out. Let's just look at the economics - when fossil fuels quadruple in price over the next few years, how many citizens of Maine will be able to afford to heat their homes with foreign fossil fuels? The rest of the country is going to stay toasty warm, and the law abiding citizens from Maine will either be frozen or broke.
You also state as follows:
"OWB, on an average per hour basis, emit about four times as much fine particulate matter as conventional wood stoves, about 12 times as much fine particulate matter as an EPA-certified wood stove, and 1000 times more than an oil furnace."
This is completely false. This New York Spitzer study was grossly flawed in its analysis. Also, to make this claim is totally misleading, given that it only relates to particulate matter. Who cares about particulate matter? "Particulate Matter" is practically harmless! Not to mention the fact that the "1000 times more." claim only relates to one bogus study of a furnace with a flawed design. Most people would rather inhale a few "particulates" than petroleum fumes and fossil fuel emissions. Do you have any idea how nasty the emissions are from an oil furnace?
How about some facts:
Background of Wood Fuel
The following is general background information of using wood as a fuel:
1. Wood has been safely used as a fuel since the beginning of recorded history.
2. Per Btu, wood is much less expensive than fossil fuels - at current prices, natural gas is three times the cost of wood, propane is five times the cost of wood, and electricity is seven times the cost of wood.
3. The Environmental Protection Agency (EPA) has specifically exempted outdoor wood furnaces from its emissions regulations. Why should the state create environmental regulations when the Environmental Protection Agency does not see the need to? Note that their new regulation - "Phase 1" is VOLUNTARY.
4. Wood is a renewable fuel. This means that it can be restored and replenished by nature in a period of time that is compatible with our human use. The heat released from wood is actually stored energy from the sun--released when consumed in a wood burning boiler. Wood is an abundant resource in this country that is easily sustained. Provided they are cared for and managed properly, our forests can be a perpetual source of fuel, unlike gas, oil, and coal, which are being depleted at a rate that is astonishingly faster than the millions of years it took Nature to make them. Wood is affordable, renewable, sustainable, it is a secure domestic heating method, and wood is appropriate to the resources of our country.
5. Wood burning is completely safe in terms of "Greenhouse Gasses" - All fuels produce carbon dioxide, the primary greenhouse gas, when they burn. When the atmospheric concentration of greenhouse gasses increases, they cause the average global temperature to rise.
Wood differs from the fossil fuels coal, oil and gas, because it is part of the natural carbon/carbon dioxide cycle. As a tree grows, it absorbs carbon dioxide from the air and stores it in the wood as carbon, which makes up about half of the weight of wood. When the wood is burned, carbon dioxide is released back into the atmosphere. No additional carbon is released because the same amount of carbon dioxide would be released if the tree died and were left to rot on the forest floor. The carbon in coal, oil and gas, by contrast, are taken from underground stores, usually from overseas, where they were deposited by Nature, and released into the air without means for equal reabsorption.
When trees are used for energy, a part of the forest's annual growth is diverted from the natural decay and forest fire cycle into our homes to heat them. Firewood is a natural energy product from the forest. Burning wood actually helps reduce greenhouse gas emissions by displacing the use of oil, gas and coal.
6. Burning waste wood also benefits the environment because it reduces wood waste that would otherwise take space in landfills. "In the US, wood and paper thrown away each year is enough to heat 5 million homes for 200 years." Think about it - five million homes for 200 years. And that was ten years ago.
7. Though the use of any resource has an environmental impact, the use of wood as a fuel is much more in keeping with the natural cycles of ecosystem Earth. The heat produced by burning firewood is actually the warmth of the sun, stored in trees through the process of photosynthesis. When the sun abandons us during the cold dark days of winter, we liberate the sun's heat through the "reverse photosynthesis" of burning. Like every other cycle in Nature, every process has its opposite.
8. What fuel will be used when the world runs out of oil - which is expected to happen within 50 years? The world is running out of fossil fuels. In a few years, the world's inhabitants will have consumed one-half of the known fossil fuel reserves. Once this happens, fuel prices will skyrocket as fears of "running out" will become more of a reality.
"The volume of the world's petroleum reserves is important because of the fear that the oil will run out. This fear should be expected, because the estimated 1 trillion barrels of crude oil is only enough to supply the world for about 50 years. This prediction is based on the present world consumption; however, world consumption is expected to increase."
9. Within 10 years, experts project the world oil demand will exceed production capacity by 20 million barrels per day. This will result in astronomical fuel prices to level the supply/demand curve. Homeowners will be forced to find and pursue alternative heating methods. States with regulations limiting the burning of lower cost fuels such as wood will find that their regulations will be ignored, or their citizens will simply move to other states that allow wood burning.
10. Once Peak Oil occurs and petroleum products increase in price four-fold, and then ten-fold and beyond, any regulations the State of Maine may pass now will probably soon fall into the category of "Goofy Laws" similar to the following:
California: No vehicle without a driver may exceed 60 miles an hour.
Florida: If an elephant is left tied to a parking meter, the parking fee has to be paid just as it would have to be for a vehicle.
Hawaii: You may not fish on a camel's back.
Illinois: You must contact the police before entering the city in an automobile.
Oklahoma: Whaling is illegal. (Is this really a problem?)
11. Though heating with wood may sound old fashioned, modern wood-burning appliances are anything but. Existing technology enables the use of catalytic converters and other emissions control devices to almost entirely eliminate smoke emissions - this allows wood to give up to 75 percent seasonal efficiency while emitting 90 percent less smoke than before. Certain models currently available further reduce emissions by "gasifying" wood and then burning the gasses at extremely high temperatures, thus almost completely eliminating emissions.
12. Wood is a reliable fuel. In the midst of a winter storm when the power goes out or during an energy crisis rolling blackout, homeowners can still heat with wood. It gives both heat and comfort during times of emergency. Wood also gives freedom. Having the ability to burn wood for heat in a home gives more freedom and options for fuel. Many homeowners live away from natural gas pipelines and are forced to purchase much more costly fuels such as propane or fuel oil. Wood fuel allows a homeowner to no longer be dependent on large energy utilities that may or may not be able to supply energy.
13. Foreign fossil fuel suppliers simply don't like wood burning advocates. These foreign energy companies likely have lobbyists who aggressively support your rulemaking efforts. They try to tell us that wood smoke is bad for us, while offering only one solution: "Pay us for our fuel!" They do not mention that their fuel can never be replaced. They say "Go ahead, take our fossil fuels out of the earth. By the time your grandkids get old enough to need it, you'll be dead anyway, so why should you care?" This short-sighted view of the greedy billion dollar fossil fuel companies (who only care about their profits) should not be permitted to be a factor in your decision-making process.
14. Outdoor wood boilers take combustion outdoors. Therefore, households and businesses can reduce their insurance costs by using outdoor furnaces since outdoor combustion eliminates many risks of fire damage.
15. Maine is a state with a rich supply of hard wood. The harvesting and burning of this wood is an important economic factor in your state. It further reduces your state's dependence on foreign energy companies. Wood supports our local economy. There is no billion dollar wood fuel utility that will profit from wood burning or multinational corporations involved in the wood heat business. Most businesses that supply furnaces are small manufacturers and retailers. Local workers who chop firewood and chimney sweeps who service wood-heating systems get the benefit of your citizens' dollars.
Factual Inaccuracies of Memo
Given this background, we would now like to point your attention to several inaccuracies in your Memo:
1. How does smoke from outdoor wood boilers rank as a source of emissions in Maine? Your notice implies that it is significant, but this is highly unlikely. If harmful emissions from outdoor wood boilers amounts to less than one-one hundredth of one percent of pollution emissions in the state of Maine (as many suggest), how can you justify rulemaking when other sources of emissions are not sufficiently regulated? This information is not provided in your Memo and we would urge you to obtain reliable data in this matter before pursuing regulation.
2. Your Memo makes the statement that "These regulations shall be designed to achieve and maintain ambient air quality standards and emission standards within any region and prevent air pollution." This statement and its implication that air quality is compromised using an OWB is simply not true. Hawken Energy, Inc. sells a furnace that produces almost no smoke emissions because of its unique design which "gasifies" wood and then combusts the gasified emissions at high temperature. Furthermore, common fireplace designs which do not include any type of forced draft emit much higher emissions relative to BTUs provided compared to almost any outdoor wood boiler. Please note that arguments not made on "relative" terms are misleading since overall fireplace emissions far exceed outdoor wood boiler emissions.
3. Your Memo appears to make the preposterous argument that burning wood is somehow more harmful than burning fossil fuels. Citizens from Maine are too smart to believe that burning fossil fuels could possibly be safer than burning wood. A considerable body of evidence suggests that emissions from fossil fuel burning are much more harmful than emissions from wood burning, and no empirical data exists stating otherwise.
4. Your Notice implies that outdoor wood boilers have much higher emissions than other home heating devices. The evidence you provide does NOT justify making this statement. Again, this statement appears to make the argument that burning wood is somehow more harmful than burning fossil fuels.
5. What you fail to address is the cost savings OWB users achieve. Not only do they help reduce our country's dependence on foreign oil, they are able to save considerable dollars that can be spent in their communities in your state. Per BTU, the current price of heating oil in Maine is easily five times the cost of wood, and the cost of electric heat is more than seven times the cost of wood.
6. You also fail to address any of the many other benefits of operating an OWB. For example, OWB users eliminate fossil fuel combustion inside their homes. This improves moisture levels inside homes, it reduces the risk of carbon monoxide poisoning, and it eliminates the risk of death by fire caused by indoor fossil fuel burning heating devices.
Hawken Energy, Inc. is a clean-air advocate. Our products produce almost no smoke compared to our competitors. We have even recently introduced a new product that makes our furnaces almost completely smoke free - it is the exclusive Hawken Catalytic Combuster, which attaches to an OWB chimney and combusts any smoke particles similar to an automobile's catalytic converter.
Our philosophy at Hawken Energy, Inc. is that we want to be a good neighbor. Therefore, we will only sell to our customers who live in densely populated areas products that produce no or very low emissions that would not affect a close neighbor. We believe that certain densely populated cities are justified in passing ordinances that restrict emissions - in their densely populated residential areas only.
We also have models that are designed for rural areas where smoke emissions are not a concern. To our knowledge, none of our rural customers have installed their outdoor wood boilers within 100 feet of their neighbors and it is for this reason that we have never had a smoke-related complaint from any customer or their neighbors.
Your proposed regulations on outdoor wood boilers would be inappropriate for the following reasons:
1. Wood is a renewable and environmentally sound fuel that has been safely used since the beginning of recorded history.
2. A state body should not create regulations based on incomplete, inconclusive, and incorrect data. Insufficient data exist to substantiate claims of harm, thus leaving the only justifiable argument for rulemaking to be the nuisance claims of a few.
3. A state body should not create regulations that impact the entire state, based on a small number of complaints by citizens from a very tiny geographic portion of the state.
4. No government body should regulate an industry without concrete standards - such do not yet exist for outdoor wood boiler emissions, but are being developed presently.
5. No other states have adopted state-wide rules regarding outdoor wood boilers, and the EPA has specifically exempted outdoor wood boilers from its mandatory wood burning regulations.
6. Wood fuel benefits your state economy, reduces your dependence on foreign fuel companies, and promotes alternative energy usage.
7. Burning wood is much better for the environment that burning fossil fuels.
8. Wood burning in an outdoor wood boiler is much safer for homeowners since the combustion is outdoors and only sends hot water indoors.
9. Given projections of very high future oil prices, states with regulations limiting the burning of lower cost fuels such as wood will find that their regulations will be ignored, or their citizens will simply move to other states that allow wood burning.
10. Finally, burning wood is much better than burning fossil fuels - it gives Maine citizens an affordable means of heating their homes, thus enabling them to use their hard-earned dollars for other goods and services at businesses within the borders of the State of Maine - not sending their dollars to foreign energy companies.
We do not support ordinances or rules proposed for non-densely populated areas. We therefore do not support township or statewide ordinances or rules. We strongly urge the State of Maine not to adopt regulations, and to allow local cities to handle the matter in their respective jurisdictions where needed.
Warren W. Walborn
Hawken Energy, Inc. is an energy technology company focusing on providing energy-saving products to residential and commercial customers. Hawken Energy has extensive expertise in energy technologies, and they are becoming recognized among leading U.S. experts in wood fuel systems.
© Copyright 2002-2013 by Magic City Morning Star