A DEBATE ABOUT REGULATORY STRATEGY

Don't penalize everyone - prosecute the polluters

From Robert in Oregon

Regulators should not ban this or that kind of stove, but ban the creation of offensive smoke that crosses property lines.  It would be very helpful to provide some kind of checklist so it's possible to separate acceptable users from unacceptable ones.  This could apply to all smoke-generating uses, not just boilers, and focuses on the harm done to others, not technology.  Such a method automatically allows users to have relatively smoky burners if they are far from neighbors, but requires cleaner burning in denser areas, which is consistent with almost everything else in the continuum of rural/urban life.

Here in Oregon, the state pioneered the use of annoying, restrictive legislation on emissions, which covered the entire state, though pollution was a problem in a few geographically distinct areas.  This raised the costs for everyone (to the extent that the law is actually obeyed), while benefiting only the people in sensitive areas.  Of course, the EPA liked this concept, and now similar restrictions are in effect nation-wide.  Since most of America's poor live in rural areas, fuel is cheap in rural areas, and smog is unusual, the burden of the regulations hit hardest where cheap woodstoves are most needed, and where emission control is least useful.  The difference between a new $1000 stove and a used, $200 stove is far from academic for some people.  The higher efficiencies will never offset this difference in many cases, since there are so many sources of free or nearly free fuel.

In my opinion, laws shouldn't impose a burden on anyone who isn't causing harm.  Smoke is a public nuisance only if it bothers someone, and should be dealt with case-by-case.  Emissions are more cumulative, so restrictions will need to cover everyone in a smog-prone area, but people outside such areas should be exempt.

Without emission controls on stoves, no one can burn clean

From John at woodheat.org

Robert makes a good case based on the logical 'polluter pays' principle and we agree that banning of particular stoves is dumb. But we think there is clear evidence that mandatory emission controls like the ones EPA uses are the best solution for users, their neighbors and the environment. Here's why:

1. You cannot burn wood efficiently and with low smoke emissions in a stove with no combustion system.
2. Without a regulation, manufacturers cannot develop and produce stoves with good combustion systems because their price would be undercut by competitors building simpler stoves.
3. The stoves that meet the EPA rules are about one-third more efficient than the conventional stoves that we would all still be using without EPA's intervention. That saves us all a huge amount of work and/or money and leaves a lot of trees still standing.
4. In an unregulated environment manufacturers can say anything they like about their product's performance and no one can challenge them. The outdoor boiler industry (which is unregulated) provides adequate proof of this and also demonstrates that technical progress will not occur without an even regulatory playing field.
5. In times of shrinking government and deregulation, there is little or no likelihood that governments will regulate with "smoke cops". It just costs way too much and creates constant friction between government and the public and endless court battles. The EPA regulation is national, effective, and cheap to maintain.
6. The incremental cost of adding a competent combustion system to a stove is only $100 to $200, which is small compared to the performance advantages and fuel savings. Low income people can still buy inexpensive used stoves.