WOOD STOVE CHANGEOUT PROGRAMS AS SEPs

1
WOOD STOVE CHANGEOUT PROGRAMS AS SEPs

• Presentation by
• Hearth, Patio Barbecue Association (HPBA)
• NCAF 2006 Energy Programs Leveraging Conference
• October 24-26, 2006
• St. Petersburg, FL

2
PURPOSE

• Describe an opportunity for leveraging your
  resources to obtain additional funding to better
  serve low-income households
• Propose ways to be pro-active
• Offer to help

3
TOPICS TO BE COVERED

• SEPs
• Wood stove changeout programs
• Weatherization assistance community
• Concept for WAP-based, wood stove SEPs
• Ways to be pro-active
• HPBA support

4
SEPs

• SEPs Supplemental Environmental Projects
• Context Enforcement of environmental laws by
  EPA and agencies at the state, local, tribal and
  territorial levels
• Negotiated settlements, resulting in consent
  decrees
• Remedial measures
• Voluntary mitigation measures, including SEPs
• Penalties, which are set partly in light of the
  SEPs
• Elaborate policies at federal and state levels
  about acceptability of projects as SEPs (e.g.,
  EPA has detailed website)

5
SEPs

• Recent examples
• Toyota
• Alleged Clean Air Act violations
• 20MM for retrofitting controls on tailpipe
  emissions from diesel engines in school buses
• ADM
• Alleged Clean Air Act violations
• 4MM for school bus retrofits in Midwest

6
SEPs

• Potential settlements
• Electric utilities in eastern half of country who
  have yet to settle EPAs Clean Air Act lawsuits
  for large plant refurbishments
• Steady stream of settlements at federal and
  non-federal level, mainly relating to air
  pollution

7
HPBA Expertise onWOOD STOVE CHANGEOUT PROGRAMS

• Wood stove residential home heating appliance
  burning cord wood or pellets, either
  free-standing or as fireplace insert
• Conventional wood stoves
• Sales prior to EPA promulgation of NSPS in 1988
• At least 7.5 million nationwide
• Long-lasting little incentive for replacement
• Modern wood stoves burn much more cleanly and
  efficiently (e.g., 70 percent reduction in fine
  particulates)
• 300,000 tons per year from nationwide changeout

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WOOD STOVE CHANGEOUT PROGRAMS

• Definition of target community
• Outreach
• Incentives
• Application procedures
• On-site inspection
• Installation
• Education on good usage
• Disposal of old appliance
• Quality control
• Accounting

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WOOD STOVE CHANGEOUT PROGRAMS

• Extensive HPBA experience, for example
• Crested Butte, CO 1988 1990
• Libby, MT June, 2005 ONGOING
• Sacramento, CA September, 2006 ONGOING
• EPA promotion
• Effective group in EPAs RTP office (stationary
  sources of air pollution)
• Outreach, technical assistance, grant program,
  etc.
• Website http//www.epa.gov/woodstoves/changeout.h
  tml
• EPA enforcement lists such changeout programs as
  viable SEP candidates

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WEATHERIZATION ASSISTANCE COMMUNITY

• 900 local organizations
• Serve 100,000 low-income families per year
• Well-suited to manage wood stove changeout
  programs
• Experience, expertise, reliability
• Ability to incorporate wood stove changeouts into
  the assistance packages for households if the
  wood stoves are cost-free

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CONCEPT FOR A TURN-KEY SEP

• The defendant enters into a grant agreement with
  a WAP provider to provide cash for EPA-certified
  wood stoves or actual wood stoves.
• The WAP provider agrees to conduct a changeout
  program in low-income homes in the course of
  installing other energy efficiency measures.
• The WAP provider would generate all necessary
  accountings.

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ADVANTAGES

• Significant reduction in air pollution
• Energy savings
• Improved home safety
• Maximum leverage of SEP dollar (e.g., low costs
  of administration)
• Reliability and accountability
• Minimal hassle for defendant
• Maximum insulation for defendant from potential
  liabilities due to installations

13
PUBLICIZING THE CONCEPT

• Open Letter to the environmental enforcement
  community from NCAF and HPBA
• Dissemination of Open Letter
• Lobby EPA and DOJ
• Mailings to EPA regional offices and non-federal
  agencies
• Direct contacts to environmental defense bar
• Press
• Posting on websites
• EPAs wood stove website
• HPBAs website

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WAYS TO BE PRO-ACTIVE

• Build infrastructure, for instance
• Model grant agreement
• How-to-do-it manual for changeout programs
  (general version on EPAs website)
• Alert non-federal enforcement officials to the
  opportunity
• Encourage federal and state WAP officials to
  support

15
HELP FROM HPBA

• Offer to help
• Each SEP will have its own set of locally
  determined needs
• Technical consultation on full range of changeout
  issues
• Networking with vendors and installers
• Training for and certification of installers
• Drafting of model legal documents

16
THANK YOU!
Contact John Crouch Director of Public
Affairs [phone] john.crouch.hpba_at_sbcglobal.
net
W. Allan Cagnoli Director of Government
Affairs [phone] cagnoli_at_hpba.org