What's Our Plan?
EPA Seeks Small Business Input
(Correspondence most recent first)
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from: Power.Lucinda@epamail.epa.gov to: buckley1035@gmail.com date: Wed, May 19, 2010 at 11:29 AM subject: Small Business Advocacy Review Panel for Revision of New Source Performance Standards for New Residential Wood Heaters Good afternoon, Thank you for your interest in serving as a potential Small Entity Representative (SER) for the Revision of New Source Performance Standards for New Residential Wood Heaters Small Advocacy Review (SBAR) Panel. A SER's participation in the rulemaking process will ensure that EPA hears small entity concerns. EPA, in consultation with the Office of Management and Budget and the Small Business Administration, will be reviewing the list of nominations over the next couple weeks. You will receive a confirmation of your participation as a SER by no later than June 11, 2010.
Lucinda P. Power "Be the change you wish to see in the world" - Gandhi
from: Jim Buckley to: RFA-SBREFA@epa.gov date: Sun, May 16, 2010 at 10:37 PM subject: NSPS for New Residentail Wood Heaters To whom it may concern: I would like to participate as a Small Entity Representative for the New Source Performance Standards (NSPS) for new residential wood heaters, wood stoves and fireplaces which is anticipated to be promulgated in 2011. I am chair of the masonry fireplace task group ASTM E06.54.07 that developed the test method E2558 used to test fireplace emissions. I have also been selected by the Clay Flue Lining Institute to represent clay flue lining manufacturers to the EPA. We are a diverse industry. While they each contribute to the construction of a masonry fireplace, there is little similarity in size and the way they do business between a manufacturing plant that makes brick, clay flues or firebrick, a dealer (among hundreds of dealers) that sells many different masonry products and a mason contractor (among thousands of masonry contractors) who actually builds a masonry fireplace with components manufactured by as many as ten different manufacturers. Gill Wood, EPA, has expressed his wish to have but one person represent the entire masonry fireplace industry but I think the masonry industry should be represented by at least four people - a brick manufacturer, a clay flue manufacturer, a firebrick manufacturer and a mason contractor. Knowing that four people representing the industry may not be selected, my recommendations in order of preference are:
Chip Clark, representing the entire masonry industry (especially brick manufacturers)
Warm regards, --
Jim Buckley
from: Chip Clark to: "Robert A. Rucker" date: Fri, May 14, 2010 subject: FW: NSPS for New Residentail Wood Heaters Below is my application to be on the panel. Chip Clark Charles B. Clark, Jr., AIA, PE, LEED AP Vice President of Engineering Services Brick Industry Association 1850 Centennial Park Drive, Suite 301 Reston, VA 20191-1542
Direct: 703-674-1531
From: Chip Clark To whom it may concern: I am interested in participating as a Small Entity Representative for the New Source Performance Standards (NSPS) for new residential wood heaters, wood stoves and fireplaces which is anticipated to be promulgated in 2011. I am well-versed in the implications of such regulations in regard to the masonry fireplace industry and the parties affected which include residential masons and component manufacturers. I have been involved with the design, construction and testing of masonry fireplaces for over 12 years. As an active member of the Masonry Alliance for Codes and Standards, I have represented the masonry fireplace industry at the International Code Council deliberations on the masonry fireplace provisions in the International Residential Code and the International Building Code since their inception in the year 2000. I am the primary BIA staff contact for fireplace and masonry heater issues. The Brick Industry Association maintains and promotes masonry fireplace construction through our BIA Technical Notes on Brick Construction series. The following six (6) Technical Notes specifically address masonry fireplaces and masonry heaters and are available on our website www.gobrick.com: Technical Note 19 Residential Fireplace Design http://www.gobrick.com/BIA/technotes/t19.htm Technical Note 19A Residential Fireplaces - Details and Construction http://www.gobrick.com/BIA/technotes/t19a.htm Technical Note 19B Residential Chimneys - Design and Construction http://www.gobrick.com/BIA/technotes/t19b.htm Technical Note 19C Contemporary Brick Masonry Fireplaces http://www.gobrick.com/BIA/technotes/TechNote19COct2001scan.pdf Technical Note 19D Brick Masonry Fireplaces, Part I, Russian-Style Heaters http://www.gobrick.com/BIA/technotes/t19d.htm Technical Note 19E Brick Masonry Fireplaces, Part 2 - Fountain and Contemporary Style Heaters http://www.gobrick.com/BIA/technotes/t19e.htm Chip Clark
Charles B. Clark, Jr., AIA, PE, LEED AP
----- Original Message ----- From: Robert A. Rucker To: RFA-SBREFA@epa.gov Sent: Friday, May 14, 2010 11:52 AM Subject: Small Business Advocacy Panel regarding emissions from wood heat sources To whom it may concern: We are the Clay Flue Lining Institute, P.O. Box 465, Malvern, Ohio 44644.. We represent the interests of member manufacturing companies including thousands of employees and many millions of dollars in clay products for site built masonry fireplace and chimney construction as well as many related goods and services produced in the US of A. We are aware of three names of people who have applied to serve on a Small Business Advocacy Panel for the purpose of discussion regarding the subject of emissions related to site built masonry fireplace and chimneys. The names are Chip Clark affiliated with the Brick Industry Association,Reston, Virginia. Colby Dehoff affiliated with a firebrick manufacturer, Whitacre-Greer of Alliance, Ohio Jim Buckley, Buckley Rumford Co., and affiliated with a clay flue manufacturer, Superior Clay, Uhrichsville, Ohio We are aware of their dedicated service to the masonry industry, and endorse their application to serve on the Small Business Advocacy Panel.. Thank you for this opportunity and please call if any specific questions.
Sincerely,
May 12
Jeff Buczkiewicz
Jim,
We are working on getting a contractor. I believe it will run down to the wire, but I have been working with Chip on the issue. I just wanted to keep you informed. Talk to you soon.
Discussions continue and just want to clarify a couple of things since my last e-mail 5/12/10 below...
The CFLI unanimously endorses Jim Buckley to represent our collective interests (as per my couple of paragraphs below) as the (EPA described) small entity representative.. We believe that Chip and Colby have already applied and fully endorse their participation as well.
Also for purposes of clarification,the referenced EPA website under "Who should I contact" clearly calls for self application or self nomination and therefore those applying need to make the application themselves. The deadline for application is today 5/14/10..I am sure that it would be of some positive support if we were all to send an e-mail to the address mentioned simply endorsing the three names mentioned, and of course if anyone else is interested in serving please step forward in the process.
Please advise if any question.
Thank you!
All,
The deadline to nominate representatives of the masonry fireplace industry to participate in the Small Business Advocacy Review Panel that the EPA is required to convene is this Friday, May 14, 2010.
Instructions for nominating people are on the EPA webstie at http://www.epa.gov/sbrefa/woodheaters.htm
Our research indicates that about 50,000 masonry fireplaces were built in 2009 and more than 80,000 were built each year in the "good years" from 2000 until 2007.
We are a diverse industry. While they each contribute to the construction of a masonry fireplace, there is little similarity in size and the way they do business between a manufacturing plant that makes brick, clay flues or firebrick, a dealer (among hundreds of dealers) that sells many different masonry products and a mason contractor (among thousands of masonry contractors) who actually builds a masonry fireplace with components manufactured by as many as ten different manufacturers.
Gill Wood has expressed his wish to have but one person represent the entire masonry fireplace industry but I think we should nominate at least four - a brick manufacturer, a clay flue manufacturer, a firebrick manufacturer and a mason contractor. We may have to rely on an association staff person, like Chip Clark, to represent brick manufacturers and someone from the Mason Contractors Association of America, like Jeff Buczkiewicz, to represent masons but I think we can get actual representatives from the firebrick and flue liner manufacturers.
Can we call each other and decide who to nominate? If we all nominate the same four or five people they would probably be more likely to be selected. My recommendations would be Chip Clark, Colby Dehoff, a clay flue manufacturer selected by CFLI and a mason contractor selected by the MCAA.
Warm regards,
On Wed, May 5, 2010 at 5:42 AM,
Response from Gill Wood, EPA
5/5/10
from: Wood.Gil@epamail.epa.gov
Jim and All,
Yes, it would be very good for the various entities to get together to
select an overall representative to nominate to be on the panel. As a
placeholder, with the suggestion of HPBA, I have tentatively reserved a
place for Chip Clark. (In fact, I have a conversation scheduled for
later today with Chip and Susan Miller.) Although the press brief is
very brief and emphasizes wood stoves, EPA's efforts are definitely
considering devices such as masonry fireplaces (and masonry heaters and
indoor furnaces and outdoor furnaces, etc.). There will be practical
(logistical) limitations on the total number of people on the panel so
nominating one representative for masonry fireplaces would be preferred.
Thanks,
Additional info is at: http://www.epa.gov/sbrefa/woodheaters.htm
5/4/10
Colby,
Thank you. I notice that the EPA press release you attached focusses mostly on wood stoves but at the end it includes this: "The revisions could include improved regulation of wood heaters, along with new regulation of other residential devices that use solid biomass fuels."
We have heard that the EPA intends to include fireplaces in the NSPS regulation as early as next year so I don't think we can afford to sit back and not be included. I have recently emailled Gill Wood (EPA), Chip Clark (BIA) and John Crouch (HPBA) about inclusion in the EPA assessment of the NSPS regulations on small business in the masonry fireplace industry. I will send you copies of my email messages.
The EPA is asking for nominations of people to represent us and has set a deadline of May 14, 2010. Maybe we should decide who would best represent the masonry industry. Suggestions have included a flue liner or firebrick manufacturer selected by the CFLI, a brick or block manufacturer selected by the BIA or NCMA and maybe a mason contractor or representative selected by MCAA. I think we should talk about our choices and respond directly to the EPA either as individual small businesses or through the CFLI and BIA - or both. And soon.
Best,
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