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1.There exists no scientifically based evidence that EPA stoves are better than
conventional wood heating appliances used at present.
3. CONCERNS - Legal Consequences : If the Impact assessment has failed to take into account
the concentrations increased in areas where the density of populations is adversely affected by wood smoke
exposure. This Project prevents citizens in all areas however especially in urban densely populated areas
from their rightful enjoyment of life. Smoke concentrations in relation to potential contradicts the reality of
what populations endure and suffer. Epidemiological studies, data sufficient assessment exists to establish
the loss of health in exposure risks to populations in urban areas and densely populated rural areas where
populations are affected by wood smoke.. This Project fails to adequately protect citizens and fails to
ensure that vulnerable populations are not placed at critical risk. Smoke contaminated areas are proven to
produce severe increase in death and disease. Avoiding life-threatening issues causing death suggests legal
negligence. Failure to ensure air does constitute a violation of the Canadian Charter of Rights and
Freedoms. As such, we maintain that the Project is illegal and clearly involves negating the obligatory
conditions of the Ministry, MDDEP and does constitute breech of trust in policy makers. Failure to ensure air
that is safe is failure to provide essential to life. The project in its present form is evidence of failure to
provide citizen’s access to smoke free air and encouraging carcinogenic dioxin and smoke life threatening
air entails life threatening pollution smoke fumes EPA Source 4 - 1996 Comments on Actual-to-future-
actual Emissions released.
6.We acknowledge that emissions are presently endangering our lives and the lives of
infants and the yet unborn. The Projet, as proposed ,will be a cause of immensely
increasing exposure to emissions and impact increasing above the national standard for
which provinces and utilities have indicated their support. This Projet de Chauffage,
which is in Public Consultation until June 23, the eve of Quebec National Holiday, would
as a result negatively impact the environment and hinder the Government of Canada's
objectives of reducing CO2 emissions and avoid achieving cost savings for energy users
and above all place Quebec citizens, especially children in harms way.
7.The Projet de Chauffage does nothing to assist citizens suffering from health
consequences of smoke exposure. The Projet in its entirety is a proposal that supports
industry profits. With all research based on no-scientific testimony, and the evidence of
well-established information industry driven misguided message from the wood stove
remains to be legally challenged. The implementation of the proposed amendment will
prove to adversely impact global warming and will contribute adversely to the health of
all citizens. The project entirely avoids the issue of smoke risks to which children are the
most vulnerable. In view of the thousands of studies on health risks to children, we ask
what responsible leadership would propose policy that would condemn children to
steadily breathing smoke? This policy places children and all citizens in harms way and
at critical unjustifiable risk. In view of the independent research on EPA stoves emitting
400% more dioxin and deadly furans along with millions of dangerous chemicals and
carcinogens into the air, in view of Breast Cancer and dioxin epidemiological studies, we
ask what could justify the harmful effects of such irresponsible legislation? [ Reference to
be forwarded -Research to be tabled on web site www.citizensfeh.com]
8.Given the real state of no scientific proof of reduction emissions from EPA stoves,
we maintain that if consumers are adequately informed of the health effects , the lack
of efficiency and the pollution caused by wood stoves and facts about the equally
polluting EPA Certified stoves and inserts, the market will gradually shift in favour of
more efficient alternative products such as gas or electricity. We cannot afford to wait
for the cultural awareness .It is our obligation to ensure public protection from
emissions that result from long term and short term exposure( Se report Dr.Vincent
Health Canada, 2005)
9.Amendments must be made on all wood stove appliances to reflect truthful facts
on emissions and comparisonws with other alternatives.. Industry driven material and
conclusions are contradicted by scientific independent studies and official reviews
[ Intertec and others Attached]. The lack of verification and the jointly established
conceptual will to adopt industry a consensus, within the established spokes people for
the MDDEP, blind faith policy denies what reasonable minimum inspection of industry
based publications and studies should be. The implementation of the proposed so called
regulation, as is will provide a benefit to outdated economics of pollution.(Not
comprehensible).
12. The lack of facts about the true total of emissions, the non disclosure of danger
to the consumer in interior and exterior exposure of emissions and the lack of science
based evidence of standardized performance information that is included product
brochures and at the point of sale material is an adoption of misleading information that
will only serve the economic interests and the determination and desirability of the stove
industry and political imaging. The matter should be subject to the Competition Bureau,
the federal consumer protection bureau. In view of the existing problem with wood stoves
and the life durability of thirty years, consequently the Regulation de Chauffage is
explicitly eliminating no old equally polluting stoves or products nor any toxic carbon
pollution. Given that there exists a lack of assessment of any impact, with no quantitative
analysis of impact of the Projet , without doubt, no proof of benefits nor economic costs
can be made. Lack of any guarantees, the policy is based on what would be nice, wishes,
myths, not facts.
13.Various internal and external studies have verified that EPA Stoves result in
increased carcinogens or emissions and no benefits of energy-efficiency can be
attributed to the change out or adoption of EPA Certified stoves.( INTERTEC AND
FEDERAL REGISTERED DOCUMENTS) Will Forward Appendix.
POINT 1:
Impact assessment has failed to take into account the concentrations increased in areas where the density
of populations is adversely affected by wood smoke exposure. This Project prevents citizens in all areas
however especially in urban densely populated areas from their rightful enjoyment of life. Smoke
concentrations in relation to potential contradicts the reality of what populations endure and suffer.
Epidemiological studies, data sufficient assessment exists to establish the loss of health in exposure risks
to populations in urban areas and densely populated rural areas where populations are affected by wood
smoke.. This Project fails to adequately protect citizens and fails to ensure that vulnerable populations are
not placed at critical risk. Smoke contaminated areas are proven to produce severe increase in death and
disease. Avoiding life-threatening issues causing death suggests legal negligence. Failure to ensure air does
constitute a violation of the Canadian Charter of Rights and Freedoms. As such, we maintain that the Project
is illegal and clearly involves negating the obligatory conditions of the Ministry, MDDEP and does constitute
breech of trust in policy makers. Failure to ensure air that is safe is failure to provide essential to life. The
project in its present form is evidence of failure to provide citizen’s access to smoke free air and encouraging
carcinogenic dioxin and smoke life threatening air entails life threatening pollution smoke fumes EPA
Source 4 - 1996 Comments on Actual-to-future-actual Methodology
Several commenters (IV-D-38, 140, 143, 146, 160) opposed the actual-to-potential
test
because it does not exempt emission increases due to demand growth or increased
utilization,
which they viewed as unfair and contrary to the statute and case law. One
commenter (IV-D-
146) stated that EPA’s analysis of the current requirements is inconsistent with both
the current
regulatory language, and prior court decisions. According to the commenter, the
overly broad
capacity without any increase in the rate of total amount of allowable emissions,
merely because
and/or deterioration of its production equipment. In the view of the commenter, the
Agency’s
proposal to further limit the long-standing exclusion for such activities is unjustified
and
unreasonable, and provides none of the relief sought by State program officials and
industry
One commenter (IV-D-160) stated that in many cases, the application of the actual-
to-potential
test is inconsistent with the CAA, as well as the existing NSR regulations. The
statute
emissions.
The key findings of the review included: (1) The NSPS certification procedure
only qualitatively predicts the level of emissions from wood heaters under
actual use in homes, (2) Wood stove durability varies with model and a
method to assess the durability problem is controversial, (3) Nationally the
overwhelming majority of RWC air emissions are from non-certified devices
(primarily from older non-certified woodstoves), (4) New technology
appliances and fuel can reduce emissions significantly….(See CAN as
research proves in labs only NOT in home heating conditions. l [ INSERT
FROM HOST “ CAN not DO (NOTE IN LABS ONLY, Not in Home Resedential
Burning SEE DOC----------------------------------------------------------------------------
), (5) The ISO and EPA NSPS test procedures are quite dissimilar and data
generated by the two procedures would not be comparable, and, (6) The
effect of wood moisture and wood type on particulate emission appears to be
real but to be less than an order of magnitude.
EXECUTIVE SUMMARY
Wood stoves are designed out of necessity to pass the EPA certification test.
It is generally recognized the these tests do not simulate the way that a stove is used
in the “real world.” Consequently, emission results obtained from certification tests are
only roughly predictive of how a wood stove will perform under actual in-home use.
However, the general perception is that stoves that show low emissions in the
certification testing will also do well in homes. The current status of stove efficiencies is
difficult to assess since, while there is an efficiency test method published in the Federal
Register, efficiency testing is not required during the certification process.
1. INTRODUCTION
Two key issues that continue to be of concern are (1) that the
emission control performance of wood stoves operated in homes
does not match laboratory certification results, and (2) that inhome
emission control performance for some stoves becomes poorer over
time. Other unresolved issues include how fuel moisture and fuel
wood effect emissions, the efficacy of, and relationships between
test methodologies, and the effectiveness and feasibility of routine
appliance maintenance for reducing emissions. The difficulty in resolving or
quantifying cause-and-effect relationships for these issues as well as for
other RWC questions is due to the large number of interrelated variables
associated with RWC. There are many hundreds of types and models of wood
burning devices in use, many dozens of tree species are commonly used for
wood fuel, draft characteristics vary (e.g., chimney and temperature
conditions), household altitude is variable, there are variations in fuel wood
seasoning and storage practices (i.e., wood moisture) and there are wide
variations in the operation of wood burning devices (e.g., burn rate, burn
duration, damper setting, kindling approach). A review of the current states-
of-the-art of residential wood combustion (RWC) was conducted. The key
environmental parameter of concern was the air emission of particles. The
technological status of all major RWC categories was reviewed. These were
cordwood stoves, fireplaces, masonry heaters, pellet stoves, and wood-fired
central heating furnaces. Advances in technology achieved since the mid-
1980's were the primary focus. These study objectives were accomplished by
reviewing the published literature and by interviewing nationally recognized
RWC experts.
The key findings of the review included: (1) The NSPS certification procedure
only qualitatively predicts the level of emissions from wood heaters under
actual use in homes, (2) Wood stove durability varies with model and a
method to assess the durability problem is controversial, (3) Nationally the
overwhelming majority of RWC air emissions are from non-certified devices
(primarily from older non-certified woodstoves), (4) New technology
appliances and fuels can reduce emissions significantly.
), (5) The ISO and EPA NSPS test procedures are quite dissimilar and data
generated by the two procedures would not be comparable, and, (6) The
effect of wood moisture and wood type on particulate emission appears to be
real but to be less than an order of magnitude
QUOTATION
“In most cases the repair of a catalyst bypass system needs to be performed
at the manufacturer’s facility. Another minor problem common to both
catalytic and non-catalytic stoves, is the deterioration of the fuel loading door
gasket material causing leaks and commensurate excess combustion air.”
National Risk Management , EPA –600/R-98-174a, December 1998 May 31, 2008
Michael Goulet
Chef de L'Environnement et des Parcs
Edifice Marie-Guyart, 675 Boulevard Rene Levesque Est
6e etage, Boite 30
Quebec, Quebec, G1R 5V7
Where there is wood smoke, there is grave danger to our health and our life.
Wood smoke emissions affect the air we all have to breathe, our quality of
life, our health, and our constitutional right to be able to enjoy our property
without the noxious and deadly emissions from a neighbor's wood smoke.
Outdoor wood boilers (OWB), chimneys, outdoor wood burning fire pits and
fireplaces, and indoor wood burning fireplaces caused residents, neighbors,
visitors, and families to involuntarily breathe wood smoke emissions. Any
burning of wood is harmful and deadly to all us.
If Quebec formally adopts Projet de Chauffage, it will greatly expand the
deadly effects of wood smoke emissions in all Quebec communities and
throughout Canada. Residents will be assaulted with tons of wood smoke
emissions. In addition to the devastating air and environmental negative
effects, children/people will suffer because they will be involuntarily breathing
wood smoke emissions.
Wood smoke emissions are a worldwide health issue. Quebec and Canadian
residents-just like Americans-want their air to be free of the unneeded and
unnecessary wood smoke emissions. People shouldn't have to pray for a
breath of air-unpolluted by wood smoke.
The Breathe Healthy Air Coalition is against the proposed Quebec law-Projet
de Chauffage-because it will: pollute the air, land, and water, negatively
affect the quality of life and health of those who involuntarily breathe the
deadly wood smoke emissions, violate private and public nuisance laws, and
wood smoke breaks the unwritten, but understood "good neighbor policy"
where one does no harm to another neighbor by their actions.
Recently, I read a “letter to the editor” that appeared in a Canadian
newspaper written by a resident who said, “…the stench of (wood) smoke fills
my home. It seeps through windows and vents, and my family suffers from
respiratory symptoms due to the constant exposure to airborne particles
emanating from the burning wood. No government regulations seem to
protect urban citizens from the smoke pollution caused by a neighbour. No
one should be forced to inhale smoke. Provisions against smoke exposure are
provided for public areas and workplaces, so why not residential areas?”
It is our sincere hope that the people and elected officials of Quebec will
stand up and say..."NO” to the proposed Quebec law-Projet de Chauffage.
The Breathe Healthy Air Coalition cares about the lives of Quebec residents
that will be gravely affected by this proposed law—Projet de Chauffage.
Sincerely,
I ,Stella Haley and in support of the citizens who have signed these
two petitions, { See Petitions: Attached} state that we at Citizens
for Environmental Health
Sincerely,
C. carol.gagne@mddep.gouv.qc.ca