WESTAR Comments on EPA’s Review of Residential Wood Heating New Source Performance Standards

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On October 11, 2024, WESTAR submitted comments to EPA’s docket regarding their Section 610 review of New Source Performance Standards (NSPS) for New Residential Wood Heaters, New Residential Hydronic Heaters and Forced-Air Furnaces, collectively know as residential wood heating devices. As part of their NSPS review, EPA is soliciting comments on: (1) The continued need for the rule; (2) the nature of complaints or comments received concerning the rule; (3) the complexity of the rule; (4) the extent to which the rule overlaps, duplicates, or conflicts with other Federal, State, or local government rules; and (5) the degree to which the technology, economic conditions or other factors have changed in the area affected by the rule. WESTAR provided comment in areas 1, 2, and 5.

WESTAR Comments on Potential Regional Haze Rule Revisions

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In July, WESTAR submitted comments to EPA’s non-regulatory docket seeking input on potential revisions to the Regional Haze rule. WESTAR recommended changes to the connection between reasonable progress and Long-term strategies, more efficient ways to evaluate source controls, a clearer role for the Uniform Rate of Progress line and Natural Conditions, and improvements to the modeling and monitoring requirements. WESTAR also recommended that EPA extend the deadline for third-round SIPs by three years to allow time to complete the rule revisions and for states to fully incorporate those revisions into their planning.

Arizona, Colorado, Utah, and Wyoming send letter to President Biden on Ozone

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On April 23rd, 2024 the governors from Arizona, Colorado, Utah, and Wyoming sent a letter to President Biden to raise concerns about attaining the 2015 8-hour Ozone National Ambient Air Quality Standard.

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WESTAR Comments – Large Municipal Waste Combustors

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On March 25, 2024, WESTAR submitted a comment letter to EPA on their proposed rule regarding large municipal waste combustors. WESTAR commented specifically in favor of the proposal to exclude air curtain incinerators from Title V requirements when they are used to burn wood waste, yard waste, and clean lumber and are not located at a major source or subject to title V for other reasons.

WESTAR Comment Letter – Multi-Pollutant Emissions Standards for Light-Duty and Medium-Duty Vehicles

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On July 5, 2023, WESTAR submitted a comment letter to EPA on the proposed rule to reduce GHG and criteria pollutants from model year 2027 and later light-duty and medium-duty vehicles.

WESTAR Comments on EPA’s PM NAAQS Proposal

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WESTAR Comments on EPA’s Supplemental Proposal on Methane

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On February 13, 2023, WESTAR submitted comments to EPA on the supplemental notice of proposed rulemaking: “Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review”, published in the Federal Register on December 6, 2022. This supplemental proposal is extensive and, if finalized, would update, strengthen, and expand the methane gas standards that affect oil and gas operations. WESTAR states shared their perspectives on how this proposed rule relates to and/or affects meaningful engagement, EPA’s ambitious regulatory agenda for 2022/2023, funding concerns, and resource constraints. The rule proposes several elements, including a “super-emitter response program” that western states, locals, and Tribes need further clarification on from EPA, knowing that this program, in particular, trends away from the usual delegation of authority to the state, local, or Tribal air agencies that the Clean Air Act is built on. For more information, see the rulemaking docket, found here.

WESTAR comment letter on EPA supplement to proposed Standards of Performance for Oil and Natural Gas–February 2023

WESTAR Comments to EPA on IRA

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WESTAR submitted two comment letters to EPA on IRA docket questions on January 19, 2023. The first responded to overall questions about the IRA funds. WESTAR encouraged EPA to utilize established pathways for regional coordination and communications between western state, Tribal, and local air agencies that exist at WESTAR. WESTAR also encouraged EPA to provide additional technical assistance and training, especially when most state agencies are understaffed. Finally, WESTAR encouraged EPA to consider the geographic obstacles to reaching communities in the west; there are additional costs for travel and time associated with reaching disadvantaged, rural communities in the west. These additional costs must be factored into funding. There are also communications challenges in areas of the west where broadband internet access is unavailable.

WESTAR’s second letter addressed IRA docket questions related to residential wood heating. WESTAR supports funding for independent testing of wood heating devices in certified laboratories using newer test methods. This independent testing would supplement EPA’s current certification program, which has relied on testing results that haven’t been reproducible in other labs. The need for transparency in test results is more important with EPA’s proposal for a more stringent PM2.5 NAAQS; additional counties in the west could be nonattainment for fine particulate matter if the proposal is finalized. This will lead states to analyze wood heating emissions possibly contributing to nonattainment in the rural west and needing data to determine the potential effectiveness of change-out programs.

WESTAR IRA Wood Heater Testing letter–January 2023

WESTAR IRA Docket Questions letter–January 2023