# The EPA and conventional Outside Wood Boilers?



## fabguy01 (Jun 9, 2009)

With all the new EPA stuff going on in the world off wood burning the word on the street is that they are going to ban the sale, manufacture, and install of the "old school" wood boilers. Can anyone here confirm this?
The main reason I ask is that there is a local manufacture here that this would affect badly in michigans already crappy economy.


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## Como (Jun 12, 2009)

I think it is a State issue.

Colorado is talking about it, can only be a question of time.

Tell him to manufacture something more suitable for this century.


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## stee6043 (Jun 12, 2009)

I bet if anything does come down it will be limited to more "densely" populated areas.  It doesn't make much sense to burn an OWB if your closest neighbor is 100 feet away.  Get out of the cities and suburbs and it seems to be less of an issue.

As I've poured over posts and articles on OWB's both here in Michigan and elsewhere it really seems to always come down to how they are used.  With good wood and proper use an OWB can burn very clean.  Maybe the EPA's solution will be the development of some strict rules on how to use a wood boiler and what can/cannot be burned in them.  No doubt strict fines would be involved for all violaters.  I'm not sure this is a real solution to anything but it sure seems to make more sense to me than an all-out ban.  I've got friends that burn outdoor Classic units that do it right and they produce very little smoke.  They shouldn't be penalized for the actions of the other guys burning trash and tires in their OWB's....


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## fabguy01 (Jun 12, 2009)

Durango said:
			
		

> I think it is a State issue.
> 
> Colorado is talking about it, can only be a question of time.
> 
> Tell him to manufacture something more suitable for this century.


Yea I've mentioned that to him, but with the economy being what it is, his bigest selling point is his price and he just cant produce anything for near the same price. his boilers start at $3,500 and he has 3 different sizes that add $1,000 per size. :coolsmirk:


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## Delta-T (Jun 12, 2009)

stee6043 said:
			
		

> I bet if anything does come down it will be limited to more "densely" populated areas.  It doesn't make much sense to burn an OWB if your closest neighbor is 100 feet away.  Get out of the cities and suburbs and it seems to be less of an issue.
> 
> As I've poured over posts and articles on OWB's both here in Michigan and elsewhere it really seems to always come down to how they are used.  With good wood and proper use an OWB can burn very clean.  Maybe the EPA's solution will be the development of some strict rules on how to use a wood boiler and what can/cannot be burned in them.  No doubt strict fines would be involved for all violaters.  I'm not sure this is a real solution to anything but it sure seems to make more sense to me than an all-out ban.  I've got friends that burn outdoor Classic units that do it right and they produce very little smoke.  They shouldn't be penalized for the actions of the other guys burning trash and tires in their OWB's....



Unfortunately I think we'll see the OWB go the way of the Dodo because of the same said peeps who burn tires and trash. Fines for stupidity only work if someone around to catch you and hand you a ticket. Case in point: Littering...we have steep fines in place for those who throw trash on the ground, yet, if you drive along any road, there is trash. If we had a way to actually collect on these things our towns and states would be super wealthy. We may not see broad band prohibition of OWB, but we'll see silly installation requirements like 40' radius of non-combustable material, chimney not less than 2times the height of your house but not more than 1.5 times the height of your neighbors house, burning only on odd days between May 15th and Oct 8th. .......ect. It is the American way to punish the many for the actions of the few.


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## Chris Hoskin (Jun 12, 2009)

The biggest problem with the traditional OWB is that it is inherently inefficient. Inefficient means dirty burning so I would suggest that ultimately emissions regulations will be the death knell.  

The huge firebox is (essentially) completely surrounded by water and the boilers are normally grossly over-sized.  How many residential applications can use a 300k+ BTU boiler?

In order to get a clean efficient burn, wood needs to burn intensely and at high temperature - upwards of 1800+ degrees.  The water surrounding the firebox in a traditional OWB is a relatively cool 160 to 180 degrees which never allows these high temperatures to be reached.  Add to this the gross over-sizing and the boiler operates in a perpetual smolder phase.  As with any wood boiler heat storage can address this issue, but does not seem to be part of the OWB Way.  Gasifiers get such high efficiency because the secondary burn chamber is refractory lined, not water jacketed, and the heat is not sucked out of the fire until AFTER that secondary burn.  Add storage for the ideal set-up.

To their credit, several OWB manufacturers are developing gasification-type boilers and I am sure that these are/will burn much more cleanly and efficiently than the traditional style.  Just like when EPA mandated emissions standards for woodstoves back in the late 1980's some companies will exit the industry and those who innovate will survive.  The next challenge for the OWB industry will be to get regulators to understand that these 'new' type boilers are not the same old smudge pots so installation restrictions should be relaxed.  

The next generation of OWB will require nice dry firewood just like any efficient wood burner, so the days of garbage, tires, wet wood and deer carcasses being burned will go away too.  You still won't be able to load fuel in your slippers though!


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## ihookem (Jun 13, 2009)

You forgot dead calfs


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## heaterman (Jun 13, 2009)

A single stage fire such as found in a typical OWB will never be clean or efficient. Mr Bio-heat nailed it when he stated that an optimum burn cannot be reached unless the combustion process is somehow "shielded" from heat transfer surfaces. Nearly all Euro design downdraft gasifiers operate under that simple principle. Garn goes one step further and effectively shields the firebox itself through an air wash effect created by negative pressure and correctly located combustion air inlets in the firebox. Any wood burner that relies on the firebox itself for heat transfer will have a high particulate count as well as sub standard efficiency.  BTW, it is very common to have a burn that appears smoke free but has a high particulate count.


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## jebatty (Jun 13, 2009)

Although in my youth I never thought too much about it, where I am now is that waste, of any kind, never makes sense or $cents, and the social cost of waste, from disposal to environmental to health of humans, is huge. Waste is false economy of the worst sort. The waster achieves a perceived personal financial or social benefit while imposing the much larger social cost on the rest of us. Mandated efficiency, call it regulation, is a win-win for everyone.

I'm not saying that all "efficiency" regulation is a win-win -- that is a completely different issue. I'm just saying that efficiency and conservation of resources in all areas, rather than waste, is a very worthy goal, and in pursuing this goal we need to be intentional about determining and publicizing the social costs of our choices. I think the public is pretty ignorant of the actual costs of a great many choices, and therefore makes very wasteful choices with the thought that these choices are economical or otherwise "worth the cost." The trouble is, we aren't given information about, or perhaps don't even know, what the cost really is. 

Not wanting my position to be "overkill' (pun fully intended), I simply don't want to pay the lung cancer cost of my neighbor's perceived economy in using a wasteful and air polluting heating appliance.


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## heaterman (Jun 13, 2009)

jebatty said:
			
		

> Although in my youth I never thought too much about it, where I am now is that waste, of any kind, never makes sense or $cents, and the social cost of waste, from disposal to environmental to health of humans, is huge. Waste is false economy of the worst sort. The waster achieves a perceived personal financial or social benefit while imposing the much larger social cost on the rest of us. Mandated efficiency, call it regulation, is a win-win for everyone.
> 
> I'm not saying that all "efficiency" regulation is a win-win -- that is a completely different issue. I'm just saying that efficiency and conservation of resources in all areas, rather than waste, is a very worthy goal, and in pursuing this goal we need to be intentional about determining and publicizing the social costs of our choices. I think the public is pretty ignorant of the actual costs of a great many choices, and therefore makes very wasteful choices with the thought that these choices are economical or otherwise "worth the cost." The trouble is, we aren't given information about, or perhaps don't even know, what the cost really is.
> 
> Not wanting my position to be "overkill' (pun fully intended), I simply don't want to pay the lung cancer cost of my neighbor's perceived economy in using a wasteful and air polluting heating appliance.




Another guy speaking the truth!


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## altheating (Jun 13, 2009)

New York State will ban them. The new draft is placing the burdon on the dealers just as VT has done. They will make it illegal for any dealer to sell a non certified OWB to any New York homeowner. This is take directely from the OWB Draft as I received it a month or so ago. It has not been passed yet, but it will be soon.


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## Gooserider (Jun 14, 2009)

One potential problem that I see if they DO ban OWB's and thus cause people to switch to gassers, is that I don't see it necessarily helping the pollution issue all that much.  While we all like to brag on how clean a gasser CAN burn, if properly operated, it is also no secret that if improperly operated they will still burn just as dirty as any pre-EPA smoke dragon...

What worries me is that while some OWB operators will get and appreciate the economy of a gasser, it also seems likely to me that the OWB industry's "problem users" - those that burn green wood, garbage, tires, telephone poles, etc. in their OWB's.  The jerks that smoke out their neighbors with an OWB are probably going to be shoveling the same crap into their new gassers, and continuing to smoke out their neighbors (While complaining about how poorly their abused gasser does at heating their homes...)  

What will THAT do to the acceptability of a gasifier in the community at large?

Something to think about...   :coolhmm: 

Gooserider


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## jebatty (Jun 14, 2009)

Goose - your point is well taken. The solution starts, hopefully, with the mfrs/dealers who will design and market wood heating appliances and train users so that the appliances are properly used and will minimize the "fuel" abuses you cite. Our mfrs/dealers have a long history of being foot-loose and fancy-free, anything goes, no regulation, no responsibility, and the larger public be *amned. Time to end this. 

Personally, I'm fed up with the fast buck, easy street, approach of our society, from industries of all sorts to the consumer. The mantra long heard is personal responsibility. The problem is that there are too many who do not actually assumes personal responsibility (and these are not the so-called welfare crowd) where there is an adverse impact on profits of the mfr/dealer or the pocketbook of the consumer. This leaves the truly responsible mfr/dealer and consumer out in in left field, out of business, and mocked by the "smart" guys and gals who revel in beating the system. And in fact, often the "smart" ones are held up as the model to follow rather than be placed in stocks on the public square.

History of the last 30 some years has proven that we are irresponsible living in a minimum regulation society. The mantra of govt being the problem, not the solution, (Pres Reagan) has dealt us a bum hand. On the macro scale it has bought us a global financial meltdown. It also has bought us a collapsing health care system, an education system in shambles, massive concentrated wealth in the hands of the abusive few, destroyed retirement accounts, accelerated climate change/global warming, pollution of our lands and waters that may end up destroying us, and abusive use of every resource to the point that the future of the whole human race is at risk. 

I don't want anyone telling me what to do any more than you do. But as a society we have proven to ourselves by our behavior that we are irresponsible in self-management and that our short-term greed has trumped the long-term best interests of our society. That's got to stop, more deregulation won't fix it, and unless we invent something else or somehow finally become enlightened to the point that we accept "we all do well only we all do well," it's going to be a government that shows us a better way and better future than the hands-off government ushered in by Reagan which sold us a false bill of goods.


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## altheating (Jun 14, 2009)

I always say there are some people out there that should only burn firewood in a fire pit, it doesn't matter how sophisticated the appliance is, they still want to burn in a fire pit. I just can't believe someone will spend 8-$12,000 on a new gasser and try o use it like a conventional OWB. Cutting their firewood usage by 2/3 should be enough incentive to get their firewood supply in and dry enough to make the gasser operate at its best. Not smoking out the neighbors is even more of a reason to use the gasser properly.


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## 603doug (Jun 14, 2009)

I am glad that we have all figured out that the world problems are caused be owb users. I have several friends who burn properly(no tires,dead cats or dispose of any trash to avoid tipping fees). As their dirty "carbon footprint" goes most owb users use best management practices to maintain their wood lots, properly insulate their dwellings etc. Education is the key, we do not need any level "uninformed government mandated fee,reg or non elected official to oversee our finite resource". We all are very concerned about waste and might be alittle more aware due to fact we are directly involved in gathering our fuel and several wasted cords burnt mean more effort etc.(money and labor are to things we like to conserve). Yes ,a form of government is needed to to maintain a "civilized" society but as I watch the current situation respond to the crisis that the "gov" has created I have a hard time being convinced that bigger and more control is better for the "masses" but only for a small few "case in point General Motors."
Okay I admit I tend to lean to the libertarian side of things and I will get off my soapbox.

Pitchforks anyone


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## rphurley (Jun 14, 2009)

altheating said:
			
		

> I always say there are some people out there that should only burn firewood in a fire pit, it doesn't matter how sophisticated the appliance is, they still want to burn in a fire pit. I just can't believe someone will spend 8-$12,000 on a new gasser and try o use it like a conventional OWB. Cutting their firewood usage by 2/3 should be enough incentive to get their firewood supply in and dry enough to make the gasser operate at its best. Not smoking out the neighbors is even more of a reason to use the gasser properly.



I'm sure that we all know people who refuse to properly season their firewood.  They'll say that their wood burns just fine, and they refuse to believe that more time and planning will give them much better results.  Frustrates the heck out of me!


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## fabguy01 (Jun 14, 2009)

jebatty said:
			
		

> Goose - your point is well taken. The solution starts, hopefully, with the mfrs/dealers who will design and market wood heating appliances and train users so that the appliances are properly used and will minimize the "fuel" abuses you cite. Our mfrs/dealers have a long history of being foot-loose and fancy-free, anything goes, no regulation, no responsibility, and the larger public be *amned. Time to end this.
> 
> Personally, I'm fed up with the fast buck, easy street, approach of our society, from industries of all sorts to the consumer. The mantra long heard is personal responsibility. The problem is that there are too many who do not actually assumes personal responsibility (and these are not the so-called welfare crowd) where there is an adverse impact on profits of the mfr/dealer or the pocketbook of the consumer. This leaves the truly responsible mfr/dealer and consumer out in in left field, out of business, and mocked by the "smart" guys and gals who revel in beating the system. And in fact, often the "smart" ones are held up as the model to follow rather than be placed in stocks on the public square.
> 
> ...


WOW :bug: you must be a gov employee to be thinking like this, Just kidding. But it just makes me laugh when i hear people talking about us dirty un-environmentally responsible americans. IMO everyone who thinks this way needs to take a trip yo India or China and not on the big money sight seeing tours, go to the Massive industrial areas, and then you will see irresponsibility. and dont say Ohh I've seen pictures because that dose it not 1 cent of justice. And I know what all will say "if we just show them the way they will follow" total B.S.Those countrys are in the same place now that we were in during the industrial revolution.And it is a process that takes time for them to figure out themselves just like we did. BTW have you seen what the all powerful gov has done with all its new power of giving YOUR money away to greedy corporations? anyway, I dont think mor gov control is the answer to anything. P.S. probably time to go to the ash can eh?


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## Gooserider (Jun 14, 2009)

Seems to be headed in the Asch Can direction, but only if we continue on the current side track...  It would be good to see a return back to the OP's question about whether or not OWB's are going to get outlawed or not, which really hasn't been answered.  (At this point in time, I'm not sure it can be...)

While I have mixed feelings about whether or not they should be, my instinct, based on observation of past behaviour, is that they probably will be...  Further, I'd be willing to bet that the restriction will have unintended consequences that hurt far more people than the original smoke boxes did, and WON'T solve the basic problem of excessive smoke...

Gooserider


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## jebatty (Jun 14, 2009)

> Seems to be headed in the Asch Can direction, but only if we continue on the current side track…



Another point well taken.


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## ihookem (Jun 16, 2009)

I don't think the elected  government officials know which end of a chainsaw to hold on to. Rest assured they will take the OWB problem and make it ten times worse and jack the cost up for a wood burner to the point we will all go back to big oil and bend over for them and take it in the @ss. I always believed a little regulation was ok, to the point that if enough people complain a compromise should be made between neighbors. I believe that gassifiers are a much better product and the free market will prove it, not regulation. Gov. regulations are decided  by lawmakers that don't know how to stack firewood so they vote the way of the  action group that has the best lawyer. I think owb will be gone when owb owners see gassifier owners pack up and go fishing or hunting when owb owners are still making wood. Also, I think firewood will get hared to come by. It is for me cause pulpers take the whole tree and run it through a chipper right into a semi and leave nothing. I used to take 2 cords of branches a year, now there's nothing but a 6" stump. Everyone is totally jumping on firewood now days and it's to some degree because owb owners need 10 cord a year when they could use 4-5 cords. I know a guy who is always making wood. He burns 20 cords a year. He is crazy if his next isn't a gassifier. P.s. I think Reagan was the best president we had in 50 years. I think the people want everything way too cheap and forget about  quality in the long run.


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## Delta-T (Jun 16, 2009)

i think its interesting....the key to ANY system of combustion that is going to be operated by the home-owner is education. I have a saying.. that may be stolen (probably is) but i dont know where it came from...."Doing something the wrong way for 30 years doesn't make you an expert, just makes you wrong"..and there will always be the die hard independant thinkers who take no consult, seek no guru, and ignore the free advice of their neighbors. I think those people generally don't occupy Hearth.com. Everyone here is sharing what they've learned or learning what others share. We tend to be the people doing the leg work and recognize that knowledge becomes power when given. It sthe guy who doesn't get on here, doesn't read his manual, doesn't bother to appreciate the science of fire that causes many of our woes. Having been in customer service for moons now, I have a huge amount of respect for the peeps on this site. I'm an eternal student of many disciplines (father is a Prof, mother and 2 sisters teachers) and marvel at the thirts for knowledge here. Maybe instead of regulation and code ammendments there should be a pre-requisite "spend a week on Hearth.com" before you can own any potential smoke dragon (wood,pellet,coal,peat,dung,corn,rendered animal fat). Sort of like a waiting period for gun ownership.


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## heaterman (Jun 16, 2009)

"I don’t think the elected government officials know which end of a chainsaw to hold on to."

Another truth speaker!
 I have a gut instinct telling me that if we had men familiar with the use and operation of chainsaws running this country, we wouldn't be in the mess we are now. Too many educated idiots running things.


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## fabguy01 (Jun 16, 2009)

:coolsmirk:  :coolsmirk: 





			
				heaterman said:
			
		

> "I don’t think the elected government officials know which end of a chainsaw to hold on to."
> 
> Another truth speaker!
> I have a gut instinct telling me that if we had men familiar with the use and operation of chainsaws running this country, we wouldn't be in the mess we are now. Too many educated idiots running things.


Now were on to something :coolsmirk:  :coolsmirk:


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## smokywoodmaster (Jun 24, 2009)

Another Massachusetts town looking to ban outdoor wood boilers.

The Town of Holliston Board of Health voted last week to ban any new or existing units.  
It is subject to DEP approval.
There is only one known boiler in town.
About 35 towns have now set their own regulations.

New STATE rules took effect 12/08 which limit emissions 
Require EPA Phase 2 "White Tag" (not many choices there)
http://www.mass.gov/dep/air/community/burnwood.htm
• As of Dec. 26, only the cleanest burning wood boilers could be sold in the state, those that emit less than .32 pounds of particulate matter for every million BTUs of heat produced. 
• Existing outdoor wood boilers that do not meet the new state emission standards cannot be operated between May 16 and Sept. 30 unless they are more than 500 feet from the nearest occupied dwelling. 
• An existing wood boiler located within 150 feet of an occupied dwelling it does not serve (such as a neighbor's house) must have a smokestack at least two feet higher than the peak of any roof structure within 150 feet. Owners of such wood boilers have until March 1 to comply. 
• It is unlawful to operate a wood burner in such a manner that the smoke from it exceeds an average of 20 percent opacity for two minutes in any one-hour period.


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## altheating (Jun 24, 2009)

You will see that most states that are working on something are using the NESCAUM model rule or a version of it. Then we have to thank our former Governer Spitzer for his lying report 'Smoke gets in your lungs". Below is the NYS Draft as I received it a month or so ago.

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Page 1 of 12
Express Terms
6 NYCRR Part 247, Outdoor Wood Boilers
Section 247.1 Applicability. This Part applies to outdoor wood boilers. Sections 247.3 and 247.4 of this Part apply generally to all outdoor wood boilers. In addition to the general provisions, sections 247.5 through 247.9 apply specifically to new outdoor wood boilers, and section 247.10 applies specifically to existing outdoor wood boilers.
Section 247.2 Definitions.
(a) To the extent that they are not inconsistent with the specific definitions in subdivision (b) of this section, the general definitions of Part 200 and Subpart 201-2 of this Title shall apply to this Part.
(b) For the purposes of this Part, the following definitions apply:
(1) ‘Agricultural land’. The land and on-farm buildings, equipment, manure processing and handling facilities, and practices that contribute to the production, preparation and marketing of crops, livestock and livestock products as a commercial enterprise, including a ‘commercial horse boarding operation’ and ‘timber processing’. Such farm operation may consist of one or more parcels of owned or rented land, which parcels may be contiguous or noncontiguous to each other.
(2) ‘Clean wood’. Wood that has not been painted, stained, or treated with any other coatings or preservatives, including, but not limited to, chromated copper arsenate, creosote, alkaline copper quaternary, copper azole or pentachlorophenol.
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Page 2 of 12
(3) ‘Commence operation’. The initial start-up of the combustion chamber of a new outdoor wood boiler after all piping and electrical connections between the new outdoor wood boiler and the building(s) it serves have been completed.
(4) ‘Commercial-size new outdoor wood boiler’. A new outdoor wood boiler with a thermal output rating greater than 250,000 British thermal units per hour (Btu/h).
(5) ‘Distributor’. Any person who sells or leases a new outdoor wood boiler to an end user. A distributor may be a manufacturer or agent thereof or an independent contractor.
(6) ‘End user’. Any person who purchases or acquires any new outdoor wood boiler for personal, family, household, commercial or institutional use. Persons acquiring a new outdoor wood boiler for resale are not end users for that product.
(7) ‘Existing outdoor wood boiler’. An outdoor wood boiler that commenced operation prior to April 15, 2010.
(8) ‘Manufacturer’. Any person who makes or produces a new outdoor wood boiler that is ultimately operated in New York.
(9) ‘Model’. All new outdoor wood boilers manufactured by a single manufacturer that are similar in all material and design respects.
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Page 3 of 12
(10) ‘New outdoor wood boiler’. An outdoor wood boiler that commences operation on or after April 15, 2010.
(11) ‘Outdoor wood boiler’. A fuel burning device that (a) is designed to burn wood or other approved fuels; (b) is specified by the manufacturer for outdoor installation or installation in structures not normally occupied by humans; and (c) is used to heat building space and/or water via the distribution, typically through pipes, of a gas or liquid (e.g., water or water/antifreeze mixture) heated in the device.
(12) ‘Residential-size new outdoor wood boiler’. A new outdoor wood boiler that has a thermal output rating of 250,000 Btu/h or less.
(13) ‘Responsible official’. A president, vice president, secretary, treasurer, general partner, proprietor, principal executive officer, or any other person who performs policy or decision making functions and is authorized to legally bind a corporation, partnership, or sole proprietorship which is subject to the provisions of this Part.
(14) ‘Test Method 28-OWHH’. “EPA Test Method 28 OWHH for Measurement of Particulate Emissions and Heating Efficiency of Outdoor Wood-Fired Hydronic Heating Appliances”, Attachment 2 of the “EPA Outdoor Wood-fired Hydronic Heater Program Phase I Partnership Agreement” dated March 16, 2007 (see Table 1, Section 200.9 of this Title).
(15) ‘Thermal output rating’. The heat value in Btu/h that a manufacturer specifies a particular model of new outdoor wood boiler is capable of supplying at its design capacity.
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Page 4 of 12
Section 247.3 Prohibitions.
(a) No person shall operate an outdoor wood boiler that does not meet the requirements set forth in this Part.
(b) Prohibited fuels. No person shall burn any of the following items in an outdoor wood boiler:
(1) wood that does not meet the definition of clean wood;
(2) garbage;
(3) tires;
(4) yard waste, including lawn clippings;
(5) materials containing plastic;
(6) materials containing rubber;
(7) waste petroleum products;
(8) paints or paint thinners;
(9) household or laboratory chemicals;
(10) coal;
(11) paper except as described in paragraph 247.4(a)(4) of this Part;
(12) construction and demolition debris;
(13) plywood;
(14) particleboard;
(15) fiberboard;
(16) oriented strand board;
(17) manure;
(18) animal carcasses;
(19) asphalt products;
DRAFT


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## altheating (Jun 24, 2009)

(20) salt water driftwood; or
(21) any other fuel that is not recognized as an approved fuel pursuant to Section 247.4 of this Part.
(c) No person shall cause or allow emissions of air contaminants from an outdoor wood boiler to the outdoor atmosphere of a quantity, characteristic or duration which is injurious to human, plant or animal life or to property, or which unreasonably interferes with the comfortable enjoyment of life or property. This prohibition applies, but is not limited to, the following conditions:
(1) activating smoke detectors in neighboring structures;
(2) impairing visibility on a public highway; or
(3) causing a continuous visible plume migrating from an outdoor wood boiler and contacting a building on an adjacent property.
The prohibition further applies to any particulate, fume, gas, mist, odor, smoke, vapor, pollen, toxic or deleterious emission, either alone or in combination with others, emitted from an outdoor wood boiler that results in the conditions or circumstances listed in this subdivision notwithstanding the existence of specific air quality standards or emission limits.
(d) No person shall operate an outdoor wood boiler in such a manner as to create a smoke plume with an opacity of 20 percent or greater (six minute mean) except for one six-minute period per hour of not more than 27 percent opacity as determined using EPA Reference Method 9 (or equivalent) (see Table 1, Section 200.9 of this Title).
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Page 6 of 12
Section 247.4 Approved Fuels.
(a) A person who operates an outdoor wood boiler may only burn the following fuels in such outdoor wood boiler:
(1) clean wood;
(2) wood pellets made from clean wood;
(3) heating oil in compliance with Subpart 225-1 of this Title, L.P. gas or natural gas may be used as starter fuels for dual fuel-fired outdoor wood boilers;
(4) non-glossy, non-colored papers, including newspaper, may be used only to start an outdoor wood boiler; and
(5) other fuels approved by the department per the certification requirements of Section 247.8 of this Part.
Section 247.5 Residential-Size New Outdoor Wood Boilers.
(a) Emission limits. In order for a residential-size new outdoor wood boiler to be certified pursuant to Section 247.8 of this Part, it must not emit particulate emissions at a rate greater than a weighted average of 7.5 grams per hour using the year-round weighting factors in Test Method 28-OWHH (see Table 1, Section 200.9 of this Title). The particulate emission rate for any test run with a burn rate less than or equal to 1.5 kilograms per hour must not exceed 15.0 grams per hour. The particulate emission rate for any test run with a burn rate greater than 1.5 kilograms per hour must not exceed 18.0 grams per hour.
(b) Setback. A residential-size new outdoor wood boiler shall not be located less than 100 feet from the nearest property line.
(c)
Stack height. A residential-size new outdoor wood boiler shall be equipped with a permanent
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Page 7 of 12
stack extending a minimum of eighteen (18) feet above ground level.
Section 247.6 Commercial-Size New Outdoor Wood Boilers.
(a) A commercial-size new outdoor wood boiler shall not be used in a solely residential application.
(b) Emission limits. In order for a commercial-size new outdoor wood boiler to be certified pursuant to Section 247.8 of this Part, it must not emit particulate emissions at a rate greater than a weighted average of 10.0 grams per hour using the year-round weighting factors in Test Method 28-OWHH (see Table 1, Section 200.9 of this Title). Further, the particulate emission rate for any test run must not exceed 20.0 grams per hour.
(c) Setbacks. A commercial-size new outdoor wood boiler shall not be located:
(1) less than 150 feet from the nearest property line;
(2) less than 300 feet from a property line of a residentially zoned property; and
(3) less than 1000 feet from a school.
(d) Stack height. A commercial-size new outdoor wood boiler shall be equipped with a permanent
stack extending a minimum of eighteen (18) feet above ground level.
Section 247.7 Permanent label.
(a) A permanent label shall be affixed to all new outdoor wood boilers.
(1) The label shall be made of a material that is sufficiently durable to last the lifetime of the new outdoor wood boiler.
(2) The label shall be affixed to the new outdoor wood boiler in a readily visible or accessible location.
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Page 8 of 12
(3) The label shall be affixed in such a manner that it cannot be removed from the new outdoor wood boiler without causing damage to the label.
(4) The following information shall be displayed on the label:
(i) name and address of the manufacturer;
(ii) date of manufacture;
(iii) model name and number;
(iv) serial number;
(v) thermal output rating in Btu/h;
(vi) list of approved fuels that may be burned in the new outdoor wood boiler;
(vii) certified particulate emission rate in grams per hour.
Section 247.8 Certification of new outdoor wood boilers.
(a) Certified models. No person shall sell, lease or operate a new outdoor wood boiler unless the model has been certified by the department pursuant to this section.
(b) Emission limits. In order to receive certification, a residential-size new outdoor wood boiler shall meet the emission limits in section 247.5 of this Part, and a commercial-size new outdoor wood boiler shall meet the emission limits in section 247.6 of this Part.
(c) Application. Manufacturers requesting certification of a model shall submit an application to the department. An application shall consist of two complete copies of the application on a form provided by the department, along with two copies of the supporting documents required by this subdivision. Both copies of the application shall be signed by a responsible official of the manufacturer, and shall include the following:
DRAFT


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## altheating (Jun 24, 2009)

(1) name and address of the manufacturer, the model name and number, serial number, date of manufacture and the thermal output rating, in Btu/h, of the new outdoor wood boiler tested;
(2) four individual, color photographs of the tested unit showing the front, back and both sides of the unit;
(3) engineering drawings and specifications for each of the following components:
(i) firebox including a secondary combustion chamber;
(ii) air induction systems;
(iii) baffles;
(iv) refractory and insulation materials;
(v) catalysts;
(vi) catalyst bypass mechanisms;
(vii) flue gas exit;
(viii) door and catalyst bypass gaskets;
(ix) outer shielding and coverings;
(x) fuel feed system; and
(xi) blower motors and fan blade size.
(4) final test report prepared by the testing laboratory; and
(5) a copy of the operation and maintenance instructions.
(d) Certificate of compliance. The department shall issue a certificate of compliance for a model if the certification application is determined to be complete and accurate and the model is determined to be compliant with the requirements set forth in this Part.
(1) Only fuels listed in the certificate of compliance may be burned in the model.
DRAFT
Page 10 of 12
(2) The certificate of compliance is valid for five years and shall expire on the date listed in the certificate unless it is renewed by the certificate holder.
(3) A change in the design of a model resulting in a change in the thermal output rating of the model constitutes the creation of a new model which must be certified pursuant to this section.
(4) Upon written notice to the certificate holder, a certificate may be withdrawn by the Department if it is determined that the application contained false or inaccurate information, or for other good cause.
(e) Test method. To meet certification requirements for this section, particulate emissions from new outdoor wood boiler models shall be determined using Test Method 28-OWHH (see Table 1, Section 200.9 of this Title), as defined in paragraph 247.2(b)(14) of this Part.
(f) Test laboratory. All certification testing shall be conducted by a laboratory accredited by the EPA in accordance with 40 CFR 60 Subpart AAA, Section 60.535 (see Table 1, Section 200.9 of this Title), or another accrediting organization approved by the department, which has no conflict of interest or financial gain in the outcome of the testing.
Section 247.9 Notice to buyers.
(a) 'Written notice.' Prior to the execution of a sale or lease agreement for a new outdoor wood boiler, the distributor shall provide the prospective buyer or lessee with a copy of this Part and a written notice which includes:
(1) an acknowledgement that the buyer or lessee was provided with a copy of this Part;
(2) a list of the approved fuels as set forth in Section 247.4 of this Part;


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## altheating (Jun 24, 2009)

and
DRAFT
Page 11 of 12
(3) a statement that even if the requirements set forth in this Part are met, there may be conditions or locations in which the use of a new outdoor wood boiler interferes with another person’s use or enjoyment of property or even damages human health, and if such a situation occurs, the owner or lessee of the new outdoor wood boiler causing the situation may be subject to sanctions that can include a requirement to remove the device at their own expense, as well as any other penalty allowed by law.
(b) ‘Completed notice.’
(1) The written notice required by this section shall be signed and dated by the buyer or lessee and the distributor when the sale or lease of the new outdoor wood boiler is completed. In addition, the following information shall be included in the completed notice:
(i) name and address of the owner or lessee of the new outdoor wood boiler;
(ii) street address where the outdoor wood boiler was installed (if different from item (i) above);
(iii) name of the manufacturer, model and date of manufacture of the new outdoor wood boiler;
(iv) height of the permanent stack for the new outdoor wood boiler; and
(v) distance from the new outdoor wood boiler to the nearest property line.
(2) The distributor shall submit the original signed copy of the notice to the department’s regional office for the location where the new outdoor wood boiler is installed or as otherwise specified by the department within seven (7) days of making delivery of the new outdoor wood boiler to the buyer or lessee.
DRAFT
Page 12 of 12
Section 247.10 Requirements for existing outdoor wood boilers.
(a) Effective October 1, 2010, all existing outdoor wood boilers shall be equipped with a permanent stack extending a minimum of eighteen (18) feet above ground level.
(b) No person shall operate an existing outdoor wood boiler between April 15 and September 30 of each year, except as follows:
(1) An existing outdoor wood boiler that is a model certified by the department pursuant to Section 247.8 of this Part and sited 100 feet or more from the nearest property line is not subject to this subdivision;
(2) An existing outdoor wood boiler sited 500 feet or more from the nearest property line and 1000 feet or more from a school is not subject to this subdivision; or
(3) An existing outdoor wood boiler located on contiguous agricultural lands larger than five acres and sited 500 feet or more from the nearest residence not served by the existing outdoor wood boiler or 500 feet or more from a property line that is not on agricultural land and 1000 feet or more from a school is not subject to this subdivision.
Section 247.11 Severability.
Each provision of this Part shall be deemed severable, and in the event that any provision of this Part is held to be invalid, the remainder of this Part shall continue in full force and effect.



Kind of a long way to get this posted , but it is what it is. A contact has heard that NYS may push this through as soon as Oct 1st of this year.


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## stee6043 (Jun 24, 2009)

I'd love to see the device that consistently and accurately measures smoke opacity in varying light conditions outside....


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## Wet1 (Jun 24, 2009)

stee6043 said:
			
		

> I'd love to see the device that consistently and accurately measures smoke opacity in varying light conditions outside....


It's called a pissed-off neighbor... okay maybe it's not all that accurate.


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## altheating (Jun 24, 2009)

And who is going to get certified to operate such device?


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## stee6043 (Jun 25, 2009)

Wet1 said:
			
		

> stee6043 said:
> 
> 
> 
> ...



Ha....but when properly calibrated it can be very effective...


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## smokywoodmaster (Jun 25, 2009)

Vermont

This State of Vermont is proposing "Phase II" standards for OWBs sold as of April 1, 2010. 

The same standards as MA, NH, and ME.

http://www.anr.state.vt.us/air/docs/SIS_AttB_Standard_Proposal_Ph2.pdf


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## Gooserider (Jun 25, 2009)

As an interesting question, what does this kind of regulation imply for those folks that are doing "Garn Barns" or a similar outdoor structure for a gasifier like an EKO or Econoburn that doesn't quite meet the description / definition for an OWB (not specifically designed for outdoor use, doesn't come with a shed enclosure, etc...)?  Yes the units are clean, but would they have the certifications that are required for an OWB?  Would they be needed?  - I'd be worried that someone was doing a gasser in a shed, and a code person would say that it's the equivalent of an OWB, and no you can't do that because it doesn't have an OWB certification....

Gooserider


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## altheating (Jun 26, 2009)

New York State has already addressed this issue. The NYS codes reads something like this. The definition of an OWB is any devise located in a structure not attached to the structure being heated with such devise. Some people have attempted to take the OWB's to a different level by placing the traditional OWB into a building thinking that because it was situated inside it is no longer concidered an OWB, well New York State addressed that too. The state code reads, any wood burning devise must be independent lab tested and labeled for indoor installation. Any OWB must also be tested and labeled for outdoor installation. There were a few OWB's that were deemed illegal for installation in New York State a few years ago. I know of no OWB that is labeled for inside installation at this time. As far as the certifications on the Eko and Econoburn goes, they are certified for indoor installs, but the codes still says they are OWB's if they heat a structure adjacent to the building they are in. Of course it makes no sense as they would be buring the same amount of firewood as if they were placed inside the home, where they are perfectly legal to install. I spent many hours at town meetings as well as many hours on the phone with the codes people in Albany a few years ago, talking with most of these people, most of them not having a clue.


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## Gooserider (Jun 26, 2009)

altheating said:
			
		

> New York State has already addressed this issue. The NYS codes reads something like this. The definition of an OWB is any devise located in a structure not attached to the structure being heated with such devise. Some people have attempted to take the OWB's to a different level by placing the traditional OWB into a building thinking that because it was situated inside it is no longer concidered an OWB, well New York State addressed that too. The state code reads, any wood burning devise must be independent lab tested and labeled for indoor installation. Any OWB must also be tested and labeled for outdoor installation. There were a few OWB's that were deemed illegal for installation in New York State a few years ago. I know of no OWB that is labeled for inside installation at this time. As far as the certifications on the Eko and Econoburn goes, they are certified for indoor installs, but the codes still says they are OWB's if they heat a structure adjacent to the building they are in. Of course it makes no sense as they would be buring the same amount of firewood as if they were placed inside the home, where they are perfectly legal to install. I spent many hours at town meetings as well as many hours on the phone with the codes people in Albany a few years ago, talking with most of these people, most of them not having a clue.



Not quite sure I follow you AH - I understand about the code definition of an OWB, and that makes sense; but it isn't quite clear to me if you are saying that an indoor listed boiler in an outbuilding would be legal or not?

(Not that it matters a great deal to me since I'm not in NY, and am thinking indoor installation regardless, but...  Of course MA screws you over in other ways instead, that I've mentioned elsewhere)

Gooserider


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## crs7200 (Jun 26, 2009)

I've seen this same basic discussion in here so many times, I can almost tell who will reply and what they will say.

Same old stuff.  OWB are bad.  smoke a lot, burn too much wood, create too much pollution.

Everything is going to be outlawed by the EPA because our elected officials, who wouldn't know the difference if the smoke was coming from a stove or their fat round cigars.

I know people that heat with everything from a OWB, gassifier, coal stove, fireplace insert, oil/wood/ combo's, just about everything.

You know what I have found to be the absolute truth is this...
                        .......I don't care what you burn or how much it smokes out your neighbors, if it comes from a chimney that comes out of your house, NO ONE CARES.   They all look the other way.  No codes officers are called, no tickets are issued, and the burning and smoking goes on without a care.

BUT ...................... have a stove that is outside, burn nothing but seasoned wood, create less to almost NO smoke and some tree hugger that drives their hybrid (below 30mph of course) will say that you are the enemy of all the people who want nothing more than to breath clean air.  All because they see your OWB and think they know it all.
      REGARDLESS of having to prove time and time again that it is not me making the smoke but my neighbor who has a woodstove that smokes likes crazy, I am always the first person they point fingers at.

Finally after the first 2 years, they all know that it isn't me.   The only good thing that has come from this is that my local government officials have learned alot about OWB from me and that they are not the enemy of the state.

I've heard about (and know of some) that burn garbage and other items.  Most of the ones that I have seen do this, do it from their stoves inside their houses.


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## heaterman (Jun 28, 2009)

What I'm wondering is what happens in a case where an indoor rated boiler (IE, Garn, Eko, Econoburn etc.) is used to heat multiple buildings. As the NewYork regs state, the unit must be installed in the building being heated. So what if the owner wants to use the boiler for multiple tasks/ buildings?


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## dogwood (Jun 28, 2009)

Out here in the western part Virginia a lot of people have plain old wood stoves for heat and the wealthier amongst us may have an OWB. It can get mighty smoky in the winter months. However there will be no bans here I suspect, since we have adapted to breathing a 50% smoke to air mix. Problems with wood smoke are relatively trifling. About fifteen years ago it took the whole community to prevent the local cement company from converting over to burning radioactive waste. That's the truth. Think about how that would affect your property value. Relatively speaking what's a little smoke? We're lucky not to be glowing in the dark.

Mike


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## greeninsulation (Jul 3, 2009)

AS a national factory direct distributor of Sequoyah and Wood Doctor, and have had an OWHH for 10 years I have heard/seen it all.  I know that people will burn trash and cause the clean WHITE tag units to smoke and I know that my older Wood Doctor burns extremly clean.   The newer gasification units are designed to help keep the environment cleaner but it depends upon the operator.  The higher efficiency, longer burn times, less wood  consumed  are huge benefits for the gasifiers.   I always spend a lot of time talking with potential customers in states that have options discussing the pros/cons of gasification furnaces.  For more information on these units, and a video please see. www.woodgasificationfurnace.com or www.mainewooddoctor.com


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## lawandorder (Jul 29, 2009)

So with all of this in mind what happens to the OWB that are already installed or which will be installed prior to the new regulations in New York State


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## altheating (Jul 29, 2009)

Here is the NYS proposed draft of the OWB regulations.

http://altheating.com/NYCRR247OWBDraft.pdf


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## heaterman (Jul 29, 2009)

altheating said:
			
		

> Here is the NYS proposed draft of the OWB regulations.
> 
> http://altheating.com/NYCRR247OWBDraft.pdf



Geepers! What about someone with a lot that's less than 300x300' ? Did I read correctly that existing OWB's have to have an 18' stack? What the heck do they think a stack is going to do in the first place?


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## Gooserider (Jul 29, 2009)

heaterman said:
			
		

> altheating said:
> 
> 
> 
> ...



Presumably the idea is that if you have a small lot, you shouldn't be running an OWB...  Get some other alternative.  This doesn't seem totally unreasonable given that most of the fuss about OWB's comes from ones located in crowded areas, and generally speaking small lots are usually only found in crowded areas.

The 18' stack is also looking at the same issue - a lot of the complaints are because the OWB smoke hugs the ground and floats around where people are standing.  An 18' minimum stack gets the smoke up to a height similar to that of a short house, say a slab built ranch, so that the smoke has more of a chance to dissipate before it gets to ground level.  Also if you look at "microclimates" it is not uncommon for there to be a thermal inversion layer close to the ground, smoke in that layer tends to be trapped and stay there, while smoke above it tends to go up and away - the tall stack helps in that regard...

One might not like the regs, but there actually is some level of logic to them.

Gooserider


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## lawandorder (Jul 29, 2009)

So do current OWBs have to meet the requirments when the legislation is passed or do they just stay as is???


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## heaterman (Jul 29, 2009)

lawandorder said:
			
		

> So do current OWBs have to meet the requirments when the legislation is passed or do they just stay as is???



Unless I read it wrong it looks like at least the stack height issue is retroactive and would apply to anything currently installed also.

Section 247-3.3 Setback and Stack Height Requirements.
(a) Stack height requirement. An *existing outdoor wood boiler must* be equipped with a permanent
stack extending a minimum of eighteen (18) feet above ground level effective October 1, 2008.
(b) Setback requirement. An existing outdoor wood boiler that does not meet the requirements set
forth in Section 247-2.2(a) or Section 247-2.3(a) of this Part which is sited less than 500 feet from the nearest
property line must be removed or rendered inoperable by September 30, 2010.


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## heaterman (Jul 29, 2009)

Things are going to get interesting..........


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## altheating (Jul 29, 2009)

In all reality I think you will see little effect on currently installed boilers, UNLESS they are causing air quality issues with your neighbors. If that occurs I think you will see enforcement including cour orders to shut them down. I have heard that once a court order is issued a fine of $500 per day can be imposed to the homeowner for each day the unit remains in operation. Current DEC regulations cover offensive smoke emissions, but are rarely enforced. The new setback limits will reduce the number of people who will be able to install them.


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## lawandorder (Jul 29, 2009)

Thats what I was thinking but I wasnt sure if I was interpreting it correctly Thats a big one on the Setback requirements.


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## hoogie (Jul 30, 2009)

all you guys make really good points i have a neighbors that are less than 300 feet away, my next door neighbor has a reg. owb the unit i just bought is a gasser, the reason that i choose that route is that i was afraid that with two regular units side by side someone would complain even though nobody has yet. Also to mention the ban on reg. owbs here in Indiana has been rumored for the last yr. i choose to run with the epa cert. white and orange tag unit....But like everyone one here knows inside or outside if ya burn crap thats whats gonna come outta your pipe....i would think with the added cost of a gasser that someone would not void there warranty with burnin crap....just my two cents worth....charlie...


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## lawandorder (Jul 31, 2009)

So, my next questoin is :  I have a tarm Solo installed in a heated detached garage 20 ft from my property line, piped underground to my house. Tarms are indoor units but if i read the NYS regs it appears it meets the definitions of and OWB????  Is this possible? or am I missing something.  THe draft legislation does not mention gassification units.... Is that just a mistake or do people in Albany not understand the processes of OWBs and indoor Gassification units to put accurate language into a draft legislation.


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## Gooserider (Jul 31, 2009)

lawandorder said:
			
		

> So, my next questoin is :  I have a tarm Solo installed in a heated detached garage 20 ft from my property line, piped underground to my house. Tarms are indoor units but if i read the NYS regs it appears it meets the definitions of and OWB????  Is this possible? or am I missing something.  THe draft legislation does not mention gassification units.... Is that just a mistake or do people in Albany not understand the processes of OWBs and indoor Gassification units to put accurate language into a draft legislation.



I would expect that it is a case of lack of knowledge on the part of the gov't types, or a lack of caring...  It is entirely possible that you might be impacted, though as others have pointed out, the odds of having a regulation enforced may be a function of how cleanly you burn - if you don't cause a problem the gov't thugs might leave you alone, but don't count on it...

Gooserider


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## lawandorder (Jul 31, 2009)

nice.......


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