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April 23, 2010 John Bames, P.E, NYS Department of Environmental Conservation Division of Air Resources 625 Broadway, Ind Floor Albany, NY 12233-3251 Re: Proposed Part 247 Regulation of Outdoor Wood Boilers Dear Mr. Bames: Tam writing to offer my comments concerning the proposed regulation Part 247, which I believe represents another example of the DEC’s one-size-fits-all mindset that ignores the special needs and conditions of families struggling to get by in Northem NY counties. St. Lawrence County, according to the US Census Bureau’s American Community Survey, has the state’s largest number of homes that rely on wood as a primary heating fuel—more than 13 percent of all residents—and a per capita income that is lower than every other county, except the Bronx, Many of these femilies and family farmers—and hundreds more in Jefferson, Oswego and Lewis Counties—use outdoor wood boilers as a cost-eflicient soutee for heat and hot water using natural and renewable sources harvested right from one’s own property. The proposed regulation would require these homeowners make expensive—and in many cases, unnecessary—alterations to existing boilers, require the devices to be scrapped long before their anticipated useful service life, and increases costs for new boilers, DEC estimates that retrofitting an existing boiler with a minimum 18-foot smokestack will costa typical homeowner $600, about the same as the cost for a full year of wood fuel. The cost will be significantly higher for farmers and other homeowners who have to meet the requirement of a smokestack that is at least two fect higher than nearby structures, like bams, silos and outbuildings. In addition, requiring homeowners to scrap their existing boilers will prevent many from even coming close to recouping their investment of as much as $10,000. Unlike recent state and federal government programs that provided millions of dollars to homeowners to improve energy efficiency and cut pollution, such as rebates for energy efficient air conditioners and other appliances, and tax credits for insulation, caulking, windows and doors, your proposal does not include any assistance for families and businesses forced to bear these additional costs. ‘And you are expecting homeowners to make these expensive investments at a time of record joblessness, when out local economy is being especially hard hit by the state and national recession. No one more than the residents of Northern New York appreciates the need for responsible stewardship of our natural resources, air, land and water. But these proposed regulations are overreaching and, while they may represent the best solution to problems ‘that downstate communities are experiencing with these devices, they show a lack of understanding of the unique and special way of life that we enjoy in Northem and Upstate New York. Thank you for the opportunity to offer my views on this proposal