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.