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Resource Library for the How-To Guide for Implementing a Wood Stove Changeout Program
We have developed this E-library of information to help you as you develop, plan, and implement your campaign. The resources are grouped according to the topics discussed within the How-To Guide as shown below. This is not an exhaustive list of information related to wood stove changeout campaigns, and we encourage you to send us links or more information as you find it or develop it.
What is a Wood Stove Changeout Campaign?
How do I know if my area is a candidate for a Wood Stove Changeout Campaign?
- Feasibility Studies
- Health Effects of Wood Smoke/Emissions Reductions from EPA-Certified Wood Stoves
- Demographic Analyses and Environmental Justice
- Marketing Surveys
- Air Quality Information
- Other Studies and Data Sources
What is the process for developing and implementing a Wood Stove Changeout Campaign?
- Identify potential partners.
- Identify sources of funding.
- Develop a project plan.
- Implement Wood Stove Changeout Campaign
- Measure success.
- Related Programs
- 2007 Residential Wood Smoke Workshop
- 2006 Residential Wood Smoke Workshop
- Other Information
**Please note that some information in this library comes from outside sources and was scanned into the library. These resources will be denoted by an asterisk (*) and do not necessarily represent the views of the EPA.
You will need Adobe Acrobat Reader to view the Adobe PDF files on this page. See EPA's PDF page for more information about getting and using the free Acrobat Reader.
What is a Wood Stove Changeout Campaign?
Environmental Cooking 101 - U.S. Environmental Protection Agency, Office of Air and Radiation. Learn about the basic elements of developing an environmental project.
The Great Wood Stove Change-Out - U.S. Environmental Protection Agency, Office of Air and Radiation. Learn the basics about a Wood Stove Changeout Campaign.
How a Wood Stove Changeout Campaign Works (PDF) (1pg, 69k) - U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. This flow diagram provides a pictorial description of the Wood Stove Changeout Campaign planning and implementation process.
How do I know if my area is a candidate for a Wood Stove Changeout Campaign?
Woodstove Changeout Feasibility Checklist (PDF) (2pp, 61k)
East-West Lessons Learned Wood Stove Changeout Workshop (PDF) (48pp, 2.6 MB) - This report summarizes the meeting in February 2005 in Atlanta, GA that served as an information exchange related to Wood Stove Changeout Campaigns.
Feasibility Assessment of a Change-Out/Education Program for Residential Wood Combustion: A Step-by-Step APproach to a National Program Aimed at Reducing Emissions from Residential Wood Combustion (PDF) (42pp, 263k) 
- The Canadian Centre for Pollution Prevention, CULLBRIDGE™ Marketing and Communications and Action-Environnement. This report evaluates whether Wood Stove Changeout Campaigns or education and outreach alone or in conjunction with one another reduced particle pollution emissions from wood stoves in Canada.
Feasibility of Developing and Piloting a Wood Stove Exchange Program - Gulland Associates
An Integrated Community Approach to Reducing Residential Woodsmoke: Community Analysis and Education (PDF) (8pp, 2.3 MB) - Lincoln County Department of Environmental Health. This paper describes a case study of Libby, Montana that was used for wood smoke reduction and community acceptance strategies in an economically challenged community.*
Health Effects of Wood Smoke/Emissions Reductions from EPA-Certified Wood Stoves
Benefits of Certified Stoves (PDF) (3pp, 448k) - U.S. Environmental Protection Agency. This document summarizes the benefits of using an EPA-certified wood burning appliances versus a conventional wood stoves.
Characterization of Organic Compounds from Selected Residential Wood Stoves and Fuels (PDF) (47pp, 671k) - New Jersey Department of Environmental Protection. This study characterizes the organic compounds found in wood smoke.
Health Effects of Wood Smoke (PDF) (15pp, 202k) - Washington State Department of Ecology. This brochure summarizes the potential health impacts related to heating with wood.
Inventory of Sources of Dioxin in the United States (External Review Draft 2005) - U.S. Environmental Protection Agency. This Web page provides an inventory of the sources and amounts of dioxins released into the environment.
Particle Pollution and Your Health - U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. This document characterizes particle pollution and how it can impact human health and the environment.
Pie chart of benzo(a)pyrene emissions in the Great Lakes region (PDF) (1pg, 12k) - U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. This pie chart shows the distribution of sources of benzo(a)pyrene emissions within the Great Lakes Area.
Where there's fire, there's smoke (PDF) (2pp, 2.3 MB) - Yolo-Solano Air Quality Management District, California. This brochure describes the potential impact of wood smoke on human health.
Woodburning - American Lung Association. This Web page defines wood smoke, its potential health effects, and possible solutions to wood smoke problems.
Wood Smoke Pollution Health Effects (PDF) (8pp, 1.2 MB) - U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. This table lists pollutants found in wood smoke and their potential health effects.
Health Effects of Breathing Woodsmoke (PDF) (5pp, 59k) - U.S. Environmental Protection Agency. This document summarizes the documented health effects from breathing smoke emitted from residential wood burning.
Demographic Analyses and Environmental Justice
American Factfinder is the U.S. Census Bureau's clearinghouse for Census 2000 data. From this page you'll be able to access two types of data that you can use for demographic analyses such as Environmental Justice Analyses or housing analyses. Summary File 1 (SF1) contains information elated to basic demographics from the national to the block level. Summary File 3 (SF3) contains more detailed information that may also suit your purposes. This information is available from the national level to the block group level.
Environmental Justice - U.S. Environmental Protection Agency, Office of Compliance and Enforcement. This Web page provides basic information about Environmental Justice (EJ) and serves as the portal to additional EJ topics.
Environmental Justice Geographic Assessment Tool - U.S. Environmental Protection Agency, Office of Compliance and Enforcement. This Web page introduces a tool you can use to determine whether your area may have EJ concerns. A presentation (PDF) (25pp, 2.9 MB) about this tool is also available.
Summary of Libby, MT Using EPA Environmental Justice Assessment Tool (PDF) (16pp, 8.4 MB) (Draft) - U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. This draft memorandum describes the EJ analysis for Libby, Montana.
U.S. Census Bureau American Housing Survey - The largest, regular national housing survey in the United States. These data sets include information on ownership of wood stoves, fireplaces with inserts, and fireplaces without inserts. For more information about the American Housing Survey, check out the Sources of Data on Wood Stoves and Fireplaces (PDF) (2pp, 160k) fact sheet.
U.S. Census Bureau Summary File 3 (SF), Table H40 - These data are part of the Year 2000 sample set data and provides information on the primary home heating fuel. This information may be obtained from the national level down the the block group level. Simply follow the directions FactFinder provides and select Table H40. For more information about the Summary File 3, check out the Sources of Data on Wood Stoves and Fireplaces (PDF) (2pp, 160k) fact sheet.
Simmons Market Research Bureau (1-800-999-7672)- Simmons conducts a national consumer study by surveying many consumers nationwide (over 27,000) about product ownership and buying patterns. Their survey includes questions on wood-burning stove ownership, wood-burning fireplace insert ownership, and whether these product have been purchased in the last twelve months. For more information about the Simmons Market Research Bureau, check out the Sources of Data on Wood Stoves and Fireplaces (PDF) (2pp, 160k) fact sheet.**
Mediamark Research, Inc. (1-800-310-3305) - Mediamark also conducts a national consumer study by surveying many consumers nationwide (approximately 26,000) about product ownership and buying patterns. Their survey includes questions about ownership of coal/wood stoves and fireplaces, whether these products have been purchased in the last 12 months, and the dollar amount spent in the last 12 months. For more information about Mediamark Research, Inc., check out the Sources of Data on Wood Stoves and Fireplaces (PDF) (2pp, 160k) fact sheet.**
**Please note that the above two market research firms are examples of firms that EPA knows have conducted hearth products surveys. There may be other firms that can provide similar data. EPA does not endorse either of these firms.
Air Quality Index brochure - U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. This brochure provides an overview of the Air Quality Index and is available through this link to download in color or black and white.
AirData - U.S. Environmental Protection Agency. This Web page provides air pollution data from ambient monitoring and the National Emission Inventory.
AIRNow - U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. Provides the public with easy access to national air quality information.
National Emissions Inventory - U.S. Environmental Protection Agency. EPA estimates wood burning emissions at the county level as part of the National Emissions Inventory (NEI). For more information, contact Roy Huntley (919-541-5398).
Detailed information of PM2.5 nonattainment designations - U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. This map is a gateway to listings of PM2.5 designations for the United States.
Map of final PM2.5 nonattainment designations (PDF) (1pg, 246k) - U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. This map shows the PM2.5 nonattainment areas within the United States.
Other Studies and Data Sources
The Energy Information Agency provides data related to the types of energy consumption in each state. By clicking on the various tabs, you can find energy information related to your individual states or for multiple states.
Mid-Atlantic Regional Air Management Association (MARAMA) - MARAMA sponsored a survey of wood burning in the Mid-Atlantic Northeast Visibility Union States (CT, DE, DC, ME, MD, MA, NH, NJ, NY, PA, RI, VT, the Penobscot Indian Nation, and the St. Regis Mohawk Tribe). Although the survey covered a limited population size, it provides information on wood stove and fireplace usage, and on the amount of wood burned in surveyed households. For more information about the MARAMA study, check out the Sources of Data on Wood Stoves and Fireplaces (PDF) (2pp, 160k) fact sheet. MARAMA also has a final report (PDF) (22pp, 11.4 MB) available related to its residential wood combustion emissions inventory.
Heating Equipment Usage Study: Shoshone County: 2003 (PDF) (2.3 MB) - Idaho Department of Environmental Quality. This study summarizes the heat equipment usage in Idaho's Silver Valley.*
Housing studies such as the American Housing Survey for the Pittsburgh Metropolitan Area in 1995 (PDF) (co-authored by the U.S. Department of Commerce and the U.S. Department of Housing and Urban Development [HUD]) can provide information about heating sources used in housing. (See pp. 4, 6, 15, and 34 for examples of heating data.)
An Integrated Community Approach to Reducing Residential Woodsmoke: Community Analysis and Education (PDF) (1.0 MB) - Lincoln County Department of Environmental Health.*
What is the process for developing and implementing a Wood Stove Changeout Campaign?
- It All Adds Up Initiative - An organization that promotes local agencies which implement air quality and transportation activities within their jurisdiction.
- Spokane County Air Pollution Control Authority has joined the Community Partners initiative. Their Web page shows how they have integrated their participation in this program into their publicity materials.
- Steel Recycling Institute - Use this link locate local steel recyclers who could participate in your changeout campaign by recycling old wood stoves. To determine how they can help you, click on appliances (wood stoves are considered appliances) in the left hand sidebar. To locate the closest steel recycler to you, click on Steel Recycling Locator in the left hand sidebar.
- Commonly Asked Questions Regarding the Tax Deduction for Old Wood Stove Replacement (PDF) (6pp, 447k) - Idaho Department of Environmental Quality. This document answers questions state and local agencies may have about tax deductions for old wood stoves.*
- The Foundation Center - This organization allows you to research grantmakers and grants awarded to find funding that may match the needs of your Wood Stove Changeout Campaign.
- Funding Databases and Instructions (PDF) (1pg, 85k) - U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. This document lists different databases where you can find information about funding and provides instructions on how to use them. [NOT OFFICIAL EPA DOCUMENT]
- Grantmaking Organizations (PDF) (69pp, 2.8 MB) - This document provides a listing of grantmaking organizations as well as a brief description of each.*
- National Foundations and Multi-City Foundations (PDF) (18pp, 3.4 MB) that may provide grants - U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. This table summarizes foundations that may provide funding for a Wood Stove Changeout Campaign. [NOT OFFICIAL EPA DOCUMENT]
- A Toolkit for States: Using Supplemental Environmental Projects (SEPs) to Promote Energy Efficiency (EE) and Renewable Energy (PDF) (66pp, 1.9 MB) - U.S. Environmental Protection Agency, Office of Atmospheric Programs. This document describes SEPs and how state and local agencies can use them.
- Santa Clara County Changeout Program rebate
application (PDF) (2pp, 49k) . This application gives an example of what a rebate
application could look like.
- Funding Options Table (PDF) (3pp, 23k) - a detailed overview of potential wood stove changeout funding sources including descriptions of funding organizations, websites, and points of contact.
- Funding Options Summary (PDF) (2pp, 318k) - provides brief description of potential funding options for wood stove changout programs; useful as a handout for planning meetings.
Burn it smart! participant survey (PDF) (52k) - Environment Canada. This survey can serve as an example to use when developing your own survey to use after you have completed your campaign.
Burn it smart! tracking form (PDF) (45k) - Environment Canada. This form provides an example of how a form can be used to track stoves turned in. Note that you can develop the form with multiple carbon copies for better tracking.*
Burn Smart, Burn Clean: How It Works (PDF) (35k) - Northwest Hearth, Patio, and Barbecue Association. This document provides an example of what can be included in a kit sent to retailer participants.*
Burn Smart, Burn Clean key message (PDF) (74k) - Northwest Hearth, Patio, and Barbecue Association. Check out this key message, which can serve as a go-by for your key message.*
Burn Smart, Burn Clean registration letter (PDF) (104k) - Northwest Hearth, Patio, and Barbecue Association. This letter is an example of the type of letter you could write when campaign participants register.*
EPA-Certified Woodburning (PDF) (271k) - Hearth, Patio, and Barbecue Association. This fact sheet provides information about EPA-certified wood burning.
The Great American Wood Stove Changeout: Radio Script Concepts (PDF) (12k) - The Frause Group. This script can serve as a go-by for your own public service announcements on the radio.*
The Great Wood Stove & Fireplace Changeout stove tag (PDF) (1.0 MB) - This tag was used on EPA-certified stoves within the area of the Great Wood Stove & Fireplace Changeout program.*
Guidance for Quantifying and Using Emission Reductions from Voluntary Wood Stove Changeout Programs in State Implementation Plans (PDF) (22pp, 202k) - U.S. EPA. This document was written to help States, Tribes, and local governments quantify emission reductions from wood stove changeouts, and credit those reductions towards meeting the PM NAAQS.
Hearth, Patio, and Barbecue Association (HPBA) Product Fact Sheets - The HPBA has developed several fact sheets related to different types of heating appliances. These may be helpful in developing information packets for distribution to the public as part of your Wood Stove Changeout Campaign.
Key Messages: Residential Wood Combustion National Education Program (PDF) (280k) (draft) - Residential Wood Combustion Multi-stakeholder Task Group on Education and Change-Out. This document describes how to formulate a key message for a Wood Stove Changeout Campaign.*
Wood Heat in the Real World (PDF) (378k) - Teton County, WY. This flier offers another example of public outreach materials.
Implement Wood Stove Changeout Campaign
- Options to Reduce Emissions from Residential Wood Burning Appliances - Environment Canada. This document is an example of a document used as the basis for discussion in a stakeholder workshop.
- Puget Sound Energy Wood Stove Replacement Program Participant Approval Form (PDF) (116k) - Building Performance Center. This form provides a go-by you could use for a participant approval form.*
- Puget Sound Energy Wood Stove Replacement Program Report/Invoice (PDF) (113k) - Building Performance Center. This form shows an invoice form that could be adapted for your own campaign.
- Brochure Examples
- Flier Examples
- Burn Smart, Burn Clean (PDF) flier (748k) - Northwest Hearth, Patio, and Barbecue Association. This flier can serve as an example. This brochure provides an example of how you could convey information about a rebate program to your citizens.*
- How to: Keep Home Fires Clean (PDF) flier (102k) - The Great Wood Stove & Fireplace Changeout. This flier provides an example of a flier used to announce a Wood Stove Changeout Campaign event.*
- Santa Clara County Rebate flier (PDF) (2.0 MB) - This flier is an example of how to advertise a rebate program.*
- Wood Smoke: Light it Right for a Cleaner Fire Tonight (PDF) (2.0 MB) - Air Districts of Sacramento, CA region. This flier shows why burning wood at night can be detrimental to air quality.*
- The 2004 Great Okanagan Wood Stove Exchange Program: Synopsis (PDF) (493k) - Central Okanagan Regional District Air Quality Program. This report summarizes the Okangan Wood Stove Exchange Program and is an example of how to write a report about the results of a Wood Stove Changeout Campaign.*
- Burn it Smart! in Eastern Ontario (PDF) (282k) - The Wood Heat Organization. This report summarizes the results of the Burn it Smart! campaign in Eastern Ontario.*
- The Crested Butte Experiment: An Air Quality Analysis Scheme to Identify Particulate Impacts Associated with a Wood Stove Replacement Program (PDF) (295k) - Colorado Department of Health. This report describes the results of an air quality analysis after a wood stove changeout in Crested Butte, Colorado.*
- Georgian Bay Wood Stove Changeout and Education Program: Report (PDF) (45k) - Telephone Survey - Hearth Products and Barbecue Association of Canada. This report describes a telephone survey conducted in Canada.*
Other Information Resources
- Spare the Air in the Wintertime too! (PDF) (2.2 MB) - Bay Area Air Quality Management District. This brochure describes the Spare the Air campaign, which is sponsored by Bay Area Air Quality Management District.*
2007 Residential Wood Smoke Workshop - March 14-15, 2007, in Reno, NV
This third in a series of annual workshops brought together Federal, State, local, and Tribal air quality and health officials to share their experiences and knowledge about residential wood smoke and wood stove changeout programs. With each year, the base of knowledge and expertise in planning, managing, and evaluating wood stove changeouts expands, making these workshops an excellent opportunity to learn and network with others. For your reference, presentations used at the workshop are provided below.
- Bay Area Woodstove Changeout Program (PDF) (24pp, 1.0 MB) J. Colbourn and R. Borrmann, Bay Area Air Quality Management District
- Libby, Montana Woodstove Changeout Program (PDF) (40pp, 2.5 MB) J. Marquez and R. Anderson, Lincoln County Health Department
- Measurable Outcomes of a Woodstove Changeout on the Nez Perce Reservation (PDF) (30pp, 3.3 MB) T. Moliga, Nez Perce Environmental Restoration and Waste Management
- Oneida Woodstove Changeout Program (PDF) (42pp, 6.2 MB) J. Mears, Oneida Environmental Health and Safety Division
- PM2.5 Monitoring Data for Libby, MT (PDF) (15pp, 57k) J. Coefield, Montana Department of Environmental Quality
- Sacramento Wood Stove/Fireplace Change Out Program (PDF) (29pp, 980k) A. Kennard, Sacramento Metropolitan Air Quality Management District
- Social Marketing and Woodstove Exchange (PDF) (41pp, 3.5 MB) T. Wakelin, British Columbia Ministry of Environment
- USDA Rural Development Overview (PDF) (20pp, 148k) M. Ramme, U.S. Department of Agriculture
- Warm Homes, Clean Air: An Oakridge Community Project (PDF) (20pp, 1.1 MB) Sally Markos, Lane Regional Air Pollution Authority
- Washoe County Woodstove Changeout Program (PDF) (6pp, 89k) A. Goodrich, Washoe County District Health Department
2006 Residential Wood Smoke Workshop
This EPA workshop, held March 8-10, 2006, in Salt Lake City, UT, brought Federal, State, local, and Tribal air quality and health officials together to discuss the impacts of residential wood smoke and approaches to address those impacts. Following up on the experience of the East-West Lessons Learned Wood Stove Changeout Workshop (Atlanta, GA, February 24, 2005), the 2006 workshop included an overview of the health impacts of wood smoke, considerations for State, local, and Tribal air quality officials with regard to the proposed air quality standards for fine particulates, and presentations on wood stove changeouts (Libby, MT, Darrington, WA, and Southwestern Pennsylvania), funding options, key Tribal issues, and local ordinances for residential woodsmoke. For your reference, presentations used at the workshop are provided below.
- British Columbia & Old Wood Stoves (PDF) (24 pp, 430 KB) Tony Wakelin, British Columbia
- Ontario's Residential Wood Combustion Program (PDF) (14 pp, 305 KB) Victor Li, Environment Canada
- Helping a Rural Community Tackle its Wood Smoke (PDF) (33 pp, 2824 KB) Amy Fowler/Mike Schultz, Puget Sound Clean Air Agency
- Wood Stove Changeout Funding Options (PDF) (7 pp, 74 KB) Larry Brockman, U.S. EPA
- Nature & Magnitude of the Wood Smoke Problem (PDF) (25 pp, 1153 KB) Gil Wood, U.S. EPA
- Wood Stove Changeout Program: Libby, Montana (PDF) (93 pp, 5211 KB) Ron Anderson, Lincoln County Health Department, MT
- Beyond Burn Bans: The Puget Sound Wood Smoke Control Program (PDF) (15 pp, 1378 KB) Amy Fowler, Puget Sound Clean Air Agency
- EPA's Residential Wood Smoke Reduction Initiative (PDF) (22 pp, 995 KB) Larry Brockman, U.S. EPA
- Proposed Revisions to Particulate Matter NAAQS (PDF) (12 pp, 714 KB) Mark Schmidt, U.S. EPA
- Southwest PA Wood Stove Changeout Program (PDF) (30 pp, 148 KB) Tom Lattener, Allegheny County, PA
- Washoe County Residential Combustion Control Program (PDF) (7 pp, 145 KB) Andy Goodrich, Washoe County District Health AQMD, NV
- Introduction to Hearth Products (PDF) (13 pp, 380 KB) John Crouch, Hearth, Patio & Barbecue Association
- Health Effects of Wood Smoke (PDF) (41 pp, 2783 KB) Ron Moolenaar & Joshua Mott, Centers for Disease Control & Prevention
- Air Emissions from Residential Wood Combustion (PDF) (113k) - Omni Environmental Services, Inc. This presentation discusses air emissions from residential wood combustion.
- Buying an EPA-Certified Wood Stove (PDF) (532k) - U.S. Environmental Protection Agency. This brochure answers questions people may have about buying an EPA-certified wood stove.
- Comparison of Test Standards from Various Countries (PDF) (221k) - Sintef Applied Thermodynamics. This document examines wood-fired applications test standards in various countries.
- Facts About Burning Wood (PDF) (274k) - Puget Sound Clean Air Agency. This flier supplies basic facts about wood burning.
- A Guide to Residential Wood Heating - Natural Resources Canada. This Web document provides a basic discussion about heating with wood and is available for downloading in pdf format from the Web page itself.
- How to Buy a Hearth Product (PDF) - Hearth, Patio, and Barbecue Association. This fact sheet describes how to buy a hearth product.
- National Policy Impacts Derived from The Crested Butte Wood Stove Study (PDF) (186k) - U.S. Environmental Protection Agency, Region 8. This paper describes the policy impacts of the Crested Butte Wood Stove Study.
- Residential Wood Combustion Technology Review: Volume 1: Technical Report (PDF) (136k) - U.S. Environmental Protection Agency, Office of Research and Development. This report describes EPA's review of different types of residential wood combustion technology.
- Residential Wood Combustion Technology Review: Volume 2: Appendices (PDF) (376k) - U.S. Environmental Protection Agency, Office of Research and Development. This document is an appendix to the technical report described above.
- Review of Wood Heater and Fireplace Emission Factors (PDF) (96k) - U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. This paper describes a technical review of the emission factors associated with residential wood burning.
- Upgrading Wood Stoves in a Small Town as a Primary Strategy Towards Visibility Improvement (PDF) (187k) - Wood Heating Alliance. This paper describes the results of the Crested Butte, Colorado study.
- What You Should Know About Combustion Appliances and Indoor Air Pollution - the Consumer Product and Safety Commission, U.S. Environmental Protection Agency, and the American Lung Association. This Web page provides information the public should know about combustion appliances and indoor air.
- Wood Burning Handbook: Protecting the Environment and Saving Money (PDF) (911k) - California Air Resources Board. This document provides basic information about residential wood burning.
- Woodburning Handbook (PDF) (885k) - Bay Area Air Quality Management District. This document provides basic information about residential wood burning.
- Wood Smoke - A Winter Health Problem (PDF) - Bay Area Air Quality Management District and the American Lung Association. This brochure provides information about the dangers of wood smoke.
**Please note that some information in this library comes from outside sources and was scanned into the library. These resources will be denoted by an asterisk (*) and do not necessarily represent the views of the EPA.