Air Quality Groups Be a part of Lawsuit more than EPA Stove and Boiler Rules

Posted by Earth Stove on April 25, 2015 with No Comments as , , , , , , , ,
On April 15, three air quality groups filed a motion to join the lawsuit that a hearth industry group is bringing against the EPA over their new wood stove and boiler regulations.  These groups said that their interest lies in “defending the Final Rule against challenges brought by industry groups seeking to further weaken or delay it.” This development is likely to make the suit more difficult for the hearth industry.
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The most prominent of the groups, the American Lung Association (ALA), has a long history of both cooperating with the EPA and also being part of suits against it.  Their motion suggests that the EPA’s new rule could or should be stricter, but they do not appear to be suing for stricter emissions standards.  If the air quality groups had chosen to sue for stricter standards, they would have risked having the rule sent back to EPA for revision, which could backfire as a revised rule may not be issued until 2017 or later, when a Republican nominee could potentially be running the EPA.
The industry strategy may be precisely that –to send the rule back to EPA for revision, then to try to delay the revision until a more sympathetic administration takes over.  But this strategy also poses a risk for industry, as the revised rule could emerge even stricter depending on who takes charge of the EPA.
The hearth industry group, the Hearth Patio and Barbecue Association (HPBA) a loose amalgamation of wood, pellet, gas, grilling and outdoor furniture industries has not yet laid out the basis of its suit and is not required to do so until the DC Circuit Court sets a briefing schedule.  The date for oral argument is usually set 6 to 8 weeks after the date final briefs are due, and the three-judge panel for oral argument typically is not be announced until shortly before the argument.
There is still time for HPBA to file a petition for reconsideration with the EPA.  The most likely scenario is that the rule will become law on May 15, 2015 and the HPBA will be focusing on challenging the stricter Step 2 emission standards, which take effect in 2020.  Other parties can still file a suit, or a motion to join this suit, until May 15. 
The other two air quality groups who joined the suit along with ALA are the Clean Air Council (CAC) and Environmentand Human Health, Inc.(EHH).  CAC is based in Philadelphia and focuses on a wide array of energy and environmental issues.  EHH is a small group based in Connecticut and has worked on outdoor wood boiler pollution for many years.  All three groups, the ALA, CAC and EHH, were active in the comment process on the rule.  Earthjustice, a public interest law firm that does not charge its clients, is representing the groups.   The Environmental Defense Fund, which had teamed up with these three groups on earlier litigation, did not join this intervention.
In the groups’ motion to intervene, they said, the “Hearth Association will likely seek to weaken or delay the Final Rule’s requirements, as their comments during the rulemaking sought to weaken protective measures required under the Final Rule. For example, the Hearth Association objected to EPA’s use of emissions testing as a quality assurance tool to verify manufacturers’ ongoing compliance with emission standards.”
One strategic point of this lawsuit will be the selection of the 3-judge panel, which is done at random.  Generally, insiders tend to consider Republican appointees more industry-friendly and Democratic appointees more inclined to support public health groups.  History has shown that judges can be less-than-predicable in terms of how they deal with threshold legal issues such as standing, ripeness, procedural issues, or deference owed to the agency, and their decisions on these issues rarely break down along party lines.  Although everyone will be interested in knowing the three judges that will form the panel, knowing who they are is rarely enough to predict how the case will turn out.
The new EPA rules cover everything from very clean pellet stoves to extremely dirty outdoor and indoor wood boilers.  Most pellet stoves and some wood stoves, for example, already meet the 2020 standards and are very affordable. The industry lawsuit is likely to focus on 2020 standards that some indoor and outdoor wood boilers will struggle to meet, as well as 2020 wood stove standards that will raise the cost for some stoves.  In the 6 months leading up to the announcement of the rule, the industry focused mainly on delaying the rule’s implementation for indoor wood boilers.
For more information about the rule, see “What Consumers Need to Know about the NewStove Rule.”

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What Customers Require to Know about New EPA Wooden Stove Principles

Posted by Earth Stove on March 16, 2015 with No Comments as , , , , , ,
In the prolonged guide-up to the&nbspEPA’s new guidelines on wooden and pellet stoves and boilers, there have been a lot of claims, predictions and fears. &nbspHere is a summary of the crucial factors in the NSPS that will effect you, the consumer.

The rule turns into legislation on Friday, Could 15, but will not expect to see many, if any, adjustments in your nearby hearth store until finally Jan. 1, 2016. &nbsp Scroll to the bottom to see a timeline of implementation.

Wooden stoves: Shoppers will scarcely notice any adjust right up until 2020. &nbspAs of 2016, stoves need to not emit a lot more than four.five grams and right after May fifteen, 2020, two grams an hour. &nbspThe most significant around term modify is that the actually cheap, uncertified stoves will no longer be on the market place after Jan. 1, 2016.&nbsp (These stoves, typically manufactured in China, sold for $ 300 – $ 600.)

Pellet stoves: Buyers will not discover considerably change listed here both. &nbspAs of Jan. 1, 2016 all pellet stoves will have to be accredited by the EPA.&nbsp Some designs are also very likely to get a lot more productive. &nbspIn 2020, pellet stoves also have to emit no more than two grams an hour. &nbspMost pellet stoves currently meet up with the 2020 normal.

Costs: There need to be no short time period price tag rises, but some companies say their prices may go up $ three hundred – $ four hundred in 2020.&nbsp Other folks say their prices won’t rise at all.

Retail “sell-through” period of time: Suppliers have until Dec. 31, 2015 to sell present stock.&nbsp Many stores do not carry something that can’t be offered below the new guidelines in any case. Beware of revenue this summer season and slide that are striving to unload inefficient stoves and boilers ahead of its unlawful to sell them!

Existing and next hand stoves: Existing stoves are not impacted by these principles, nor is the vibrant next hand marketplace for wooden stoves. States can regulate current and uncertified stoves and Washington and Oregon do not enable any person to set up an uncertified stove off the second hand market place.&nbsp All states enable customers to purchase and install 2nd hand licensed stoves.

Corn, coal and multi-gasoline stoves: Corn and coal stoves are not coated by EPA policies and can carry on to be marketed without any federal government emission regulation, so extended as they will not market that they can also use wood or pellets. Multi-gasoline stoves are no longer allowed.&nbsp Accredited stoves can only be marketed for the fuel that they are examined with, and there is not yet a check strategy for corn or coal.

Misleading promoting: Most companies have posted unverified and exaggerated efficiency claims on their brochures and sites.&nbsp The new principles specify how stove effectiveness is to be tested and noted, but its nonetheless mysterious if the&nbspEPA will crack down on the rampant exaggerated and misleading performance statements.&nbsp Blaze King and Seraph are only businesses that offer verified, correct performance figures of all their stoves to customers and the EPA. &nbspBeware of any stove that advertises more than 83% efficiency. &nbsp

Efficiency:&nbspThe EPA will start to demand effectiveness tests and reporting, but ninety five% of existing stoves will not have to be examined until 2020, so handful of stoves will be required to publish performance quantities.&nbsp To day, most organizations nonetheless deal with confirmed efficiency as private documents.

New hangtags: The EPA is receiving rid of the aged hang tags that consumers have been accustomed to on the showroom ground.&nbsp Instead, they are issuing particular, voluntary cling tags only for those stoves and boilers that presently meet the stricter Step 2 specifications (2 grams and hour) or that have been made and analyzed with cord wood. This will support shoppers far more effortlessly recognize the cleaner stoves and people that are made to be used with cordwood – the same variety of gas that customers use.&nbsp (At present, all stoves are analyzed with 2x4s and 4x4s, which burn off very differently than wire wood.)

Carbon monoxide (CO): The new principles do not limit the quantity of CO that can be emitted but call for that it be analyzed and documented. As with effectiveness, it is nonetheless unclear if CO levels from existing stoves will be obtainable before 2020.

Stoves examined with cordwood: The policies established up an option, voluntary compliance option for Stage two emission stages of 2.five grams an hour for stoves examined with twine wood. &nbspThis recognizes leaders in the industry who are optimizing their stoves for using twine wooden and encourages other producers to follow their case in point.

Export stoves: US producers can continue to make and promote stoves with no emission controls or tests to nations that even now let this.&nbsp These stoves have to be labeled as an “export stove. Could not be offered or operated within the United States.”&nbsp

Litigation: The deadline to file match over this rule is Might fifteen, 2015. &nbspThe major stove and boiler industry association, the HPBA, has indicated it will be filing suit, most likely above the cost usefulness of the 2020 emission requirements. &nbspAir quality or environmental groups might also sue, claiming the new specifications are as well lax. Our lawful professionals say that a go well with from both aspect would be hard to acquire.

Boilers &amp Furnaces

Boilers: Like stoves, boilers must fulfill Stage one emission boundaries by Might 15. &nbspRetailers can still offer more mature, uncertified and unqualified boilers through Dec. 31, 2015. &nbspIn 2020, they have to fulfill stricter emission limitations. &nbspDue to a schism between domestic boiler manufacturers and people importing far more superior European technologies, most examination labs are not willing to take a look at the imported units. &nbspThey may possibly face limitations to turning out to be certified by Jan. one, 2016.

Warm air furnaces: Furnaces that heat air, instead of water, got a reprieve from the EPA after intense advocacy by industry and force from Congress. &nbspSmall types have to satisfy Step 1 emission standards by May 15, 2016 and big kinds not until finally May 15, 2017.

Value: As opposed to stoves, possibilities for consumers will adjust much more, since the boiler furnace market had not been controlled and a lot of low-cost, lower-performance models were on the market place. &nbspPrices – and efficiencies- are likely to rise substantially but running fees will be significantly lower.

Humidity meters: Furnaces have to appear with a free dampness meter as of Jan. 1, 2016. &nbsp(Some advocates experienced urged all stoves to appear with moisture meters.)&nbsp

Heated Up!

Excessive Wood Stoves: Odd and Progressive Designs from Historical Greece to Nowadays

Posted by Earth Stove on March 12, 2015 with No Comments as , , , , , , , ,

Over the centuries, wood stove makers have tried all sorts of designs to transfer heat to a room and to capture the imagination of consumers – or just their own imagination.  Some emphasize design and beauty over function and efficiency.  Others are both practical, efficient and the result of centuries of experimentation.  And some are destined for the dustbins of the history of heat.  For a detailed chronology of wood heating, click here.  We hope you enjoy them as much as we did, and encourage you to send ones that you think should be included.

Visit our other international photo essays on firewood collection and stacking, wood fired hot tubs and typical wood stoves.

Ancient Greek clay anthrakia. Greeks experimented with designs to heat, cook – and to BBQ.
Troy New York, near Albany, was the stove building capital of the world in the late 1800s, when ornate stoves like this were popular.
Vermont. Amen to that.
This Russian masonry heater/bed will keep you warm on the coldest Siberian night. 
Alsatian (French) stove with large exhaust gas heat exchanger. Stove makers have long experimented with expanding heat transfer surfaces.
 The power go out and you have lots of ironing?
 A German masonry stove
The world’s largest wood stove.  Michigan, USA
The world’s smallest commercially available wood stove? Aptly named, the Sardine and made in Washington state.
 “Bender Bending Rodriguez” by UK’s Rob Halftroll

Cat Tractor themed stove in Oregon

Somewhere in Eastern Europe.

An Estonian sculptor makes these stoves from old Russian mine shells.
The Italian stove maker Castlemonte’s new stackable stoves.

Somewhere in Western Europe. (Would you want this in your living room?)
Can the design get any simpler?
Dutch designers eliminated the need to cut your wood with this stove.
A Swiss made “rocket” stove.

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Utah invoice HB 396: A Hastily Crafted Invoice that Misses the Mark

Posted by Earth Stove on March 2, 2015 with No Comments as , , , , ,
Winter inversions, caused mainly by cars
and trucks, often obscure the Utah legislature
in a cloud of pollution that can last days.

A bill was just introduced in the Utah House of Representatives that would mandate certain types of change out programs, set air quality levels that can be used to call no burn days and otherwise undermine the ability of the state to help move toward cleaner burning and cleaner air.

The key to reducing wood smoke in Utah’s populated and often polluted valley surrounding Salt Lake City is a genuine partnership between the states air quality division, industry and other non-profits and stakeholders.  Ultimately, solutions are going to require funding, especially if a change out program is involved, which can be expensive.  For any significant amount of money to be used for change outs, the Utah governor and air quality division should support the change out, not have HB 396 thrust upon them, which will tie their hands.

Utah Governor Herbert’s proposed seasonal ban was ill conceived and drawn up without sufficient consultation.  HB 396 was similarly drawn up without sufficient consultation and will not lead to genuine solutions that can get solid funding.

Like most others, the Alliance did not support the seasonal ban proposed by the Governor, but HB 396 is not the solution.  HB 396 was drafted by key stove industry members and reflects the interests of some stove retailers and manufacturers, but does not embrace many solutions which can benefit homeowners who heat with wood and pellets.

There are a variety of proven ways to reduce wood smoke while protecting the rights of families who heat with wood and pellets.  HB 396 only refers to several strategies and it ties the hands of the Division of Air Quality, without even providing funding for solutions.  Wood stove change out programs are one of the effective strategies, but HB 396 does not include many options and best practices that other jurisdictions use in change outs to support high efficiency wood and pellet heating while reducing emissions at the same time.
This hastily crafted bill needs to emphasize the interests of all Utahans, more than the just retailers and stove manufacturers who drafted the bill.  Lines 28 and 29 which require consultation with representatives of the solid fuel burning industry while not mentioning representatives of other concerned groups is unfortunate.  The solid fuel burning industry does not represent the consumers who use their products any more than any other industry group represents consumers of their products.  For instance, one of the most important reasons people heat with wood and pellets is to save money, particularly lower income families.  However, the solid fuel burning industry refuses to release the efficiencies of the stoves they sell.  Some pellet stoves are between 40 – 50% efficient and some are between 70 – 80% efficient, but industry has long stonewalled consumer interests to know which stoves are more efficient than others. 
Industry has also actively opposed change out and incentive programs which require the disclosure of efficiency or only make the cleanest stoves eligible for replacing older, uncertified stoves.  Such options and programs, however, benefit consumers and should be considered in any change out program.
Ultimately the solution in Utah, like in any jurisdiction, requires the active engagement of all stakeholders and the consideration of all solutions – and funding.   If industry, DAQ, and other stakeholders can agree on the parameters of a change out program, it will be far easier to secure funding each year and for that funding to have the most impact.  HB 396 will not achieve that and pits the solid fuel industry against the interests of many other key stakeholders.
For these reasons, we urge the Legislature to vote against HB 396.
Over the last 4 years, the Alliance for Green Heat has also advocated on behalf of families who heat with wood and pellets with members of the Utah legislature, the Utah Division of Air Quality and the Utah Air Quality Board.  We provide expert background on wood heating technology, wood smoke emissions, and analysis.
On the current debate in Utah, we issued three short papers to help policymakers and the public better understand the importance of wood and pellet heating and options to improve air quality:
On February 24, we provided an informal briefing at the Utah Division of Air Quality (DAQ) on options for reducing wood smoke that other jurisdictions are pursuing, none of which include a ban on stove use.  That powerpoint can be downloaded here: Utah presentation.pptx

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HEPA Air Filters Display Very good Benefits at Minimizing Indoor Wooden Smoke

Posted by Earth Stove on February 18, 2015 with No Comments as , , , , , , , , ,
By Diane Peng and John Ackerly*
Alliance for Green Heat
If you smell wood smoke in your house, you should go to the source and fix the problem. But if the source is a neighbor’s stove or outdoor wood boiler, it can be very difficult to solve the problem.  Recent research suggests that a high-efficiency particle air (HEPA) filter can reduce indoor wood smoke by up to 60%. Even small amounts of smoke from backpuffing when you open your stove to reload it can pose a health concern and may warrant the investment in a HEPA air filter. 
This highly rated Whirlpool HEPA air
filter cost under $ 300.
Wood smoke contains two types of pollutants that that are of major concern, particulate matter and carbon monoxide (CO). Particulates from wood smoke  range in size from 0.01 to 0.1 microns and can penetrate deep in the lungs, causing respiratory ailments. Carbon monoxide is a colorless, odorless, and tasteless gas that can be lethal when concentrations grow high enough in contained spaces. Having a working carbon monoxide meter in your home is vital to your safety. Fortunately, carbon monoxide is unlikely to be a problem if the smoke is from your neighbor’s stove or boiler, because the concentration will be too low.  An air filter will help reduce particulate matter.
Many air filters claim that they are effective at reducing particulates including from wood smoke, but only HEPA filters have been proven to be effective.  The June 2012 issue of Consumer Reports rated HEPA air purifiers and found the Whirlpool AP51030K ($ 300) and the Hunter 30547 ($ 260) to the most effective and “Best Buys.”
Fireplaces are much more likely to cause
indoor wood smoke problems than wood
stoves.  Your nose is an excellent instrument
to tell if smoke is leaking into your home.

Indoor air pollution poses a real threat to human health. The air we breathe inside our homes can be filled with dust, pollen, animal dander, smoke, and many other physical and chemical pollutants, sometimes making indoor air more harmful to our health than outdoor air. Simply opening a window and providing ventilation can reduce the amount of pollutants inside our homes, but when this solution is not sufficient, many turn to indoor air filters.
Air filters direct air through a filter that removes any suspended particles. They can be portable units for individual room purification or cartridges that are installed directly into the home’s HVAC (heating, ventilation, and air conditioning) unit for home purification. The filter itself can be made out of a variety of materials: foam, cotton, fiber, and synthetic fibers. Pleated fibers work best because they provide greater surface area for which to catch the pollutants. One major limitation to air filters is its inability to filter larger particles because they settle from the air before reaching the filter. It is also important to note that these types of filters remove particle pollution only; gaseous pollutants such as carbon monoxide will not be removed from the air.
Filter efficiency is measured by the minimum efficiency reporting value (MERV). MERV values range from 1 – 20 with higher scores corresponding to more efficient removal of particles. High-Efficiency Particulate Air (HEPA) filters have MERV values ranging from 17 – 20 and have met the U.S. Department of Energy standard of removing 99.97% of particles greater than 0.03 microns from the air that passes through. HEPA filters are not traditionally installed in a home’s HVAC unit but are found in separate filtration devices.
Both old and new wood stoves can leak
smoke into the home.  Its often the installation
and the chimney, not the stove, responsible
for leakage. A CSIA certified chimney sweep
is an excellent resource to find and help
remedy indoor smoke issues.

Wood particles are between .01 and .1 micrometer.  One source gave the average at 0.07. According to the EPA, HEPA filters can filter particles as small as 0.03 micrometers in size.
Researchers from the University of Montana and other experts published a paper, “Evaluating the Effectiveness of a Commercial Portable Air Purifier in Homes with Wood Burning Stoves” in the Journal of Environmental and Public Health in 2011 and found that a portable HEPA air filter is an effective option for reducing particle concentrations in homes that use wood burning stoves as their primary or secondary heating source. Particle concentrations of the homes in the study decreased 61-85%.. Another research group also found that installing a HEPA filter significantly reduced particulate pollution. In addition this group found that people living in these homes saw a 32% average decrease in their levels of C-reactive protein, a marker of inflammation and cardiovascular disease.
One thing to keep in mind is that it is always better to prevent the problem rather than try to fix it. The best solution to purifying indoor air is to remove the source of contamination. This can be hard to do if the source of wood smoke inside your house is a neighbor’s outdoor wood boiler. Smoke from a neighbor’s outdoor wood boiler could very well end up inside your own home through your ventilation system.
Bottom line: If you have any level of detectable wood smoke in your house, go to the source and fix the problem.  If you can’t fix it, it is probably time to upgrade your stove and have it professionally installed, particularly if you have a stove made prior to 1988 that is not certified by the EPA.  If you can’t replace or fix the leaky stove, an air filter may be an inexpensive way to mitigate the particulate matter problem. Even with an air filter, however, carbon monoxide may still remain a serious pollutant in the home.   Given the potential negative health impacts of any prolonged exposure to wood smoke and other indoor air pollutants, there is a growing body of scientific evidence that HEPA filters may significantly improve air quality in homes effected by wood smoke and that these reductions may have positive health benefits.

An air filter intervention study of endothelial function among healthy adults in a woodsmoke-impacted community,  Am J Respir Crit Care Med.2011 May 1;183(9).
Hart JF, Ward TJ, Spear TM, Rossi RJ, Holland NN, Loushin BG. Evaluating the Effectiveness of a Commercial Portable Air Purifier in Homes with Wood Burning Stoves: A Preliminary Study. Journal of Environmental and Public Health. 2011 Jan: 2011: 324809
Ogulei D, Hopke PK, Wallace LA. Analysis of Indoor Particle Size Distributions in an Occupied Townhouse Using Positive Matrix Factorization. Indoor Air. 2006 Jun;16(3):204-15.
INDOOR AIR QUALITY: Wood-Burning Stoves Get Help from HEPA Filters

* Diane Peng was a Research Fellow at the Alliance for Green Heat and is now a medical student.  John Ackerly is the President of the Alliance.  Thanks also to edits from Derek Rogalsky, a medical student at Georgetown Medical School and the lead author of Estimating the Number of Low-Income Americans Exposed to Household Air Pollution from Burning Solid Fuels.

Heated Up!

New EPA Stove Rules Begin Cleaner Chapter for Wooden Heating

Posted by Earth Stove on February 6, 2015 with No Comments as , , , , , ,
Statement by the Alliance for Green Heat on the Wood Heater NSPS

Key EPA architects of this NSPS include
Greg Green, left, and Gil Wood,  right  and
Amanda Simcox. Gil retired on February 3. 
Overall, the EPA did a good job and released a fair rule that includes many compromises between industry and air quality agencies.  We think these rules are good for consumers and will not drive prices up substantially for most product categories, but will result in cleaner and more efficient appliances that will ultimately save consumers time and money. This is our initial reaction to the rule, which we will be followed by a more thorough analysis.

High performance stoves: The EPA took some key steps to address the lack of recognition for high performing appliances. Notably, stoves that test with cordwood in the next 5 years can use a special EPA label that will alert consumers that the device is designed and tested for use like the consumer will use it. This shift is possibly as important than just lowering emission standards for wood stoves. Along these lines, the EPA is also allowing stoves that already meet the 2020 standards, to use a special label so consumers can more easily recognize these higher performing stoves. We are, however, very disappointed that the EPA removed the long-standing requirement that all stoves have a consumer hang-tag that helps consumers better appreciate the basic differences between all stoves on the showroom floor.

Boiler testing: Another positive step forward is EPA’s recognition of the European test method EN303-5 to certify European style indoor wood and pellet boilers that have been accepted by Renewable Heat New York (RHNY). Also boilers certified by the New York State Department of Environmental Conservation (NYSDEC) will be automatically deemed EPA certified. This is another step to recognizing higher performance equipment. NYSERDA deserves credit for the R&D, test method and other funding that EPA and DOE should have been doing to develop higher performance equipment. These parts of the new EPA rule will help give consumers more options to buy cleaner and more efficient devices.

Stove emission standards: As expected, the EPA is staying with the de facto status quo for the next 5 years, at 4.5 grams an hour (g/hr). The 2 g/hr standard for stoves as of 2020 is fair and reasonable. As the EPA explained in the rule “nearly 90 percent of current catalytic/hybrid stoves and over 18 percent of current non-catalytic stoves” already meet the Step 2 emission limit of 2 g/hr. We hope that those manufacturers who have to redesign stoves use the opportunity to redesign to use cordwood and to reduce start-up and fugitive emissions. The optional Step 2 certification test for cordwood at 2.5 g/hr represents a very creative and positive approach by the EPA to move towards required cord wood testing.

Some independent stove and boiler companies played a vital role in broadening the debate and sharing key data sets that enabled the EPA to show that some stoves can already meet the Step 2 standards of 2 g/hr with cordwood. We are pleased that companies who participated in the 2013 Wood Stove Design Challenge helped the EPA and OMB understand that smallest manufacturers can undertake the R&D to make very clean and affordable stoves that operate well on cordwood.

Key issues not addressed: Some of the most important issues with wood stoves are difficult to address in regulations, such as indoor air quality from fugitive smoke and the ability for homeowners to reduce air-flow so much that the stove smolders for hours on end, which is often a nightly occurrence. Ultimately, we believe that some types of automation are needed to prevent the widespread consumer misuse of wood stoves. The attempt by the EPA to set a maximum emission level while the stove is on its lowest burn rate was a good start. We had urged the EPA to more formally address alternative tests for automated stoves that hold tremendous promise to reduce widespread poor operation by consumers.

Warm air furnaces: Delaying the standards for all warm air furnaces for 1 – 2 years was a mistake because some companies have little ability or intention of meeting the Step 1 standards. An interim measure after 6 months to distinguish between companies on their way towards meeting standards and those who aren’t would have been far better.

Exempt wood stoves:
We are very pleased to see that the era of exempt wood stoves is over. About 1 out of every 3 or 4 new wood stoves sold in America has been exempt in recent years and EPA had considered a weaker standard for them, but is now holding them to same standard as all other stoves.

Masonry heaters:
The EPA was not able to set standards for masonry heaters but we are glad to see that the EPA has charted a path forward to work with the Masonry Heater Association so that masonry heaters become a certified appliance category

Sell-through period: The sell-through period, set at 8 months through December 31st is fair for certified wood stoves, pellet stoves and qualified or EN303-5 approved boilers, but too long for exempt wood stoves and traditional outdoor boilers which should have come off the market sooner.

Electronic reporting: We were very glad to see that the EPA will begin electronic reporting for stove certification tests and provide more transparency for the public and access more data that is not Confidential Business Information (CBI) about stove tests.

Efficiency: Achievable efficiency standards are important in the near future and we are pleased that the EPA will finally require the manufacturers to test for, and report actual efficiency numbers not only to the EPA, but also on their websites. In practice however, many existing stoves many not have to retest for 3-5 years and it is unclear if they will have to disclose efficiency before then, unless they do it voluntarily. This is particularly important for boilers and pellet stoves that have a very wide range of efficiencies.

Renewable energy: We are very disappointed that the EPA did not mention the term “renewable” in this rule. The EPA Office of Air and Radiation should take into consideration that this sector has potential not just to make cleaner energy, but to use a renewable energy source and displace fossil fuels. Governor Cuomo’s Renewable Heat New York is investing tens of millions into the sector and integrates the goal of driving down emissions, driving up efficiency while replacing fossil fuels and offering homeowners an affordable, renewable heating source. In addition to setting minimum emission standards for lab testing, the EPA should adopt a more integrated approach to this technology that is being increasingly adopted not just by New York, but by other states as well.

In conclusion, the EPA crafted a fair and balanced rule overall and took some important steps towards testing with cordwood and recognizing those companies who take steps to build stoves based on how consumers operates them. In the long run, this new rule will result in cleaner appliances and a better foundation for renewable wood and pellet heating.

Full EPA rule and fact sheets

Wood and pellet stoves

Step New PM emissions limit Compliance deadlines
Step 1: All uncertified wood and pellet stoves (cat and non-cat) 4.5 grams per hour for crib wood test method

If tested with cordwood, emissions test method must be approved, and stoves must meet crib wood limit

60 days after publication in the Federal Register
Step 2: All wood and pellet stoves (cat and non-cat) 2.0 grams per hour, or 2.5 grams per hour if tested with cordwood (test method must be approved) 5 years after publication in the Federal Register (2020)

Hydronic heaters

Step New PM emissions limit Compliance deadlines
Step 1 0.32 pounds per million Btu heat output (weighted average), with a cap of 18 grams per hour for individual test runs (crib wood test method)

If tested with cordwood, emissions test method must be approved, and stoves must meet crib wood limit

60 days after publication in the Federal Register
Step 2 0.10 pounds per million Btu heat output for each burn rate, or 0.15 pounds per million Btu heat output for each burn rate. If tested with cordwood; method must be approved 5 years after publication in the Federal Register (2020)

Warm air furnaces

Step Standard Compliance deadlines
Step 1 Operational/work practice standards 60 days after publication in the Federal Register
Step 2 Emissions limit of 0.93 pounds of PM per million Btu heat output, weighted average. Cordwood testing is required for forced air furnaces Small furnaces: 1 year after publication in the Federal Register (2016)

Large furnaces: 2 years after publication (2017)

Step 3 Emissions limit of 0.15 pounds of PM per million Btu heat output for each individual burn rate. Cordwood testing required All furnaces: 5 years after publication in the Federal Register (2020)

Related stories:
Private Talks Yield Consensus on Key Issues in NSPS
Paper Undermines Stove Industry Variability Study

Heated Up!

Wooden Heating Trends in Utah

Posted by Earth Stove on February 4, 2015 with No Comments as , , ,

The proposal by the Governor of Utah to ban the wintertime use of wood and pellet stoves was met with intense opposition from a large majority of Utah residents and the wood stove industry. It also underscored the need for Utah state agencies, the media, and the public to better understand the role of wood heating and its prevalence in the United States. This short paper compares census data of wood heating in Utah compared to the rest of the country.

As of 2013, 10,500, or 1.2%, of Utah residents use mainly wood and pellets for their primary heating, far less than the national average of 2.1%, according to the US Census. There are likely to be an additional 40,000 to 50,000 who use it as a secondary heat source, though the US Census does not track secondary heating.  The EPA however estimates that there are about 93,000 wood and pellet stoves in Utah, some of which may not be used at all or only occasionally.

Utah is one of the states that buck the national norm, in that far more homes heated with wood and pellets in 1990 compared to 1940. Utah residents gave up wood heating faster than the United States as a whole, with the number of homes mainly heating with wood hitting a low point in 1950, two decades before the rest of the country. But between 1970 and 1990, Utahns embraced wood heating far more aggressively than the rest of the country. The number of Utah homes mainly heating with wood rose from 0.3% in 1970 to 3.2% in 1990, a high point that the state has not hit since then.

The rapid growth of wood and pellets in Utah since 1970 is likely due to many of the same reasons it has grown so quickly elsewhere: both gas and oil prices had been climbing, until gas prices finally dropped in 2008 and oil prices just starting dropping in 2014.  And, the increase of wood and pellet heating may also be linked to an increased desire for household energy security by both conservative and liberal households, but for different reasons.

Median household income remained relatively static in Utah for most of the 2000s before they began falling in 2008 and rising again in 2012, compared to the US where incomes first decreased in 2007 and only started recovering in 2013. Often, more households turn away wood heating as incomes rise and this is likely a factor in Utah since 2012 as well.

Since 2005, the percent of Utahns using wood or pellet as a primary or sole heat source has ranged between 1% and 1.4%, and since 2010 has remained steady at 1.2%, significantly below the national rate of 2.1% that has remained unchanged since 2009. Wood heating peaked in 2009, at the height of the recession and dropped slightly as the economy has picked up.

Wood and pellets are the fastest growing heating fuel in Utah, followed by electricity, as it is the US overall. Wood and pellet heating as a primary heat source had increased nearly 40% in Utah from 2000 to 2013, slightly less than the nation overall.

Utah is quite different than national heating trends when it comes to gas and oil. Gas heating has grown 30% in Utah since 2000, yet has only grown by 4% nationally. This increase in gas heating may be tied to slower growth of wood heating in areas with gas lines, while wood heating remains robust in areas without gas lines. Accurate county data could confirm this.  And oil heating has dropped far quicker in Utah than it has in the nation overall, although it has not been a very widespread form of residential heating in Utah.

Utah has the lowest percentage of homes heated primarily with wood in the West.  The Census does not have county level data of wood heating in Utah, but typically rural counties have far more wood heating than more urban ones.  And, lower income counties typically have more primary wood heating and higher income counties have more secondary wood heating.

EPA Estimates of Fireplaces, Stoves and Boilers in Utah

The EPA figures, above, estimate nearly a quarter million wood fueled devices in Utah.  A majority of those are fireplaces and studies show that a large percent of fireplaces are never used or only used once a week, unlike stoves which are often used every day.  About 93,000 units are stoves, nearly 16,000 of which are pellet stoves, 48,000 uncertified stoves (most made prior to 1990) and 26,000 are EPA certified stoves, made since 1990.

Heated Up!

Flurry of Lobbying on Furnaces and Test Strategies on Eve of New Stove Policies

Posted by Earth Stove on February 1, 2015 with No Comments as , , , , , ,
The Office of Management and Budget
is in the Old Executive Office Building
next the White House.

Sources confirmed that the EPA is set to announce the new wood heater rules on Tuesday, February 3rd, the court ordered date.  After years of debate and anticipation about cost impacts and emission standards for stoves and outdoor boilers, the issue that has become the most contested on the eve of the announcement is warm air furnaces.

Even though the big decisions were all supposed to be made last fall, there has been intensive lobbying by stakeholders right up until Friday afternoon, January 30th – one business day ahead of the announcement. At least 2 groups met with the Obama Administration through the Office of Budget and Management (OMB) on Friday, January 30th. During January, interest groups had at least six other meetings with OMB, lobbying for last minute changes to the proposed rule.

The patterns, attendees and paperwork left behind at OMB meetings this month offer a unique glimpse into some of the most contested areas of the rule. Thanks to sunshine laws that make records of meetings with government agencies public, the public can see a list of who met with the OMB in the weeks leading up to the announcement of the rule.

The short term fate of warm air furnaces (WAF) appears to be the top priority of the hearth industry because they represent the only product category where most existing models cannot be made or sold for a period of time after the rule becomes law and before they become certified. HPBA participated in two meetings in January along with their legal counsel and consultant, Jack Ferguson, and various of their member companies, including US Stove, Central Boiler, Hardy, Heatmor and Hawken Energy.

Jack Goldman, CEO of the Hearth Patio & Barbecue Association, said in a letter to EPA that this is “clearly a death sentence” to most of the companies making warm air furnaces. The EPA says that they do not have the legal authority under the Clean Air Act to delay implementation of emissions standards. Warm air furnaces are the only class of wood heaters that will be required to meet emission standards, but are still unregulated and have no ability to be tested and certified until the rule is announced.

Another hot topic that emerged in recent months is a dispute over the opposite end of the spectrum, unregulated hot air furnaces – high performance indoor boilers, often made in Europe, but now being made in the US. The EPA certified test labs refuse to use a test method for these appliances developed by DOE’s Brookhaven National Lab and funded by NYSERDA, which captures some start-up emissions and uses cord wood instead of cribs. This is emblematic of a long simmering rift between test methods for outdoor wood boilers and European style indoor boilers with thermal storage, which offer the potential for cleaner combustion. NYSERDA and Econoburn, a NY manufacturer who makes these furnaces ask, “Who should really benefit? Those who innovate or those who refuse to?”

Other meetings in January with OMB and key stakeholders include one with about a dozen air quality agencies and states; with representatives of the Pellet Fuels Institute and a pellet testing facility; and with Intertek Test labs. Attendees in meeting between OMB and indoor and outdoor boilers and furnace manufacturers, and with NYSERDA and New York manufacturers are also in the public record.

If participants of the meetings provided OMB with documents, those documents are also public. Three key documents were provided this month, two from HPBA on a their legal argument (PDF) to delay compliance for hot air furnaces and a survey (PDF) commissioned by HPBA of HPBA member retailers on sell through trends. Four of the groups that met with OMB did not leave materials and there is as of now no record of the topics raised at those meeting. The only other document from the final month of intensive lobbying was from NYSERDA, NESCAUM and New York based companies.

Heated Up!

Sample Wood Smoke Nuisance Restrictions

Posted by Earth Stove on January 29, 2015 with No Comments as , , , ,
This outdoor wood boilers in Morgan
County Utah was somehow found not
to be a nuisance by a County Judge. 

Many jurisdictions in the Western US have “burn bans” that disallow the use of wood or pellet stoves when air quality is very poor, often in conjunction with weather inversions.  Nuisance regulations, on the other hand, apply when one person is creating excessive smoke that bothers an immediate neighbor.  That person may be using an EPA certified stove, an old stove or an outdoor or indoor boiler.

The purpose of this paper is to show the range of standards by which excessive smoke is measured.  Lack of resolution between neighbors is all too common, due sometimes to a lack of a clear nuisance standard for that town or county, or simply due to a lack of the ability or willingness to enforce a nuisance standard. 
If a jurisdiction has no written standard or regulation, the sample provisions below offer an excellent starting point for the jurisdiction to adopt.  Most jurisdictions use “opacity” as a measure of smoke – meaning the ability to see through it.  An opacity of 20% or lower is often listed as acceptable, but not always.  In some regulations, a specific amount of start-up time is exempted, ranging from 6 to 20 minutes in these sample regulations. However, many wood stove experts say 20 – 30 minutes is often the time needed to get a fire without visible smoke.

The Ringellman chart or scale was developed in 1888 and is still sometimes used and referenced today.

The Ringellman scale was adapted by the US Bureau of Mines.
The Alliance for Green Heat has noticed an increase in complaints about wood smoke.  We know that in many cases excessive wood smoke results from burning unseasoned wood, caused in part by the shortage of seasoned firewood this year.  Too many people with wood stoves wait until the fall to order wood and too many firewood distributors try to pass off unseasoned wood as seasoned.

The proposed ban of stoves in Utah has also brought the issue of “responsible burning” to the forefront, with industry calling for EPA certified equipment to be exempt from any ban.  These nuisance provisions, with a few exceptions, make no distinction between the kind of device that is being used, and focus solely on how well the operator is using it. 
No person shall cause or allow the emission of smoke exceeding twenty-percent opacity from any flue or chimney, except for a single fifteen-minute period for cold start-up. Any emission in excess hereof is hereby declared to be a nuisance and is prohibited.
A person who operates in a densely populated area an outdoor wood-burning device that produces visible emissions, measured as any opacity, totaling 12 minutes in any hour that cross onto land or buildings immediately adjacent to a dwelling or commercial building not owned by the owner of the outdoor wood-burning device creates a nuisance.
Massachusetts Department of Environmental Protection (MassDEP) regulations limit visible smoke (or “opacity”) and prohibit air pollution that places people at risk, interferes with property uses, threatens natural resources, or creates nuisances, such as excessive odor and soot.

* Existing sources outside special control areas. No person may emit any air contaminant for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 40% opacity.
* New sources in all areas and existing sources within special control areas: No person may emit any air contaminants for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity.

* A nuisance is anything which is injurious to health, indecent, offensive to the senses, or an obstruction to the free use of property, so as to interfere with the comfortable enjoyment of life or property. A nuisance may be the subject of an action.
* A nuisance under this part includes tobacco smoke that drifts into any residential unit a person rents, leases, or owns, from another residential or commercial unit. [There is no mention of wood smoke or opacity in the nuisance provisions of the Utah Code.]

No person shall cause or allow a visible emission from any wood-burning device in any building or structure that exceeds No. 1 on the Ringlemann Chart or 20 percent opacity for a period or periods aggregating more than three consecutive minutes in any one hour period. Visible emissions created during a fifteen-minute start-up period are exempt from this regulation.

* Certified wood heaters may be operated during a no-burn period provided that no visible emissions are produced after a twenty (20) minute period following start up or refueling.
* During a period in which the Director has not declared a no-burn, no person shall operate a solid fuel heating device in a manner which produces emission into the atmosphere if the emissions exceed 30 % opacity twenty (20) minutes or longer after ignition or refueling of the solid fuel burning device. Visible emission opacity shall be determined by an observer certified by the Director.

Smoke shall not exceed an average of 20% opacity for any 2-minute period during an hour or average of 40% for 6 minutes after start-up.
The emission into the open air of visible smoke from any residential indoor non-wood pellet-burning appliance or any non EPA-Phase II certified wood burning appliance or fireplace used for home- heating purposes in such manner or in such amounts as to endanger or tend to endanger the health, comfort, safety or welfare of any reasonable person, or to cause unreasonable injury or damage to property or which could cause annoyance or discomfort in the area of the emission, is prohibited.

* During a green or yellow advisory, no person in charge of property shall operate or allow to be operated a solid-fuel space-heating device which discharges emissions that are of an opacity greater than 40 percent. This provision does not apply to the emissions during the building of a new fire, for a period or periods aggregating no more than ten minutes in any four-hour period.
* Upon a determination that a person has violated section 6.255 of this code, the city manager may impose upon the violator and any other person in charge of the property, an administrative penalty not greater than $ 500.

Fort Collins, CO
* After the first 15-minutes of start-up, smoke from the chimney must be at or less than 20% opacity (smoke should be barely visible looking at it with your back to the sun).
* Violation of City Code can result in a summons to appear in municipal court resulting in a fine of up to $ 1,000 and 180 days in jail.

No person may operate a solid fuel-fired heating device in such a manner that visible emissions reduce visibility through the exhaust for more than 15 minutes in any one hour by 50% opacity or greater.

* No person shall discharge into the atmosphere from any source of emission whatsoever any air contaminant greater than 20% visible opacity as determined by Test Method described in subsection A, for a period in excess of six (6) minutes in any consecutive sixty (60) minute period.
* Any emissions from portable, stationary, or motor vehicle sources in excess of 40% opacity, regardless of length of time, are considered excessive emissions.

* State law limits the density of smoke from indoor fires to ensure that people use clean burning techniques. This requirement is called the 20 percent smoke opacity limit. Opacity means how much your view through the smoke is blocked.
* 100 percent opacity means you can’t see anything through the smoke. 20 percent opacity means there is very little smoke and you can see almost perfectly through it. If you use dry enough fuel, the right equipment, and give your fire the right amount of air, there should be no visible smoke from your chimney or stove pipe–only heat waves.
* There are two exceptions to the opacity rule which allow you limited time for denser smoke:
• Starting the fire. You have up to 20 minutes every four hours.
• Stoking the fire. You have up to six consecutive minutes in any one-hour period.

Heated Up!

As Utah debates seasonal stove ban, Salt Lake County adopts stricter guidelines

Posted by Earth Stove on January 23, 2015 with No Comments as , , , , , , , , ,
The proposed state seasonal
ban affects 75% of the Utah
As Utahns debate a seemingly doomed proposal to ban seasonal stove use,  Utah’s most populous county enacted its own rules banning stove use on both mandatory and voluntary air actions days as of Jan. 1, 2016. In other counties, voluntary air action days continue to be voluntary.

This will impact about half of all wood burning appliances in the non-attainment counties and could contribute significantly to reducing wood smoke.  Salt Lake County has nearly 102,000 wood burning appliances, with fireplaces accounting for a majority of that with 60,000 units, according to EPA figures.  There are nearly 20,000 uncertified wood stoves and about the same number of pellet stoves and certified wood stoves.  

This stove inventory was provided by EPA who use a variety of databases and sources to estimate the deployment of wood burning devices.
The governor’s seasonal ban proposal that would impact 7 counties in and around Salt Lake City is drawing intense and sustained criticism from Utah residents, with only a few people speaking up in support of the ban.  It’s also drawing national attention from the wood stove industry that wants a 2-stage system, where EPA certified stoves could be used in stage 1 and all stove use banned in state 2.
On the other hand, Salt Lake County, which has a more than a third of the state’s population and nearly half of the population and half the stoves in the Wasatch front non-attainment area, went the opposite direction, including all stoves, certified and uncertified, in both stages of air action days.  “This is a significant measure and with more enforcement could achieve a quarter to a half of the reductions that the Governor’s plan sought,” said John Ackerly, President of the Alliance for Green Heat.

The issue has become an emotionally charged debate about individual rights vs. government control, striking a nerve within a deeply conservative part of the country.  In the public hearings, many people have testified about not being able to afford any other fuel than wood, and not wanting to be forced to use fossil fuel when they can use a cheaper renewable. 
But for air quality officials, the issue is simply about cleaning up the air and meeting federal air quality goals that are tied to highway funding.  The discussion quickly becomes about what the state can enforce and what it can’t.  The problem is that the state compliance capacity is already overstretched, with little ability to take on wood stoves.
However, that is different in Salt Lake County, which is moving ahead to enact stricter rules.  The County has decided to undertake the investigations of wood burning on mandatory no burn days itself, instead of leaving those to the state, which now only issues the fine.  Typically the initial warning is viewed an education process that leads to compliance, so that while many $ 25 fines have been given, rarely has the maximum of $ 299 been imposed. 
The new Salt Lake County rules, which take effect on Jan. 1, 2016, were not a reaction to the governor’s proposal or a rejection of the stove industry’s recommendations.  The County’s process began before the state’s process and ended before the stove industry got involved and helped set up the advocacy group Utahns for Responsible Burning.
According to officials at the Salt Lake Country Health Department, there was virtually no support for exempting EPA certified stoves from the county rule.  Both certified and uncertified stoves can produce excessive smoke, depending on operator behavior and moisture content of wood, with uncertified ones performing worse, on average.  While most EPA certified stoves produce 2 to 4.5 grams of particulates an hour in the lab when they are tested with specially prepared dry wood, they often produce far more in the real world.
The Alliance for Green Heat is urging Utah officials to consider phasing out uncertified stoves, since reducing the number of wood stoves will have the biggest impact.  “It may be that only about half of wood burners are really burning responsibly, whether they own a certified or uncertified stove,” Ackerly said.  “The uncertified stoves made before 1988 are now obsolete and most should not be used in densely populated areas,” Ackerly continued.

The current debate over wood heating comes less than 2 years after the outdoor wood boiler industry fought against Utah regulations that would prevent the installation of wood boilers on the Wasatch Front.  That debate also brought national attention of industry who hired lobbyists in Utah.  The industry effort to keep the market for outdoor boilers open in the non-attainment area was partially based on an argument that outdoor boilers were cleaner than wood stoves.

That case, like the current debate, involved questions of emissions data from test labs vs. emissions in the real world, and the likelihood that operators would be burning responsibly.

Heated Up!