Posted by Earth Stove on March 2, 2014 with No Comments
Along with proposed regulations, the EPA printed 367 files that are now offered for public review and scrutiny.  Many are obtainable to the public for the initial time.  Several of the paperwork are long, substantive scientific studies, check info and formal displays to the EPA by various stakeholders.  But other files are e mail threads that the EPA deemed considerable.
The trove of paperwork can be located here at Rules.gov
Regulations.gov serves as EPA’s digital public docket
and on-line comment system.
The files variety span two many years of analysis, studies and reports about wooden warmth emissions, health impacts, screening problems and regulatory troubles.
Incorporated are all substantive correspondence in between states, air good quality agencies, industry and other individuals.
Attorneys will be sifting through the documents to see whether or not the EPA has a “reasonable basis” to suggest the emission limits and other needs that it selected.
The files also provide to gentle key controversies in the fireside local community regarding the NSPS.
Aside from the problems surrounding examination approaches for out of doors boilers, documents present that non-catalytic stove companies engaged in a concerted effort to discredit catalytic stoves. A team of companies compensated for a agency to conduct a review that showed catalytic stoves work nicely in the laboratory, but not in the arms of consumers who really don’t operate them accurately.
They concluded that catalytic stoves need to be held to a 2.5 g/hr regular and non-cat stoves held only to a 4.5 g/hr.
This internecine fight, and possibly other folks, could undermine the ability of the HPBA to existing a unified voice to EPA and is most likely to be raised throughout the February 26 community hearing in Boston.
This is also the web site exactly where the public can see the feedback produced considering that the rules ended up posted on the Federal Sign up on Monday, February five.  As of Tuesday, February 27, 153 remarks have been posted, numerous of which are anonymous, limited, impassioned statements telling the EPA that the rules are unneeded or counterproductive.  Some are from makers and other folks that tackle the specifics and implications of numerous elements of the proposed rule.
Posted by Earth Stove on February 28, 2014 with No Comments
Most of the controversy at the EPA’s public listening to on their new residential wood heater restrictions was not about outside wood boilers or other unregulated heaters but about the conventional wood stove.
The biggest bloc of speakers was from market that appeared to have a effectively-coordinated, constant concept that these principles are sick conceived and counter-productive.  Most of the market speakers manufactured the position that the policies would like elevate expense of stoves significantly, therefore slowing the change from previous, much more polluting stoves, to new, cleaner ones.  They mentioned the resolution to wood smoke must emphasis on shifting out older stove, not striving to squeeze yet another gram an hour or two out of newer types.
Far more than a dozen air good quality officers and advocates spoke just as passionately about the want for cleaner stoves, expressing general assist for the proposed rules and arguing for a limited timetable for them to take effect.  Condition officials from NH, VT, MA, CT, MN and WA argued for the regulations whilst a single condition, Maine, sided significantly more with market.  Patricia Aho, Commissioner from the Maine Office of Environmental Protection expressed numerous reservations about the proposed rule, like strong reservations about a shift toward a lot more catalytic stoves.  Several condition officers known as for Section 1 expectations, which just take impact proper absent, to be stricter.
An assistant for Senator Patrick Leahy from Vermont mentioned the Senator was typically supportive and would be offering official written feedback.  He like several of the speakers talked about the value of wooden stoves for center and reduce-revenue buyers. A legislator from Missouri on the reverse aspect of the political spectrum said it is very clear that the “EPA is attempting to outlaw wood stoves” and that the EPA should not permit “environmental groups to be concerned in the rulemaking.”
A single notable big difference among the EPA and most state officials is that state officials also all talked about the importance of wood and pellet as a neighborhood, cost-effective and renewable vitality supply, themes that are mainly absent in the EPA proposal or website.
One steady conversing stage echoed by many sector presenters was that catalytic stoves executed effectively only in the laboratory and that customers did not operate them effectively in their homes, leading to surplus pollution.  A lot of in market called on the EPA to enable non-catalytic stoves to fulfill a more lenient emission common even though keeping cat stoves to a far more stringent 1.  Tom Morrissey, proprietor of Woodstock Soapstone vigorously defended catalytic stoves and named into question a report funded by US and Canadian non-cat producers.
While most of industry speakers supported modify-outs above tighter emission specifications for new stoves, one producer who tends to make the exempt, uncertified stoves appeared to advocating for ongoing ability to market these stoves.  The EPA estimates that about twenty,000 new exempt, uncertified stoves are marketed and installed each and every yr.
Numerous of the companies argued for the need for promote-by means of intervals and more lead-time to comply with the new specifications.  Other stakeholders named for an end of the sale of unqualified outdoor wood boilers as soon as possible, with no market-through period of time.
An importer of European boilers urged the EPA to also settle for the Brookhaven take a look at strategy for boilers with thermal storage and established an achievable emission concentrate on for that technique which involves start-up emissions.  A retailer of Central Boiler out of doors boilers from New Hampshire talked about his decrease-revenue shoppers who could not afford a competent unit, and urged the EPA to let him to a reasonable sell-through time period for his competent units.
A producer of fireplaces known as on the EPA to control fireplaces, instead of exempting them again, as the EPA proposes.  The American Lung Association strongly supported this, also urging that fireplaces be regulated.  Many associates of masonry stove builders urged the EPA to more function with them to make certain that their units could be qualified.
The CEO of US Stoves famous that the SBA and OMB had severe troubles with the EPA’s proposed guidelines and stressed how numerous of their consumers ended up reduced-cash flow residences that are very delicate to even small value boosts.  US Stoves and other individuals at the moment market quite a number of EPA licensed versions in the $ 600 – $ 900 variety, equivalent to the price of stoves in the seventies when modified for inflation.
Several companies, which includes the Alliance for Green Warmth, spoke of the benefits of shoppers having entry to third-get together verified performance quantities employing a consistent performance measurement and obtaining that amount prominently shown on a hold-tag on the showroom flooring.  The EPA proposed to remove the hangtag with no clarification as to why.
Baffled about stove efficiencies?  You are not alone.  Even most individuals in the sector are perplexed – or really don’t want to really let buyers know what is likely on.  Granted, it is complex and tough to describe stove efficiencies to men and women who are not experts, but stove companies also have their own incentives for obfuscating what the quantities truly imply. Heating with wooden and pellets can be an excellent way to affordably warmth your residence with a nearby, renewable gas.  But the sooner the EPA demands companies to disclose precise efficiencies, the much better it will be for shoppers.
Listed here are 4 primary factors why stove efficiencies are unreliable:.
one. Not like all other heating and cooling gear that has third party-verified efficiencies, the EPA has in no way necessary that stove manufacturers report their analyzed efficiencies.  The consequence is that stove companies routinely promote efficiencies that are increased than their genuine efficiency.
two. This confusion turned even worse in 2009 when the IRS said that companies can self-certify their effectiveness employing the European decrease warmth value (LHV) relatively than the American greater heating value (HHV).  Virtually overnight, every manufacturer claimed that all their stoves have been at the very least 75% successful in get to qualify for the federal tax credit rating (which at that time was $ 1,500 but has now expired.)
three. Numerous pellet stoves are not EPA-qualified, and, as a result, may possibly have extremely minimal efficiency. The EPA regulates particulate subject in wooden and pellet stoves that have an air to fuel ratio of less than 35 to 1.  If they have an air ratio higher than that, they operate a lot more like a hearth, and are not controlled. Some organizations decided to put excess air through their firebox to keep away from regulation but this helps make their effectiveness fall substantially. The EPA internet site  explains that “
Some pellet stove designs are topic to the wooden stove regulations, whilst other people are exempt thanks to a substantial air to gas ratio.” About half of all pellet stoves are not qualified.  Despite the fact that most pellet stoves on the marketplace nowadays have efficiencies earlier mentioned sixty%, there are some as reduced as 40 – fifty%.  Even so, nearly all assert to be at minimum 75% for reasons of the federal tax credit score.
four. Producers can use a variety of different techniques to test for effectiveness and choose the way that makes their goods search most successful.  Moreover, they can do the testing in their very own lab instead of obtaining a reputable, 3rd social gathering lab do impartial testing.
That said, not all manufacturers exaggerate their quantities and most make dependable, excellent top quality stoves.  But there is not a tradition of transparency amid stove producers, but rather a lifestyle that only discloses what is necessary by regulation to be disclosed.  There are three factors shoppers can do to shield them selves from acquiring an inefficient stove.
one. Purchase a stove that reports its real efficiency final results to the EPA.  A handful of producers have not too long ago provided the EPA with 3rd celebration-verified effectiveness figures, and we hope much more will do so in the foreseeable future.  There are now 19 stoves on the EPA’s record with third confirmed quantities utilizing HHV.  The greater part of these are wooden stoves.  Only one pellet stove producer, Seraph, has offered verified effectiveness quantities.  Blaze King is the only business to offer confirmed efficiency quantities for all their stoves. For a checklist of the 19 stoves, click on here.  Usually, catalytic stoves are five – 10% higher efficiency than non-catalytic stoves and are significantly less difficult to keep a fireplace burning cleanly and successfully right away.
2. If you want to make certain to get a higher effectiveness pellet stove, get a single that is EPA accredited.  Just take manufacturer representations about effectiveness with a huge grain of salt, especially if they do not specify no matter whether the figure is in LHV or HHV.  (A stove that is 68% HHV will most likely be close to 75% LHV.)
3. Preserve in head that with wooden stoves, efficiency is not just a purpose of the stove, but also how the operator makes use of it.  Make sure to use seasoned wooden that is below twenty% moisture content material to get the greatest performance out of your stove.
Qualifications: New, EPA certified non-catalytic stoves are almost all in the 55 – seventy five% efficiency range, HHV, with most in the high 60s and reduced 70s. Catalytic stoves will likely be in between 70% – 82%.  A 20% distinction in gas effectiveness can incorporate up to a great deal of financial savings for customers, whether or not you purchase your firewood or cut it oneself.
With pellet stoves, the efficiency variety is even increased and buyers stand to acquire or shed a complete thirty% or even forty% in gas effectiveness relying on what product they acquire.  At least one particular pellet stove on the marketplace receives only 33% performance and yet another forty nine%, but most are in the 60s and 70s, and some will be in the reduced 80s, once again calculated utilizing HHV.  Sector leaders have conceded that most pellet stoves are not 70% productive even with the EPA approximated default of seventy eight% efficiency.
Nearly no business, agency or non-revenue has brazenly and honestly discussed this issue and tried out to assist unravel the confusion about efficiency quantities. One of the number of sites that has anything on it is www.combustionportal.org.  It says “On February 6, 2007, the EPA authorized use of the CSA B415 take a look at protocol as a implies by which to decide efficiency ratings. The IRS sponsored wooden stove tax credit rating program permits producers to use a distinct technique of deciding effectiveness. IRS enables laboratories to use higher versatility in figuring out the thermal effectiveness ranking for tax credit score functions.”
The Alliance for Eco-friendly Warmth is a non-earnings client organzation that encourages cleaner and much more productive wooden heating. For more information about us and our applications, click right here.
HB 931 – Renewable Strength Portfolio Standard – Thermal Power
Day: February twenty, 2014
Committee: Financial Matters
John Ackerly, President
Alliance for Eco-friendly Heat
6930 Carroll Ave., Suite 407
Takoma Park, Maryland 20912
The Alliance for Green Heat urges the Financial Issues Committee to situation a favorable report on HB 931 both in its current kind or with amendments that leaves current biomass services in Tier one of the RPS.
|Delegate Dana Stein, sponsor of
Initial of all, we would like to thank the Maryland Thermal Strength Job Drive and assistance their recommendations. While it was disappointing that the bill to consist of thermal woody biomass in the RPS previous 12 months did not pass, the generation of this Task Power was an exceptional thought so that there could be far more regularity to thermal power pathways in the RPS.
Any RPS that focuses on only one renewable energy pathway – electrical energy – results in unfair and primarily unintended implications for other power pathways, notably heat vitality. If an RPS excludes warmth strength, we get rid of leverage above a enormous piece of the power pie. Including thermal power provides us numerous far more techniques to lessen fossil fuels and carry much more renewable systems to the desk so that we can obtain even a lot more aggressive renewable power targets.
The Alliance for Eco-friendly Warmth focuses on residential wooden and pellet heating which is by far the biggest contributor of residential renewable strength in Maryland and the United States.
There are twelve million installations of wood and pellet heating appliances in the United States, when compared to significantly less than 50 percent a million photo voltaic panel installations. Biomass warmth can tap into this massive household renewable power market place because it is much far more inexpensive than solar or geothermal. The difficulty is that most residences in Maryland and the US that use wood warmth have old stoves that are too polluting. We have focused our incentives on photo voltaic and geothermal, which favor wealthy family members and remaining out rural center and lower-revenue people who warmth with wooden and pellets. Including household thermal biomass in the RPS will extend the advantages of the RPS to average Maryland people and not just focus those benefits on the wealthy family members that set up photo voltaic and geothermal and who are typically concentrated in Montgomery and Howard counties.
We think all Maryland homes ought to have the option to participate in our renewable vitality long term and that indicates including systems like new, large performance EPA certified wooden and pellet stoves in the RPS. We commend the Maryland Power Administration for starting up a grant software for wood and pellet stoves, like they have for photo voltaic, but this rebate is basically not enough for numerous people to get over the original purchase price of a method that can properly warmth their whole property. Residential thermal RECS will enable reduced and center-earnings Maryland family members to benefit from this financial framework just like rich Maryland households.
For these factors, we strongly favor reforming the RPS to be a lot more expense efficient and far more technologies neutral in reaching the renewable vitality ambitions that are essential to Maryland’s financial and environmental overall health and properly-currently being.
HB931 creates an incentive to far more efficiently utilize our finite biomass methods, putting much less stress on the sustainability of our forests to satisfy growing energy requires. HB931 will enhance jobs, prosperity, and economic advantages related with utilizing biomass for energy in Maryland.
We support the sixty five% effectiveness bare minimum. If anything, with regard to household wooden and pellet heating, 65% is as well minimal. Most household wood and pellet heaters accomplish 70% performance and the ideal kinds are more than 80%, measured in higher heat value (HHV) using the EPA endorsed CSA B415.one calculation. Presented the varied stakeholders impacted by this laws, we believe 65% efficiency is truthful and achievable.
We also strongly assistance excluding wood squander that contains handled or painted wooden since most non-utility scale crops do not have the emission control techniques that could take care of wooden squander with out generating air good quality troubles.
Posted by Earth Stove on February 11, 2014 with No Comments
In November, 2013 the Hearth, Patio & Barbecue Association (HPBA) joined a lawsuit brought against the EPA arguing that its members have and are suffered economic injury as a result of the EPA’s failure to enact the NSPS in a timely way.
The lawsuit had already been brought by non-profits that are at odds with the HPBA – the American
Lung Association, the Environmental Defense Fund, the Pennsylvania based Clean Air Council and Connecticut based Environment and Human Health Inc. This lawsuit is is based on the statutory duty of the EPA to conduct a NSPS every 8 years and the parties to the suit gain some control over the timing of the promulgation of the NSPS.
The HPBA complaint, excerpted below, shows how some technology classes, like outdoor wood boilers, saw more benefits in a national standard than having to meet different state standards and the prospect of jurisdictions simply banning devices in the absence of national emission standards. Currently, outdoor boiler manufacturers who are part of the EPA’s voluntary program have to compete with boiler companies who do not meet any emission standards in most states.
There is widespread uncertainty among stove and boiler manufacturers about the timing of the NSPS and how quickly they will be held to the new standards after those standards are announced in 2015. HPBA is advocating for extended “sell through” periods so manufacturers, distributors and retailers can sell off stock that does not meet the new standards.
Excerpts of the HPBA’s Complaint in the matter of
American Lung Association et al and HPBA, Plaintiffs vs. Gina McCarthy, Defendant
17. HPBA’s members have suffered and continue to suffer economic injury as a result of EPA’s failure to timely complete its review and revision of the Subpart AAA standards.
18. EPA’s delay impedes HPBA’s members’ ability to meaningfully plan to assure compliance with revised regulatory requirements, and to do so without incurring additional costs due to the resultant regulatory uncertainty. In particular, woodstove manufacturers as well as manufacturers of other appliances are forced to delay specific planning or investment, or do so at the risk that their efforts may be redone in light of requirements ultimately promulgated under a revised Subpart AAA. As long as EPA continues to delay its revision of Subpart AAA standards, the costs of regulatory uncertainty continue to mount.
19. EPA’s delay also uniquely injures HPBA members in the hydronic heater and masonry heater subsets of the industry as a result of the existing NSPS’s inapplicability to these appliances. These members currently face a patchwork of inconsistent state and local regulatory requirements and, in some cases, product bans as a result of EPA’s failure to timely revise the NSPS so as to incorporate these categories of appliances within Subpart AAA.
20. HPBA’s Hydronic Heater Sub-Section wrote EPA six years ago seeking coverage under the Subpart AAA regulations so as to foster greater uniformity in hydronic heater standards, and to mitigate the costs of participation in separate state and local proceedings. EPA’s continued delay in issuing revised standards including hydronic heaters prevents manufacturers from obtaining resolution of the contentious issues surrounding these appliances and from seeking EPA-certification for their appliances. In the meantime, new state and local standards continue to be issued, including, most recently, proposed emission limits for wood heaters, including hydronic heaters, in Alaska. As a result, EPA’s members in the hydronic heater industry continue to face costs as a result of EPA’s delay.
More states are starting or changing their stove incentive programs to tighten eligibility, require professional installation, and often, to install an outside air supply. Until recently, incentive programs only required that wood stoves be EPA certified. And even though the EPA certifies many pellet stoves, it does not recommend EPA certified pellet stoves be required in incentive or change-out programs. Change-out programs designed and managed by the EPA and HPBA allowed virtually any new wood or pellet stove to be installed. The new trend led by states is changing all that.
The Oregon program
, which began in 2013, is the most complex in terms of requirements, but provides up to a $ 1,500 tax credit.
To date, the highest tax credit awarded was $ 960, according to Deby Davis of the Oregon Department of Energy.
For larger tax credits, the Oregon program requires that stoves have actual measured efficiencies and be listed on the EPA list of certified wood stoves.
Only 19 stoves to date have provided the EPA with actual efficiencies and those brands are getting a bump in sales in Oregon and Maine. If the manufacturer of the stove has not provided the EPA with an actual measured efficiency, the Oregon tax credit is $ 144 for non-catalytic stoves, $ 216 for catalytic and $ 288 for pellet stoves.
The Maine program
had required actual efficiencies but is in the process of changing to require emission limits only. The emission limits of 3.5 grams per hour for wood stoves and 2.5 for pellet stoves mirror the emission limits in Oregon. Despite a very generous $ 5,000 rebate for residential boilers, the Maine program provides only $ 250 per stove and it is still unclear how successful the program is.
The Maryland program is slightly stricter on emissions, with an upper threshold of 3.0 for wood and 2.0 for pellet stoves,
but does not require pellet stoves to be EPA certified.
As a result, it may be incentivizing some very low efficiency pellet stoves.
The program is unique in that the $ 500 – $ 700 rebate is only available to homes that do not have access to natural gas.
None of the three programs require that an uncertified stove be traded in for a new stove.
These programs mark a trend towards stricter eligibility for stoves incentivized with taxpayer funds. But managers of these programs are struggling with some unintended barriers and consequences. In Oregon, the program excludes all pellet stoves but one because only one pellet stove manufacturer, Seraph, has provided verified efficiency to the EPA. In Maine, the program initially required stoves to be installed by contractors with a solid fuel license, but did not provide for hearth professionals to do installations. That glitch is being changed as well.
The tax credit calculation in Oregon favors non-catalytic stoves over the cleaner catalytic or pellet stoves, which puts the agency in charge of the program, the Oregon Department of Energy, at odds with the Oregon Department of Environmental Quality. The Oregon tax credit amount is based on the efficiency improvement over the EPA’s default efficiency. So a non-cat tested at 70% would have a 7% improvement over the 63% default. A pellet stove tested at 75% would not have any improvement over the 78% EPA default efficiency. The program thus unintentionally puts pellet stoves at a disadvantage because the EPA set unrealistically high default efficiency for pellet stoves.
Oregon, Maine and Maryland require professional installation and Oregon and Maine require inclusion of outside air supply. In Oregon, this could mean simply a $ 35 vent that provides air within several feet of the stove. All three programs avoid “free riders” to some extent because even if the incentive does not lead to the sale, the state achieves important goals of professional installation, cleaner appliances, outside air where applicable, etc. Free riders is a term used for consumers who get a rebate but who would have made the same purchase regardless of the incentive.
The proposed new EPA stove regulations will require all stoves to be tested and listed for efficiency, but there is widespread concern that the EPA will not require — or even have the capacity to make — efficiencies available to the public within the first year or two after promulgation. This is leading Oregon and other states to consider keeping or even starting to use efficiency requirements in their incentive programs.
In the weeks since the EPA unveiled their new regulations on residential wood heaters, many myths are starting to circulate in the right-wing media about what they mean. It’s sometimes hard to tell if the authors are intentionally spreading misleading information about the regulations, or they simply haven’t done enough research to know that they are spreading rumors. Probably some of both.
Next week we will be taking a look at the language used by some environmental activists who want much broader bans on wood heating.
And sometimes it’s hard to tell who is on the right and who is on the left.
One off-grid newsletter was touting the benefits of unpasteurized milk, organic vegetable gardens – and the evils of the EPA who cozy up to big business and threaten our freedom to live healthy lives.
After reading quite a few of the articles decrying the wood stove regulations, it’s clear that they are feeding off one another and often quoting one another.
Many of the articles are from small fringe groups and websites, but some are from mainstream ones like Forbes and from ideologues at think tanks like the Heartland Institute. Here are some of the most common myths in the making:
1. The “EPA Banned 80% of Wood Stoves” Myth: “Only weeks after the EPA effectively banned 80 percent of the wood-burning stoves money-saving Americans use to heat their homes, the attorneys general of seven states are suing to force the agency to crack down on wood-burning water heaters.” That the EPA is banning 80% of stoves has appeared in numerous headlines, and refers to the estimate that 80% of stoves currently on the market do not meet the new standards that will come into play 5 to 8 years from now. True, the EPA will “ban” the production of those models 5 to 8 years from now, but those articles often do not clarify that existing stoves are not affected and are grandfathered. This writer also confused the timeline and nature of the EPA’s proposed regulations and the lawsuit.
2. The “Replacement Isn’t Allowed” Myth
: “Older stoves that don’t [meet new standards] cannot be traded in for updated types, but instead must be rendered inoperable, destroyed, or recycled as scrap metal.” Another article simplified this by saying “trading in an old stove for a newer stove isn’t allowed.” This nugget of misinformation started by quoting language about trade-out programs and then got applied to the new EPA stove regulations.
The “Sue and Settle” Myth: This is but another example of EPA … working with activist environmental groups to sue and settle on claims that afford leverage to enact new regulations which they [EPA] lack statutory authority to otherwise accomplish.” “With a wink, wink, the Federal agencies encourage outside groups to file suit against some perceived flaw in the way we live.” “Such lawsuits … are nothing but an opportunity for the courts to take power and authority from the legislative and executive branches of the government since the courts supervise the settlements. It’s a way the courts can become another legislature.” “This collusive lawsuit is intended to expand EPA authority to stop burning wood.”
Part of this is sheer myth and part is a skewed analysis of what is going on. First of all, the EPA has statutory authority already given to it by the US Congress in the Clean Air Act of 1970 (under Richard Nixon) that was updated in 1990 (under George H.W. Bush). The agency does not need to expand its powers and, for example, has the authority to regulate fireplaces but is choosing not to use that power. Second, the lawsuit filed by 7 states and another by 5 environmental groups has nothing to do with the merits of the regulation, but only to force the EPA to issue regulations and not keep delaying them. (The industry trade group, the HPBA, is also now a party to that suit.) True, the states and groups suing are ones that want much stricter regulations; however, their influence on the regulations preceded their lawsuit and happened during 2012–2013 when they realized that the EPA was going to propose far less strict regulations. It was believed by many that the EPA had become too close to industry and too dependent on industry expertise and data during a time that the EPA didn’t have enough of their own resources to do necessary testing and research.
4. The “EPA Will Force People to Buy New Stoves” Myth: “Low- and middle-class families living primarily in rural areas may be forced to spend thousands of dollars to switch to newer units or use more expensive forms of energy in order to stay warm.” No matter how often the EPA says that existing units are grandfathered and not impacted, this myth was going to gain traction. There may be some local areas that pass “sunset” laws, like in Tacoma-Pierce County, Washington, where use of old, uncertified stoves will not be allowed as of Jan
. 1, 2015.
But low-income families are often exempted, or provided funding to trade up.
Most people assume that this will add some cost to most new stoves (estimates range between $ 100 and $ 1,000) and that low-income families will be even more likely to buy and install an old, uncertified stove rather than buying a new one.
This is a legitimate issue and will undoubtedly get lots of public attention over the next year.
The EPA expects to issue final regulations in 2015. Watch for a new round of myths to arise then.
For a sample of one of the more mainstream mythmaking articles, click here
By John Ackerly
President, Alliance for Green Heat
In January I attended an amazing conference where about 60 people came together to share ideas on building cleaner, more efficient stoves.
But the conference wasn’t just about stove design; it was also about how to incentivize them, how to monitor their use, and how to deploy the clean ones more widely.
Speakers gave several presentations showing diagrams of optimal use of primary and secondary air.
Most of the discussion was about the two streams of secondary air and exactly where and when to get them into combustion chamber.
On one model, tests showed that it was critical to get the secondary air lower in the combustion chamber when the stove was operating on low so a separate channel carried it another inch down the stove wall.
And, it was found that if this air was not preheated, the stove operated just as well – often better – than if it was preheated.
One reason is that the air created more turbulence if it sank, rather than rising quickly along with the combustion gases.
Another major topic discussed was how to get people to give up their old polluting stoves and invest in new, efficient ones.
Some research showed that even when families understood how much wood they would save with a new stove, they were still very resistant to giving up their old one.
And, if they did buy a new one, the old one was not always discarded, but used in another place.
One of the most fascinating subjects concerned the use of wireless sensors that could remotely monitor the temperature of the stove so researchers could learn more about the operating habits of the owner.
PM sensors could also show how the operating habits of owners impacted indoor air quality and measure the improvement compared to the old, more polluting stove.
Outside the classroom, we lit the stoves to see how fast they would be free of visible smoke.
The following day we tested the stoves with a dilution tunnel, not for any certification, but just to learn how testing was done, and to see how design changes impacted efficiency, CO, and PM emissions.
Engineers freely shared their innovations with others, and with the government officials from the EPA and European agencies, who also attended.
What distinguished this wood stove gathering from others I was familiar with is that the engineers and experts were all sharing their work and designs without first patenting their ideas.
It wasn’t about selling anything, but about a community working together, including to help existing and potential manufacturers build cleaner stoves.
Unfortunately for some of us, the conference was about international cook stoves, not domestic heat stoves.
It made me painfully aware of how vibrant that community is in terms of sharing ideas and designs, and attracting so many different universities and small entrepreneurs.
It was organized by a non-profit called ETHOS
: “Engineers in Technical and Humanitarian Opportunities of Service”. The organization’s mandate is to facilitate research and development of appropriate technology by forming collaborative partnerships between universities, research laboratories, engineers, non-governmental organizations and the private sector.
As I sat in the sessions, which were fascinating, I kept wondering why such a collaborative and urgent campaign had developed around international cook stoves and not domestic heating stoves. Part of the reason must be that the leadership and culture in humanitarian groups, which are publicly funded, compared to the private sector where companies are vying for market share. Several of the groups and companies had DOE funding for R & D.
One of main leaders of that group is Dean Still, Executive Director of the Oregon based Aprovecho Research Center
, a world leader in open source stove technology development. Dean is a charismatic figure with seemingly boundless energy, the kind of person whom people rally around. He oversees a biomass stove research laboratory that conducts emission equipment manufacturing, and is the author or co-author of six books and dozens of technical reports and articles on clean stoves.
|Dean Still with Prince Charles
|There has been some collaboration between Aprovecho and the domestic heat stove community over the years. Dr. Larry Winiarski, a long-time Aprovecho figure, invented the rocket stove
(http://en.wikipedia.org/wiki/Rocket_stove) and Aprovecho has worked on numerous rocket mass heating stove projects in China, Tibet, Nepal, the Andes, etc. Omni Test labs, an EPA accredited wood stove test lab, helped Aprovecho set up their dilution tunnel and emission testing system for cook stoves.
After the conference, which was in Seattle, I drove down to Portland to visit Omni and Dirigo Test labs and discuss how the new EPA wood stove regulations would impact test labs.
Then I kept driving south to Cottage Grove, Oregon where Aprovecho is based.
I spent a few days with Dean Still and his dedicated team of engineers and test lab technicians (14 staff in all).
Every summer they run a “stove camp,” which I had read about in the feature story, “Hearth Surgery
,” in the New Yorker Magazine.
Stove camp is a hands-on workshop where participants try to tweak stove designs and test them to see if they can improve efficiency and emissions. Dean and I got to talking about doing a Heat Stove Camp this summer, where up to 50 participants would bring innovative wood stoves to tweak and test. Normally at stove camp, applicants are selected based on their background and pay a minimal fee. Each morning, everyone reviews the test results, which are data logged from the previous day’s tests, and discusses what design elements work best. In the afternoon, participants can alter designs in the fully equipped metal shop, and then test them again.
Dean and others think that their extended community can come up with designs that meet the 1.3 gram per hour mark without using a catalyst.
They have extensive experience using combustion fans in stoves, which some think is one of the keys to ultra low emissions.
One model that Aprovecho uses is to collectively design and test a stove, and then have a non-profit patent it so it can be open sourced, allowing anyone to build from it.
If this could be done for a stove that hits the 1.3 grams that the EPA is proposing all stoves meet in coming years, it would be a natural extension of the Wood Stove Decathlon
, and help lift all boats.
The Alliance for Green Heat welcomed the release of proposed EPA laws on residential wooden and pellet heating products, expressing that new, stricter emission requirements “will support The us embrace wood and pellet heating as a crucial renewable power that can help significantly lessen fossil gasoline usage.”
More than ten million American homes heat with wood and pellets, ten occasions far more than photo voltaic and geothermal mixed, in accordance to information from EIA and the US census. “We can harness the massive demand for this variety of renewable power if the stoves and boilers are thoroughly clean ample,” mentioned John Ackerly, President of the Alliance for Inexperienced Heat. “We imagine the emissions quantities unveiled by the EPA these days are affordable and achievable and will support the wood stove market increase and thrive in coming decades,” Ackerly continued.
The proposed rule has number of surprises in phrases of emission figures. Almost all the key quantities have been integrated in draft proposed policies shared with market, states and non-profits during 2013. But the proposed rule does replicate the considerably stricter numbers the EPA developed soon after states and air quality agencies intervened in 2012. Previously, the EPA was contemplating 2.five grams per hour to be the strictest level for wood and pellet stoves. But final calendar year, the EPA floated a one.3 grams per hour for all pellet and wood stoves and that is the amount that was unveiled right now.
The EPA is proposing that wooden and pellet stoves at first satisfy a 4.5 grams per hour standard, and then fulfill a considerably stricter regular of one.3 grams per hour 5 several years soon after promulgation. Alternatively, the EPA proposes a three-phase procedure of heading to 2.5 grams per hour soon after 3 a long time and then one.three grams an hour soon after 8 a long time.
Likewise, the EPA is proposing two alternatives for furnaces and boilers. The first would set up rigorous emission boundaries soon after 5 several years, and the next would have an intermediate phase after 3 years, and then the stricter standard right after 8 several years. Initially, heat air furnaces would only be held to .93 lb/MMBTU, while hydronic heaters would be held to .32. Ultimately, the two would need to have to get to .06 lb/MMBTU both five or 8 years right after promulgation. It is commonly expected that industry will advocate for the 3-stage approach and that EPA would be open up to this as effectively.
The EPA’s press launch stated that “when these expectations are totally carried out … [c]onsumers will also see a monetary benefit from performance advancements in the new woodstoves, which use much less wooden to warmth houses.” However, the EPA decided not to contain any effectiveness common, leaving open up the chance that some extremely inefficient units may continue to be on the market place. Wooden and pellet heating appliances are the only HVAC tools with no bare minimum efficiency standards.
Each performance and CO would have to be recorded and noted underneath the new proposed rules. To stay away from logjams in screening to the new requirements, the EPA is proposing “to allow ISO-accredited laboratories and ISO-accredited certifying bodies to boost the availability of laboratories and certifiers.”
The EPA is scheduling a public hearing on these laws in Boston on February 26. Interested get-togethers need to register by February 19 at http://www2.epa.gov/household-wood-heaters if they want to make community responses. Every person will be constrained to 5 minutes. The community has 90 days to comment on the laws following they are posted in the Federal Sign up, which is anticipated to come about in the up coming week or two.
The proposed rule does offer you an abnormal glimpse into disagreements in between the EPA, the Little Business Company (SBA) and the Office of Price range and Management (OMB).  In the Panel Report, the “SBA and OMB advisable that the EPA not go ahead with proposed emission boundaries for pellet stoves, indoor hydronic heaters, biomass pellet stoves, masonry heaters.” The EPA even so rejected this suggestion and provided a sound foundation for their proposal to incorporate pellet stoves, all hydronic heaters and masonry heaters.
The SBA and OMB also advised that the NSPS only protect parts of the country exactly where wooden smoke air pollution was substantial. They advised that states and areas where wooden smoke is not high be authorized to issue their own restrictions and consider voluntary expectations. The EPA selected to emphasize and counter these recommendations in its proposed rule, demonstrating that they have regarded these choices but discovered they ended up not justified.
The Alliance for Inexperienced Warmth is a non-earnings client advocacy group that fights for cleaner and much more efficient wood and pellet heating to help households affordably switch to a renewable heating fuel.
For the full rules see: http://www2.epa.gov/household-wooden-heaters
A summary of the restrictions well prepared by EPA, without emission figures, can be found listed here:
www2.epa.gov/internet sites/manufacturing/data files/2013-twelve/paperwork/proposed_wood_heater_nsps_overview_simple fact_sheet_1.pdf
Posted by Earth Stove on December 30, 2013 with No Comments
The Wood Stove Decathlon was a historic celebration. It was the 1st at any time attempt to get a selection of stoves in the discipline (practically, in this scenario) and take a look at them for particulate subject (PM) emissions.
|Norbert Senf, right, with Neils Wittus,
heart, and John Ackerly
For one thing untried until now, the side-by-side area-screening can declare many firsts.
It effectively in contrast stoves in a shocking range of groups which includes masonry heaters as well as retrofit kits. The undertaking was a success not only as a media function but also in advancing the actual planet tests of wood burning stoves.
Cordwood is an extremely difficult gasoline to get repeatable knowledge with simply because it is so inherently variable. To incorporate to the obstacle, PM is specifically difficult to measure, even in a laboratory. While the test results from the Decathlon ended up not adequate to offer PM numbers that allowed comparison with EPA quantities, they did allow a position of the stoves from every other. This is a considerable accomplishment in alone.
PM is the wooden gasoline pollutant of biggest desire given that it leads to the most public wellness considerations. Carbon monoxide (CO) is one more pollutant.
It is produced by incomplete combustion like PM, but it is a lot simpler to measure. It is usually not considered a overall health hazard in low atmospheric concentrations exterior of densely trafficked city locations, and sooner or later oxidizes to CO2 on its personal.
Owing to new wood burning emissions rules in Germany, two new moveable instruments for measuring PM in the subject ended up recently created there. Thankfully, this occurred just in time for the Decathlon to consider them out. The instruments are minimal to the 15-minute test cycle that is mandated in the German regulation, and as a result can only evaluate what occurs during a portion of the burn up. Measuring an whole examination cycle will definitely be a aim for foreseeable future Decathlons.
Frequent knowledge retains that minimal carbon monoxide (CO) emissions, which are easy to evaluate, will also make sure lower PM, which is hard to measure. The contest final results did not bear this out. The stove with the most affordable PM had the second highest CO. For the stove with the least expensive CO, there were 4 stoves with reduced PM. To be sure, the data set is restricted. The 15-minute check window did not enable for common values to be calculated in excess of the melt away of an whole gas load.
Repeatability is a single of the most crucial actions of information quality. Considering that each stove in the Decathlon gained two (in theory) similar take a look at runs, we can get a transient glimpse here, as effectively. Discarding obvious outliers, we see a coefficient of variation (CV) in repeat operates of forty three% on PM, 40% on CO and seven% on efficiency. This compares favorably with EPA inter-laboratory repeatability scientific studies, in which the two stoves with the biggest info sets equally arrived in at forty four% CV on PM. For masonry heaters, an MHA (Masonry Heater Affiliation) laboratory research on repeatability with dimensional lumber fuel cribs yielded 10% CV on PM, 1.5% on CO, and .26% on effectiveness.
The repeatability metric provides a useful baseline for judging information good quality in long term decathlons. There is an ongoing fueling protocol debate in the testing group among the repeatability achievable with fuel cribs, and the actual world randomness of cordwood. EPA screening is at present done with cribs. To get a repeatable EPA cordwood number could need running a big number of (costly) laboratory examination operates and taking an average. To day, very minor function has been carried out to offer information for both facet of the discussion.
All in all, the Wood Stove Decathlon was a wonderful energy in the direction of advancing our understanding about how wooden stove emissions compare in the real globe. This was notably beneficial to see for various lessons of appliances with no frequently outlined EPA tests approaches.
Useful lessons and insights have been had for developing a long term obstacle. Seeing the complicated tests issues enjoy out in true life was a distinctive academic chance for contestants, organizers, judges, regulators and the testing group by itself.
Norbert Senf was 1 of the 10 judges at the Wood Stove Decathlon. He joined early efforts to publish codes and requirements, and was a founding member of the Masonry Heater Affiliation of North America (MHA). He presently chairs the MHA Technical Committee.