Collaborative Stove Design and style Workshop Announcement

The Collaborative Wooden Stove Design Workshop to be held Nov. 4 – 7, 2014 is a gathering of stove professionals to examine, take a look at, and talk about innovative wooden stove types.&nbsp The Workshop will be held at Brookhaven Countrywide Laboratory in New York and will entail fingers-on stove testing, every day review of examination data, and a series of shows by members and other specialists.&nbsp
Apps will be accepted beginning June 2 for advanced stoves to test at the event.&nbsp Stoves should have some type of automation that significantly minimizes operator mistake, use of unseasoned wooden, and/or commence-up emissions.&nbsp To use, stove designers must agree to share examination info received for the duration of the Workshop with other members and permit contributors to inspect their technology to find out how it operates.&nbsp
The Workshop is created for contributors to share their knowledge, learn from each and every other, and explore superior stove styles that might help substantially lessen particulate emissions and fulfill potential stringent emission specifications set by the EPA. &nbspThe Workshop will also be establishing an substitute take a look at approach for automatic stoves, as authorized under the present NSPS.
The four finalist stoves will be analyzed in a dilution tunnel employing the creating ASTM twine wooden check strategy. Screening will be carried out by Brookhaven workers, Ben Myren of Myren Consulting, and other folks. &nbspEvery single participant will vote on the successful stoves.&nbsp The first prize winner gets $ 1,000.
Participants:&nbsp Because of to space restrictions, there is only space for 30 participants.&nbsp We are searching for professionals from the stove sector, the global cookstove group, universities and government businesses as properly as inventors.&nbsp Fascinated persons may possibly implement as of June 2.
Stoves: &nbspStoves should consist of revolutionary, automatic attributes that pre-empt the operator from managing air consumption, or some other technological innovation that can considerably improve true entire world efficiency by lowering odds of misuse or extended smoldering.&nbsp&nbspMitigating the influence of employing unseasoned wooden is also crucial.
Logistics:&nbsp The Workshop will be held at the Brookhaven Nationwide Lab in Upton, New York, 1.5 hrs east of New York Metropolis on Prolonged Island. &nbspThere will be a $ 250 payment per participant to go over administrative and other expenses.&nbsp Lodging will be offered in a regional lodge and contributors must go over their very own travel, lodging and meals.
Qualifications: The Collaborative Stove Style Workshop is the 2nd phase of the Wood Stove Design and style Challenge, pursuing previous year’s Wooden Stove Decathlonon the National Shopping mall in DC.&nbsp As opposed to the Decathlon, this Workshop will not be formally judged or open to the general public. Relatively, it will be a more collaborative event with some of the country’s prime stove experts.&nbsp It is partially modeled after an once-a-year “Stove Camp” hosted by Aprovecho Investigation Middle in Oregon, which utilizes an interdisciplinary method to planning stoves that are frequently not patented, but open up-sourced so that any person can create them and boost on them.&nbsp The Workshop is getting sponsored by the Alliance for Green Heat and Brookhaven National Lab.
Arranging Committee (as of Might twenty):
1.&nbsp&nbsp&nbsp&nbsp John Ackerly, Alliance for Environmentally friendly Warmth
2.&nbsp&nbsp&nbsp&nbsp Ellen Burkhard, NYSERDA
three.&nbsp&nbsp&nbsp&nbsp Tom Butcher, Brookhaven National Lab
4.&nbsp&nbsp&nbsp&nbsp Ben Myren, Myren Consulting, Inc.
5.&nbsp&nbsp&nbsp&nbsp Dean Nevertheless, Aprovecho Study Heart
six.&nbsp&nbsp&nbsp&nbsp Rebecca Trojanowski, Brookhaven Nationwide Lab
The stove and applicant application will be posted by June two on our website and website and a month-to-month summary in our publication. &nbspFor concerns or recommendations, remember to make contact with us at details@forgreenheat.org.

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Wooden Stove Tax Credit history Unlikely to be Extended in 2014

AGH, May 22, 2014 – The $ three hundred federal tax credit score to obtain a new wooden or pellet stove expired on December 31, 2013 and it is unlikely to be prolonged in 2014.&nbsp Often, when a tax credit rating like this expires, it is extended the pursuing yr and made retroactive to the date that it experienced expired.&nbsp This is what a Senate monthly bill would have accomplished for several tax credits that was unanimously accredited by a Senate committee this spring.&nbsp But on Could 15, Senate Republicans voted from passing the invoice even although extending most of the expiring tax credits had wide bi-partisan assistance. &nbspThe monthly bill failed due to the fact Democratic management would not permit unrelated amendments to be included on the Senate flooring following the invoice had been negotiated in committee.&nbsp

This displays the percent of taxpayers that took a tax credit score
for possibly strength performance or renewable vitality
advancements, which includes the stove credit score.

It is not unattainable that this bill could be brought to the Senate flooring for one more vote before or soon after the November elections. But it is not likely at this point, which implies that the $ three hundred stove tax credit score is unlikely to be prolonged this 12 months.&nbsp There is also a slight chance that a bill in 2015 could make the tax credit history retroactive to Jan one, 2014, giving tens of thousands of stove purchasers an sudden bonus. That will not aid push far more product sales in 2014 and would be considered by a lot of as a waste of taxpayer dollars.&nbsp Individuals receiving such tax credits are named “free riders” due to the fact they would have produced the purchase anyway and ended up not determined by the discount offered by the tax credit score.
The stove tax credit rating has extended been criticized by a lot of in the power efficiency neighborhood as being dominated by “free riders” simply because the credit history applies to nearly every single single EPA licensed wooden stove and uncertified pellet stove on the market place.&nbsp As an alternative of an incentive to get consumers to buy a larger efficiency or far more “green” appliance, like Vitality Star appliances, the federal government has been supplying a discount to all wood and pellet stoves (other than uncertified, exempt wooden stoves.)&nbsp This is because stove producers are permitted to self-certify their eligibility for the tax credit history, leading each and every producer to claim they are making only substantial efficiency stoves.&nbsp The number of stoves that have third party verified efficiencies are listed listed here.
Stove producers and other folks protect generating every stove qualified for the tax credit rating since no matter of effectiveness or emission levels, stoves are an crucial way for ordinary people to affordably warmth their houses and decrease reliance on fossil fuels.&nbsp The tax credit score allows some share of customers to pay for the acquire, fairly than purchasing older, uncertified stoves on the second hand market, or just relying on fossil fuels.&nbspThe Alliance for Green Heat has been a extended-time advocate of a robust tax credit history, but only for stoves that are genuinely cleaner and more effective.
Customers who acquired a stove in 2013 could claim the credit history on their 2013 taxes, assuming they have not exceeded the $ 500 restrict for residential vitality advancements. &nbspThe over map shows that people of the higher midwest and northeast most typically claimed renewable power and power efficiency tax credits. &nbspThis is likely owing to the perception that weatherization is far more crucial in colder climates and simply because the housing inventory in these areas is older and wants far more weatherization. &nbspData about for every capita use of the stove tax credit is not accessible, as far as we know. &nbspData displaying the average house revenue of households employing the stove tax credit score in contrast to solar, geothermal or other tax credits would be extremely useful.
With the federal tax credit absent, there could be far more pressure for states to offer rebates or tax credits for the cleanest stoves.&nbsp More states are beginning to supply incentives, often simply because longtime photo voltaic incentives are noticed as unfairly benefitting one particular technologies and one particular demographic to the exclusion of another technology and demographic.

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A Reaction to “Ideal Procedures in Alter Out Programs”

This is a reaction by Sylvia Shultz of the non-revenue Cleanse Air Fairbanks to our Weblog Publish on Greatest Methods in Adjust out Packages. &nbspSylvia will take concern with our assertion that Fairbanks employs a strategy that we think about a “very best practice.” &nbspHer believed provoking response is reproduced below. If others have substantive responses, make sure you send out them and we will think about reprinting them.

“Thanks for sharing your weblog publish and asking for comments.
In your site, you wrote that “Fairbanks could be the ideal case in point of efficient prioritizing based mostly on location as an alternative of utilizing a very first-occur, first-provide model.” &nbsp
The only “best instance” of techniques for the Fairbanks PM2.five non-attainment spot is the Town of Fairbanks ban on hydronic heaters. Other than that,&nbsp”greatest” at losing general public funds is all the adjust-out system can declare. $ 7.eight million has been put in on adjust-outs, with $ one million a lot more in the 2015 Funds Budget (expected to be signed by the Governor). It is a exclusive between change-out plans in a PM2.five non-attainment location as there is tiny to avert rolling again to the most polluting heaters and boilers.
The Fairbanks North Star Borough (FNSB) and the State of Alaska proceed to let any strong gas or other heating device to be put in in this serious PM2.five non-attainment region. Even so, in&nbsp2009, the Metropolis of Fairbanks banned new hydronic heaters. Outside the metropolis restrictions, without having controls, PM2.five levels are much increased. But other than that single provision in town code, set up of coal, wood, pellet, biomass, or waste oil burners for household and commercial&nbspuse is unrestricted. New devices of every taste, from $ fifty barrel stove kits&nbspto $ 20,000+ coal hydronic heaters, continue to be mounted. FNSB paid inhabitants to put in wood boilers, the Condition paid&nbspfor $ twenty,000 coal boilers (it will not likely say how numerous), and&nbspschools had been&nbspconverted to wooden (despite the fact that that didn’t perform, and now are changing to organic fuel with state funding). Condition funding also paid for unreliable and ineffective ClearStak catalyst retrofits on wooden and coal boilers.
So, although it is right that FNSB employs location-based mostly prioritization for&nbspthe voluntary adjust-out plan to goal air pollution hot zones, any variety of heater or boiler may possibly&nbspbe mounted in these regions, as prolonged as it is exterior the City of Fairbanks.&nbspHighly polluting heaters can be mounted by homeowners who been paid $ eleven,000 to exchange a hydronic heater. It is nonsense to herald Fairbanks’ prioritization approach as a “ideal techniques” design when there is no restriction on new installations, even in scorching zones. PM2.5 calculated in the cleanest region, the City of Fairbanks, rank amid the worst in the country. Displays from neighborhoods exterior the town limits rank amid&nbspthe worst in the globe.
A study in 2010 for the Conditionbelieved&nbspa overall of three,360 uncertified woodstoves, coal heaters, and outside wood boilers in the PM2.5 nonattainment region. After $ seven.eight million has been put in, that is in excess of $ 2,300 for each uncertified heater. Paying another $ 1 million would deliver the overall for each uncertified heater to over $ two,600. Yet,&nbspmany uncertified heaters remain and more carry on to be put in. Ineffectively throwing income at a severe dilemma need to not be held up as a greatest exercise. Most communities could not afford to undertake this sort of an costly technique that demonstrates such inadequate benefits.
You should assessment the Circumstance Research on two Central Boiler 2300, Phase two certified,&nbspin Fairbanks AK. It was submitted to EPA as component of our NSPS responses. EPA seems unaware of the issues and the&nbspjudge’s get in&nbspAlaska v. Straughn that declared the operation of the boilers to be a “general public nuisance.” EPA’s proposed Stage one emission common would let hydronic heaters that have even higher emission levels than individuals in Alaska v. Straughn.
The FNSB adjust-out plan compensated Straughn $ ten,000 to remove one boiler, and agreed to shell out $ 10,000 for the next. This was right after the judge requested the proprietor to stop procedure of the boilers and later on a settlement limited the qualities to oil or gas heating. Paying to take away and ruin units that are unable to even be used at those houses serves only to avert them from getting sold and installed in other places in the PM2.five nonattainment area, even up coming doorway.
Thanks for your reporting and focus to depth.
Sylvia Schultz

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Greatest Procedures in Alter Out Programs (and Why Some Packages Underperform)

Adjust-out programs are now commonplace in the wood stove neighborhood, particularly in the Northwest, with Libby, MT becoming the maximum profile one.&nbsp In Libby and elsewhere, altering out old uncertified stoves to new EPA certified stoves has demonstrably contributed to cleaner air top quality.&nbsp Generally, wooden stove modify-out programs begin with govt funding, and then leverage in-variety donations from wooden stove producers, stove suppliers and other folks.&nbsp

Even so, change-out programs occasionally supply much less air top quality advantages than envisioned.&nbsp And, for every ton of particulate issue removed from the environment, they can be really expensive. &nbspRaw quantities from Washington State primarily based on money they put in as opposed to believed emission reduction arrived to practically $ 50,000 for every ton of particulate. &nbspWhen Washington Condition utilizes the EPA methodology for calculating expense for each ton, the indicate cost was amongst $ 14,000 and $ 19,000 per ton.&nbsp


In addition to the vintage alter out plan designed to lessen abnormal smoke in particular city, valley or region, alter out applications can just help rural homes far more successfully use a regional renewable power supply. &nbspAlso, manufacturers and merchants can undertake them in the gradual, summer time year.


In evaluating the effectiveness of adjust-out packages, the Alliance for Green Warmth discovered a deficiency of arduous investigation or discussion about how to ideal attain air good quality improvements. Some states are beginning to create far more&nbspmodern attributes&nbspin incentive programs rather of subsequent the sample established by the EPA and HPBA. Right here are seven methods that will boost alter out plans. &nbspVirtually none of these strategies, that a lot of take into account important areas of alter outs, can be identified on the&nbspEPA&nbspor HPBA alter out pages. &nbspExpect drive back from local authorities organizations, HPBA and/or merchants on some of these details, but all of them are getting to be a lot more and a lot more acknowledged.
one. Managing long term installations of uncertified stoves
As well a lot of change out applications arise in spots were individuals are even now permitted to put in outdated, next hand stoves or even unqualified out of doors boilers.&nbsp Reports touting the success of modify-outs in Pennsylvania, Indiana and the Fantastic Lakes states really do not even point out that although previous stoves are becoming eliminated, traditional out of doors wood boilers are getting set up in the quite same communities.&nbsp In Vermont and Keene, NH, a lot more uncertified wooden stoves may have been installed given that their packages finished than ended up removed.&nbsp Before investing minimal dollars on change-outs, money need to be centered in locations where the locality has adequate commitment to clean air to stipulate that old, uncertified stoves and unqualified out of doors boilers can not be put in in the potential.
2.&nbsp&nbspPrioritize which stoves get transformed out first
We believe that some packages inappropriately employed a very first-arrive, first-served strategy when stoves employed as a primary of sole heating supply in more densely populated places could have been targeted very first.&nbsp Although this does not utilize to valleys with inversions like Libby, the place each stove is equally critical, in places like Massachusetts and southern New Hampshire, exactly where cash can operate out swiftly, stoves in the middle of towns which are employed as a primary heating gadget should be presented precedence.&nbsp Some new epidemiology investigation is coming out stating that stove change-outs do not necessarily boost indoor air top quality and the main advantage is to enhance out of doors air quality that impacts the local community at-big.&nbsp In modify-outs that cover multi-county places, or even statewide, as in Vermont’s program, we feel focusing on stoves in cities is warranted.&nbsp Very last precedence must be stoves in isolated residences that only use wood as a secondary warmth resource.&nbsp Fairbanks may be the best instance of efficient prioritizing based mostly on location rather of making use of a first-come, 1st-provide product.
three.&nbsp&nbspEmphasis on wooden, not just stoves
Some professionals are now pondering if a $ 150 rebate to assist develop a wooden get rid of to preserve wooden dry might create comparable air high quality results as a $ one,000 rebate for a stove.&nbsp It is properly recognized that the gear is only fifty percent the battle, and the other 50 % is the gasoline and the operator.&nbsp Requiring firewood sellers to carry a dampness meter when delivering wooden and producing down dampness content on the product sales receipt may possibly also be a excellent approach. Adjust out applications could prioritize homes with woodsheds, to aid make certain that subsidizing a new stove will result in decreased smoke from the house. &nbspOr residences with woodsheds could receive a increased rebate, which incentivizes appropriate storage and educates individuals about its importance.
four. Correct-size the rebate and need partial payment
When rebates vanish in a couple of hours or even a few weeks, it probably means the rebate was way too generous and a lesser rebate could have resulted in much more adjust outs.&nbsp Also, fairly than offered a set amount, packages that give fifty% or even 35% of the new stove need to be regarded, where feasible.&nbsp When more compact, much more targeted populations are included like Keene, NH, greater rebates are needed, as they also are with low-earnings populations.
five. Require that new stoves meet stricter emissions and performance requirements
Practically all modify-out programs now require that the new EPA certified stove be four.five grams or considerably less, but some are starting to call for three or 2.5 grams an hour or less. Pellet stoves, which run in the discipline significantly&nbspmore like they did in the testing lab than wood stoves, need to be held to two.five or two grams an hour at the most. &nbspSome states, with different degrees of accomplishment, are starting up to experiment with minimum efficiency specifications and this is very likely to be a common requirement sometime in 2015. &nbspOregon provides a&nbspbetter rebate&nbsplevel for stoves made by companies who agree to share confirmed efficiencies with their buyers. &nbspMost stove manufacturers will not launch this info, preferring to use unverified and frequently exaggerated numbers. &nbspMaryland&nbsprequires a highest of 3 grams for wood stoves and 2 for pellets. (The Maryland program is a renewable vitality software and does not require the alter out of an outdated stove, but about 50 percent the outdated stoves are disabled and wrecked in any case.)
6.&nbspCall for equally wood and pellet stoves be EPA certified
Few programs have required that pellet stoves be EPA qualified despite the fact that there are significant benefits of this. &nbspEPA certified pellet stoves are usually a lot more successful than their exempt counterparts since exempt pellet stoves frequently use the 35 to one air to fuel ratio loophole to steer clear of certification but all that air lowers effectiveness. &nbspSome pellet stoves are as low as 40% efficient, and a lot of are in the 50s and 60s, when they easily can be in the 70s. &nbspHouseholds ought to not be unwittingly backed to get a low-performance pellet stove that will saddle them with considerably larger fuel costs for a long time to occur. &nbspUnfortunately, large and small pellet stove companies presently self-report efficiencies and are notoriously adept at&nbspexaggerating and inflating&nbsptheir effectiveness numbers. &nbspThe EPA and DOE have carried out minor to counteract this and have at times contributed to&nbspthe issue.
7.&nbspIntegrate wood stove inspections in strength audit approach
If your condition is notably fascinated in retiring older stoves, it is crucial that point out backed vitality audits require that the auditor inspect the wood stove, just like they verify other HVAC gear. &nbspAuditors can teach property owners about the relevance of upgrading to safer, more efficient tools, spot hazardous installations, aid in taking away unsafe stoves and sometimes help get stove upgrades to be backed via low desire loans or other plans. &nbspThe Developing Performance Institute (BPI) is taking the direct to build&nbsptips for energy auditors&nbspto inspect wood stoves. &nbspIn modern years, energy auditors have&nbspfailed to contain&nbspwood stoves in hundreds of 1000’s of properties.
Background
Based on an casual study of ten change out programs, we found the typical rebate delegated for a new wood stove was $ 627 pounds, but ranged from $ three hundred to $ one,050 per stove and considerably more for low-cash flow adjust outs. The median rebate was $ 670.&nbsp Nine out of the ten plans surveyed presented extra support to low -cash flow applicants, and 3 out of 10 supplied full rebates.
Alter out applications, depending on their measurement and scope, can price a fantastic deal of income to run and market. The regular value per alter out differs drastically in between packages. Libby, Montana had a huge budget and was servicing a low-income populace so the cost for every stove was increased.&nbsp Pittsburgh program’s average cost was relatively reduced, at $ 770 for each change out.&nbsp&nbsp Increased fees for each stove do not necessarily mean they were much less effectively run, as there are so a lot of variables and so a lot require for high priced academic packages that concentrate on home owners who are not shifting out stoves, but could be emitting a great deal of surplus smoke.&nbsp

Click for more substantial model.

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One particular Chapter of Polluting Legacy of Out of doors Boilers Coming to Close

One chapter of the fight in excess of outside wooden boilers is on the verge of ending, as EPA regulations are prepared to ban the sale of unregulated boilers in the 38 states that nevertheless enable them. &nbspAnd virtually all the &nbspmain stakeholder teams, from business to air good quality companies, concur that this will be a single of the best things about the approaching residential wood heater rules established to take influence in the spring of 2015.

A determination by the EPA in the mid 1980s to not regulate residential wooden-fired boilers, also referred to as hydronic heaters, appeared reasonable at the time.&nbsp Fossil fuels were cheap and our nation was turning away from wood heating and speedily adopting electrical power and fuel as heating resources. But beginning all around the flip of this century, a boiler layout emerged that grew to become more and more popular, spawning a few dozen tiny organizations, some managing out of garages and barns.&nbsp The design and style was amazing: put the boiler in the yard up coming to your woodpile and pipe the hot h2o underground.&nbsp But they experienced 1 large disadvantage.&nbsp They experienced a drinking water jacket all around the firebox that regularly cooled the fire, keeping it from reaching temperatures that combustion requirements to be clean and effective.
Twelve states currently ban the installation of unregulated
out of doors boilers and most also require property line established-backs
and stack&nbspheight constraints even on the cleaner, Stage two &nbspmodels.
(Compiled by the Alliance for Green Heat)
Outdoor wood boilers are one particular of the reasons that states and non-profits are demanding stricter EPA emission boundaries not just for boilers, but also for stoves and furnaces, which are all coming underneath much more scrutiny.&nbsp In the absence of federal laws, a dozen states possibly effectively banned them, or only permitted designs that fulfilled stricter voluntary emission requirements.&nbsp Vermont was the initial condition to call for this in 2005 and Utahwas the very last in 2013 before federal rules, identified as New Resource Efficiency Standards (NSPS) will just take influence in 2015.
These laws will near the chapter on installing new, unregulated boilers in the US, but the hundreds of 1000’s of present boilers already set up still forged a pall over the wooden heating neighborhood, lowering neighbors residence values and forcing some people to depart their home, rather than breathe the dense smoke that frequently arrives from these boilers.
New battles are previously looming all around outdoor boilers, as the Fireside Patio and Barbecue Affiliation (HPBA) fights for a 1- calendar year time period to market off existing stock of the unregulated boilers.&nbsp States and air high quality groups oppose this further 12 months and the EPA will choose by February 3, 2015 whether to permit the extra 12 months of revenue, as well as how numerous kilos of particulate subject the boilers can emit in 2015, and how significantly tighter the regular must be by 2020.
Litigation is likely, but aid is not probably to appear before long enough for firms like Central Boiler, the leading company of equally unregulated boilers and the cleaner types.&nbsp Central Boiler has fought laws in state after state to continue offering their unregulated types, whilst at the identical time constructing cleaner EPA Section 2 designs for the dozen states that ban their unregulated kinds. Their most well-known designs are the unregulated kinds and at the moment, their sellers do not know if they can offer them following subsequent spring.&nbsp Several sellers are telling clients to get and put in now, while they nonetheless can.
The outside wooden boiler industry is also pitted from the importers of far more innovative European technologies, with the US importers combating for examination strategies and emission requirements that are geared towards European technologies, which are a lot more probably to include oxygen sensors, thermal storage and higher temperature combustion.
The battle over the future of outside boilers is a microcosm of numerous equivalent battles about our power foreseeable future.&nbsp Much more than a dozen Republican lawmakers are demanding that the EPA fall these rules that they say will make this age-old American tradition of heating with wooden prohibitively costly.&nbsp Democrat lawmakers are much more concentrated on reducing air pollution.&nbsp Equally sides assert they are they are supporting the long term of a lower carbon gasoline supply.&nbsp
But numerous battles will continue being with the states, as house line set backs and stack heights are still deemed essential by numerous states who don’t want outside boilers in suburban neighborhoods or in which a neighbor’s residence in only a hundred or 200 toes away.&nbsp While the cleaner models are cleaner when used effectively, they even now can be misused by operators who load them with un-break up moist wooden, or even even worse, with home rubbish that lead to plumes of smoke to blow by way of valleys shared by other family members.

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How Much Does Weight Influence Value of a Stove? A Historic Look at Bodyweight and Pricing of Stoves

One particular of the key aspects in the value of a stove is not how clear or effective it is, but how huge it is and no matter whether it is bought by means of a specialty retailer or a huge box chain.&nbsp We looked at a sample of 19 more compact stoves from 8 distinct brands, with firebox sizes ranging from 1.7 to 2.25 cubic ft and calculated the correlation between stove weight, emissions rate and industry value.

The outcome was a reasonable optimistic correlation among weight and cost but only a modest correlation among emissions and price.&nbsp We did a scatter plot of the two stove bodyweight in lbs . and their marketplace cost and located a very clear upward sloping craze. The calculated Pearson correlation will come to R=. 6691. The connection in between a stove’s emission price and their market place price is only slight for scaled-down stoves.

(See under crucial that matches stove brand names and
designs to the quantities in the chart.)

All other factors being equal, stove specialists say heavier stoves have a tendency to be much more resilient fat can be a single of a lot of elements in determining which stove to get, and whether it is a good “deal.”&nbsp Stoves with one.seven to two.2 cubic fireboxes normally weigh in between 275 and 475 pounds.&nbsp The lighter stoves (275 – 325 lbs) tend to cost less than $ 1,000. Heavier stoves (350 – 450 lbs) have a higher value selection, with a couple of under $ two,000 but most between $ 2,000 and $ three,500.&nbsp Solid iron stoves are likely to be both heavier and a lot more costly.

Perry’s business was a leader in the creation of lower cost stoves, as it still is these days.&nbsp&nbspBack then, Perry utilized inexpensive labor from Sing Sign jail to make stoves.&nbsp&nbspWhen his opposition obtained a legislation banning such prison labor, in 1866 Perry relocated creation to the lower-wage, nonunion south and experimented with utilizing “colored” labor.&nbsp&nbspToday, US Stove is even now based in Tennessee with manufacturing there, in Alabama and China. The initial 50 % of an&nbsp8-moment promo video&nbspfrom US Stove provides a polished story of their historical past.
The use of bodyweight to establish the value of stoves did not previous extended, but NASM remained relevant and lively also due to the fact its member firms necessary a voice to lobby on federal guidelines impacting their business. By the Initial World War, the sector was in speedy decrease as electrification and oil heat took over.&nbsp&nbspNASM membership collapsed and the NASM held its previous recorded meeting in 1929.
In accordance to Prof. Harris, who wrote the exhaustive study of the US stove market in the 1800s, the main goal of NASM was price tag correcting, and secondarily was advancement of manufacturing and enterprise approaches.&nbsp&nbspInnovation, says Prof. Harris, was not on the agenda of the NASM.
Crucial to figures in the above chart on bodyweight and value comparison.

[one] &nbspHowell Harris (2012). Coping with Competitiveness: Cooperation and Collusion in the US Stove Industry, c.1870–1930. Company Background Overview, 86, pp 657-692. doi:ten.1017/S0007680512001808.

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A Short Overview of Comments to the EPA’s Stove & Boiler Restrictions

The Alliance for Green Heat (AGH) has done an initial review of almost all of the comments on the new NSPS filed by manufacturers, states, air districts, non-profit organizations and politicians.  We read more than 100 comments and selected a few of the important topics to summarize. There are many more topics we did not address. Some key manufacturer comments still have not been posted because some manufacturers sent their comments as “confidential business information” (CBI). At the bottom, we recommend a list of the comments we think are most representative, thoughtful, concise and important to read.
We highlight some of the trends, areas of agreement and areas of disagreement that appeared in comments.  We were heartened to see the wide variety of organizations and companies that put a lot of time and effort into participating in this debate and we found scores of very thoughtful and innovative comments.  The EPA will be reviewing and deciding on all these matters this year, and the rule will be finalized by February 3, 2015.
Note: the positions included here are from agencies, groups or companies who gave a specific number or position  If a group only opposed a standard or said it should be stricter, we usually did not record it in this initial analysis.  Some positions may be more nuanced than described as this strives to be a succinct summary, not a full analysis. If you see any errors or misrepresentations, please let us know.
Areas of broad agreement
Virtually everyone, from industry to air quality agencies, supported the Environmental Protection Agency (EPA) undertaking this New Source Performance Standard (NSPS) and regulating a broader range of appliances including boilers, furnaces, pellet stoves, single burn rate stoves and masonry heaters.  A few made very good arguments to include fireplaces (American Lung Association & Innovative Hearth Products, IHP). 
There is also a broad agreement on switching from crib to cordwood testing, but lots of disagreement over how and when.  Notably, a couple of big stakeholders, NESCAUM and NYSERDA, urged the EPA to continue using cordwood for Step 2 emission testing.  The Hearth, Patio and Barbecue Association (HPBA) argued that cordwood should only be used on a voluntary basis, under an alternative certification scheme.  Under this proposed scheme, stoves would have to meet a 7.5-gram an hour standard to be certified using cordwood.
Few stakeholders argued for an 8 year, 3 Step process.  HPBA and many companies do not support any Step 2 or Step 3, which makes the debate over 5 or 8 years irrelevant. Most states, air agencies and non-profits urged 5 years or less but at least 7 of them argued for a 3 year transition to a final Step 2.  The largest stove manufacturer, Hearth & Home Technologies said 5; Travis said 8.
Step 1 Emission Standards
There is also a lot of agreement with Step 1 emissions standards for both stoves and boilers. Industry is nearly unanimous in agreeing to 4.5 for cat, non-cat and pellet stoves, .32 pounds per MMBTU for boilers and .93 for furnaces.  However, some non-industry stakeholders are pushing for stricter Step 1 standards. At least 9 states and institutions are calling for Step 1 wood stove standards between 2.5 and 3.5 grams per hour.  States include Massachusetts, New York and Maryland and groups include Environmental Defense Fund (EDF), American Lung Association (ALA), and the Clean Energy States Alliance (CESA).
Several stakeholders, including Western States Air Resources (WESTAR) and Massachusetts say that catalytic stoves should be held to a stricter standard than non-catalytic stoves.  Three California air districts suggest a limit of 4.1 instead of 4.5. Some stakeholders do not get into the debate about catalyst degradation, but simply do not agree with setting a higher emission limit in this NSPS compared to the last one. Others  believed that every technology should be held to a standard that reflects the emission reduction capabilities that have developed over the years.
At least 1 state (Oregon), 2 air quality districts (Sacramento and Sonoma), 3 non-profits (ALA, AGH and CESA) and 1 company (New England Wood Pellet) urged a 2.5 Step 1 standard for pellet stoves. 
There is wide agreement that .32 pounds per MMBTU was a good Step 1 standard for boilers though real disagreement between industry and others whether there should be a 7.5 gram an hour cap or a 18 gram an hour cap on each burn rate, the latter of which was part of the voluntary outdoor wood boiler program. At least 4 non-industry stakeholders urged a Step 1 furnace standard between .32 and .48 pounds per MMBTU, including AGH, ALA, NESCAUM and Washington Department of Ecology.
Step 2 Emission Standards
This is where things get much more complicated, and few stakeholders outside of industry specified what Step 2 should be for stoves.  Industry closed ranks around 4.5 for both Step 1 and Step 2, arguing that BSER can’t be adequately demonstrated below 4.5 because there is too much variability and imprecision in the test method.  Two respected industry actors, Dectra and Rising Stone, said 2.5 and 2.0 were reasonable Step 2 stove standards. 
HPBA developed an interesting but potentially risky legal argument that seeks to prevent EPA from implementing Steps 2 or 3, but still transition to cordwood.  They say “EPA must revisit and withdraw its proposed Step 2 and 3 limits, and in their place adopt an “off-ramp”  scheme under the statute’s “innovative technology waiver provision that will build a needed bridge to a new paradigm—standards based on testing with cordwood.”  
For boilers, industry appeared less unified than on stoves, and there was some coalescing around a Step 2 limit by some non-HPBA industry members. For example, BTEC said 0.15, Dectra said 0.1, Ecoheat Solutions said 0.19 or .06 and Rising Stone said 0.15. Tarm said 0.15 in 3 years. There was acknowledgement that if the Brookhaven Method were chosen, as many non-HPBA players would like, .06 would be too low because Brookhaven includes start up emissions. 
Sell-Through Provisions
One of the most hotly contested areas is sell-through, which would allow manufacturers and retailers to continue selling existing stock or even to make or import certain models for a specific time period.  The EPA proposed 6 months for certified stoves and nothing whatsoever for exempt products including qualified boilers that participated in the voluntary EPA program. NESCAUM urged a year for certified stoves. For previously certified models, HPBA is asking for a sell-through period of unlimited duration.
  
AGH urged 2 years for qualified boilers and EN303-5 certified boilers and many importers of EN303-5 appliances appealed for either a longer sell-through for their equipment or acceptance of EN303-5 as one of allowed test methods.  HPBA provided extensive detail about sell-through recommendations for each appliance class, and argued for sell-through for unqualified outdoor wood boilers.  Many outdoor boiler companies argue for a one-year sell-through for unqualified boilers and longer extensions for qualified ones.  Many, if not most, states and non-profits specifically urged that exempt stoves and exempt, unqualified outdoor boilers not be allowed to sell those devices after promulgation.
US Stove included some of the most specific proposals and justifications for a variety of appliances, from 2 years for pellet stoves, 4 years for single-burn stoves and up to 5 years for furnaces. 
Few non-industry stakeholders supported any sell-through for exempt pellet stoves.  Many pellet stoves are being tested for certification this year, to avoid the possibility that they will not be included in any sell-through provision.  In a newsletter, the HPBA criticized the “minuscule six-month sell-through provision for pellet stoves.”  Others asserted that pellet stoves makers have had years of notice that their products would be certified in this NSPS, and if any product would not need a sell-through, this may be it.
Acceptance of the PFI Pellet Standard
Acceptance of the Pellet Fuels Institute (PFI) standards was also a hotly contested area, with many inside and outside of the pellet industry taking positions on both sides.  While some pellet producers may not favor any standards, most agree that they are necessary but differ as to whether the PFI standards should be recognized by the EPA.  Many support thePFI standard, many want federal standards, many want the European ENplus standard and many want PFI to more closely resemble ENplus.  Much of the support for ENplus comes from the Northeast and includes NESCAUM, Massachusetts and to a lesser extent NYSERDA.  HPBA did not comment on the issue.
Test Methods
Test methods are another hotly debated arena with widespread industry opposition to many of the changes EPA is proposing.  Because there are so many detailed and technical issues involved, we did not try to cover it in this brief analysis.
Best System of Emission Reduction (BSER)
There appears to be wide disagreement over BSER as a legal standard. HPBA maintains that Steps 2/3 of the NSPS  fail to fail to reflect BSER for several reasons, and must be abandoned because within the range  of uncertainty of test methods are “arbitrary and capricious.” 
HPBA and industry repeatedly refer to the need of building up larger emission databases and EPA may focus on establishing BSER with a far smaller number of units.  Industry seems to have omitted a BSER analysis for pellet stoves. If cat, non-cat and pellet stoves are in the same section, BSER may not apply to each technology separately.  In what could be a significant policy shift, the non-catalytic stove caucus, who lawyers submitted comments under the “Wood Heater Coalition”did not ask for a specific stricter emission standard for cat stoves, but did ask that they have their own section, which could trigger a separate BSER analysis for cat stoves. 
We are not aware of any industry stakeholder urging a stricter standard for pellet stoves even though BSER is clearly way below 4.5 and the accuracy and replicability of the test are not in dispute like it is with wood stoves.
Many states and air quality agencies say or infer that they will accept something far less than BSER for Step 1 as long as its applied to Step 2 in order to give manufacturers time to retool.
Some stakeholders accused the EPA of using pellet boiler numbers to arrive at a Step 2 level of .06 MMBTU that they would then apply to wood boilers.  Many argued that no wood stove has achieved 1.3 using cordwood and the high and low burn rate calculation instead of the weighted average.  Woodstock Soapstone however has tested in an EPA lab with cordwood and without weighting the burn rates and that data is in the EPA record.  This appears to occur in other places where industry seems sure that EPA does not have data that it may actually have, or will have prior to promulgation. 
The legal concept of “adequately demonstrated” will also be hotly contested. HPBA has taken the position that even if a stove or stoves have been tested using the ASTIM cordwood test method, they “undoubtedly constitute innovative technology that has not yet been adequately demonstrated.”  
Change-outs vs. Stricter Emission Standards
A key talking point among HPBA members is that the NSPS may slow down change-outs because they will raise the price of stoves, and lead to more homes keeping their old uncertified stoves. HPBA developed a legal argument around this, saying that “EPA cannot show that its proposal is the best “system” of emission reduction, because it will slow change outs of the six million uncontrolled woodstoves still in American homes—an environmental consequence of its proposal that it has also failed to take into account.”
States, air agencies and non-profits also voiced support for change-out program but hardly any stakeholder in or out of industry thought realistically and specifically about how such a massive change-out program would happen and who would fund it.  Notably, of all the politicians mobilized by industry to express their concern to EPA, none expressed interest looking for funds to pay for it.  And, the predominantly Republican elected officials opposing the NSPS are the least likely ones to support public funding in a “Cash for Clunker” type bill.  So, while virtually all stakeholders agree that change outs remain a great idea, no one has adequately demonstrated that such an effort is politically feasible or likely, or why it would replace, rather than complement stricter emission standards.
Consumer Hang Tag
We expected the consumer hang tag issue not to be very controversial, despite the fact that EPA proposed to do away with it.  However, HPBA and every HPBA manufacturer we encountered agreed with EPA that the hangtag should not be required.  HPBA argued, “hangtags have been a minor headache for retailers because of their tendency to become separated from the appliance on the sales floor. … Moreover, experience has shown that instead of assisting consumers in making informed purchases, hangtags often confuse them. We also believe that EPA is correct in concluding that hangtags have become obsolete with the advent of the internet and its widespread use among consumers.” In another section of their comments, HPBA praised the success of the Energy Star program, which relies primarily on its hangtag to gain consumer recognition.  Several non-HPBA manufacturers supported the hangtag, but most avoided the topic altogether, with the exception of HHT who opposed it.
States were uniform and vocal about their support for continuing the use of a hangtag and improving the look and content of it.  States that support it include Alaska, Massachusetts, Minnesota, New York, Oregon and Washington. Groups that support it include AGH, CESA, EDF, NYSERDA, WESTAR and 2 California air agencies. 
Mandatory Efficiency Standard

The EPA request for comment on a mandatory efficiency standard did not attract a lot of attention, although some significant players urged the EPA to set an efficiency standard: EDF, Massachusetts, Minnesota and NESCAUM.  Oregon urged the EPA to establish an aspirational standard and AGH urged the EPA to ensure that it’s included in the next NSPS. HPBA said that they “agree with EPA’s determination that the promulgation of efficiency or carbon monoxide standards would be inappropriate at this time” and that “there is neither any need for nor data to support the establishment of such standards.”

Our recommendations of comments to read

If you don’t have time to wade through the more than 100 substantive comments on the NSPS, we have a few recommendations of comments that cover a range of topics in the NSPS instead of just one or two specialized areas.
  1.  The longest, most detailed and legal is from HPBA at 170 some pages.  Home & Hearth Technologies is a brief, concise comment that reflects key HPBA positions.
  2.  Many state agencies were thoughtful and detailed. Minnesota is a good, well-rounded state comment and Massachusetts Clean Energy Center is a standout for consumer protection and advancing wood heat as a renewable energy solution.
  3.  Among non-profits, we were most impressed with Environmental Defense Fund.
  4.  For innovation, creativity and thinking about the future, ClearStak is a must read.
  5.  For a manufacturer with thoughtful, independent-minded and concise comments, we recommend Dectra, a boiler maker. Rising Stone as another interesting independent minded industry voice.
  6.  Other, more predictably thoughtful and substantive comments are from Washington, Oregon, NESCAUM, WESTAR, NYSERDA and the ALA. 
  7.  The only state to speak up in opposition to much of the EPA’s proposal was Maine.
  8.  To understand perspectives of manufacturers that serve lower and middle-income families, both England Stove Works and US Stovesubmitted substantive comments. 
  9. Of course, we like our own comments and thank the law firm of Van Ness Feldman, who have a specialty in NSPS law, and who graciously represented us pro bono.
  10. Finally, we urge people to dip into the hundreds of passionate citizen comments that are an important counterpoint to the very legal, acronym filled comments of the primary industry, government and non-profit stakeholders. You can quickly scan a interesting list of comments by people who rely on wood heat here.

Heated Up!

AGH Comments on the EPA’s Wood Heater NSPS

Alliance for Green Heat
Comments on
EPA’s Proposed Standards of Performance for New Residential Wood Heaters, New Residential Hydronic Heaters and Forced-Air Furnaces, and New Residential Masonry Heaters
Docket ID No. EPA-HQ-OAR-2009-0734
May 5, 2014
SUMMARY OF COMMENTS
The Alliance for Green Heat (Alliance), appreciates the opportunity to comment on EPA’s proposed New Source Performance Standards (NSPS) for wood heating devices.[1]  The Alliance is an independent non-profit organization that works with environmental and forestry organizations, air quality experts, the wood and pellet stove industry, and others in the wood burning community to promote high-efficiency wood combustion as a low-carbon, sustainable, local and affordable heating solution.  The Clean Air Act requires EPA to review and revise, if appropriate, the NSPS at least every eight years.  The Alliance strongly supports EPA’s decision to update the standards for wood stoves and to require a number of previously unregulated wood heating devices to reduce their emissions.  We also believe that the new standards, which reflect significant improvements in wood heating technology, are both appropriate and long-overdue. 
We have several suggestions for improving the proposed NSPS, which we outline below.
In our comments on the NSPS, we make the following points:
·      First, it is important to recognize that wood heating is renewable heating and should be acknowledged as such by EPA.
·      Second, the Alliance strongly supports EPA’s decision to issue revised performance standards for wood stoves and other wood and pellet heating appliances.
o   The Alliance supports EPA’s decision to close existing loopholes and to include all major categories of wood-fired heating devices in the new performance standards.  Previously exempted devices (such as non-qualified outdoor boilers and single burn-rate stoves) and devices above the new Step One emission limits should not be “grandfathered.”  
o   The Alliance supports a six-month sell through for certified stoves with emissions that are greater than the Step One emission standards, and a two-year sell through for boilers or furnaces that are EN303-5 (Class 3, 4 or 5) certified or EPA qualified.
o   In the agency’s next revision to the wood heater NSPS, EPA should regulate uncertified, pre-1988 stoves as new sources if they are installed in a new location.  Doing so will help to hasten the removal of the oldest, most polluting stoves from our airsheds.
o   In the agency’s next revision to the wood heater NSPS, EPA should also regulate fireplaces.
·      Third, the Alliance believes that the proposed emission limits, though reasonable, could be more stringent for certain devices:
o   Data from currently certified stoves appear to justify a more technology-forcing, lower Step One performance standard for wood stoves.
o   Pellet stoves are clearly capable of meeting a lower limit for Step One.  The majority of pellet stoves certified by EPA are already emitting less than 2.5 grams per hour (g/hr).  We call on the EPA to set a 2.5 g/hr standard for pellet stoves in Step One.
o   Forced air furnaces could achieve a Step One emission limit of 0.48 pounds per million BTUs (lbs/MMBTU), instead of the proposed 0.93 lbs/MMBTU.A 0.48 lbs/MMBTU standard corresponds to the pound/MMBTU of a typical Washington State-approved wood stove, and some furnaces are already meeting that standard already.
o   In addition, although we believe a .06 lbs/MMBTU Step Two standard for pellet boilers is justifiable, this limit may not be appropriate for cord wood boilers, particularly for test methods that include start-up emissions.  A 0.15 lbs/MMBTU standard appears to be a reasonable Step Two standard, assuming that start-up emissions are part of the test.
·      Fourth, the Alliance strongly supports a shorter, five-year implementation period for the NSPS.  This deadline is both achievable and reasonable given the state of wood heating technology today.
·      Fifth, the Alliance believes that credible testing and enforcement are essential components of any New Source Performance Standard under the Clean Air Act (CAA).
o   The Alliance supports the proposed transition to cord wood testing, and calls on EPA to continue its cord wood testing to obtain additional information on the performance of existing wood stove models using cord wood prior to promulgation of the final rule. While we believe that EPA has sufficient data to justify EPA’s Step Two standards, it is important to show that the emission limits contained in the standards can be achieved using the best systems of emission reduction available for several types of wood heaters.  To that end, if EPA believes that it lacks sufficient data to determine that the Step Two limits are achievable with cord wood, we recommend that the agency commit to re-examining the achievability of the Step Two standards for stoves that must be certified on cord wood before those standards become effective.
o   The Alliance urges EPA to establish a clearer path to certification for advanced technologies like automated stoves.  The Alliance is also encouraged by ClearStak’s comments and urges EPA to consider some of the forward-thinking ideas put forth in those comments.
o   The Alliance supports EPA’s proposal to delegate some oversight and enforcement authority to the states, and urges EPA to improve the capacity of the Office of Enforcement and Compliance Assurance (OECA) to help ensure that enforcement programs are effective, that the list of EPA certified stoves is updated in a more consistently expeditious fashion, and that manufacturers and retailers comply with the NSPS.
·      Sixth, the Alliance believes that mandatory efficiency standards are needed. Greater efficiency is particularly import to low-income wood stove users because it can lower their heating bills by requiring less fuel to heat their homes.  Nevertheless, the Alliance supports EPA’s decision to delay imposing a mandatory efficiency standard as long as manufacturers are required to quickly post their efficiency numbers, and with the understanding that future NSPS would set mandatory efficiency standards.
o   The Alliance strongly supports a requirement to post B415.1 HHV efficiency numbers on all wood heating appliances on the market within six months of the rule’s promulgation.  Models that are EN 303-5 certified or qualified by an EPA voluntary program should be allowed to use HHV numbers from existing test data until they become EPA certified.
o   The Alliance opposes the elimination of the hangtag requirement and urges EPA to consider additional consumer information resources such as a Green Label and state incentives for changing out old stoves and installing the most efficient new stoves.
o   The Alliance agrees that both particulate matter (PM) and carbon monoxide (CO) emissions data, as well as efficiency data, should not be considered Confidential Business Information (CBI), and urges EPA to make emissions and efficiency data about all four burn rates public on its website.
o   The Alliance urges EPA to immediately begin requiring manufacturers and labs to scan and electronically submit all paper data submissions, even as the agency works to develop a more streamlined Electronic Reporting Tool (ERT). 
o   To avoid misleading consumers further, EPA should remove the “default” emission factor column from its posted list of certified wood stoves, and require manufacturers and retailers to stop using these default factors in their advertising materials by the time this NSPS goes into effect.
  • Finally, while EPA’s Environmental Justice (EJ) analysis for this round of revisions to the wood heater NSPS appears to be sufficient, a full, comprehensive EJ analysis would better account for the importance of reducing PM and other emissions from wood heating devices as a key step in eliminating the disproportionate impact that wood heater emissions can have on low-income and minority communities. Therefore, we urge EPA to perform a more comprehensive EJ analysis in the next revision to the wood heater NSPS that looks at the full range of wood smoke impacts on tribal, low-income, and minority communities.
We appreciate your attention to our comments and look forward to working with EPA to successfully implement this important rule.  The full text of our comments is below.


COMMENTS
      I.         Wood Heating Is Renewable Heating.
On June 25, 2013, President Obama announced a bold new commitment to addressing climate change by cutting American fossil fuel emissions and promoting the increased use of renewable energy.  The Alliance strongly supports this commitment and urges EPA to recognize the important role that wood heating can play in meeting the goal of reducing greenhouse gas emissions and slowing the process of climate change. 
Although the industrial, commercial, and agricultural sectors are important sources of greenhouse gas emissions, the residential sector—where most home heating devices are installed—contributes over a billion metric tons of CO2-equivalents each year.[2]  Many of these emissions are the result of homeowners using natural gas, fuel oil, or fossil-fuel generated electricity to provide heat in cold weather.  In contrast to these heating options, which accelerate the movement of carbon from under the earth (where it is harmless) to our atmosphere (where it leads to climate change), wood heating is effectively carbon neutral.  This is because the greenhouse gases released when wood is burned are the same greenhouse gases that were absorbed and sequestered while the fuel source was growing.  In addition, by using wood instead of fossil fuels to heat their homes, Americans are reducing the rate at which we deplete our stores of non-renewable fossil fuels.  In other words, wood heating is renewable heating, and it is good for the climate.
We urge EPA to recognize the important contribution that wood heating can make to reducing residential fossil fuel use, and to ensure that EPA’s updated wood heating regulations support continued innovation in the wood heating industry that will lead to more efficient, cleaner, and more customer-friendly wood heating options in the future.  With the right regulations, wood heating can become an important renewable, environmentally sound, and home-grown substitute for fossil fuels.  The Alliance urges the EPA to acknowledge this in the preamble to the NSPS, and to reflect the contribution that wood heating can make to reducing GHG emissions in other EPA publications and materials.
    II.         The Alliance Strongly Supports EPA’s Decision to Issue Revised Performance Standards for Wood Stoves and Related Devices.
The Alliance strongly supports EPA’s decision to issue performance standards for wood stoves, pellet stoves, hydronic heaters, forced air furnaces, and masonry stoves.  The Alliance firmly believes that technology developed since 1988 is capable of dramatically more efficient, cleaner-burning performance, and that new renewable wood heaters can and should be operated without making particulate matter or other local pollution problems worse.
Although many in the wood heater industry have continued to innovate, EPA’s wood heater regulations have not been updated since 1988.  Moreover, hydronic heaters, forced air furnaces, masonry heaters, and some pellet and wood stoves are not currently regulated by EPA.  It is past time that EPA revise its original 1988 wood heater NSPS to close these significant loopholes.  Regulating these devices will help to promote the innovation that will continue to reduce emissions, increase fuel efficiency, and allow the wood heat industry to better contribute to reducing Americans’ reliance on fossil fuels.
In addition to closing these loopholes, the Alliance urges EPA to consider another loophole in the new source performance standards—residential fireplaces—in a future rulemaking under section 111.  Like the other home heating products EPA proposes to regulate in this NSPS, residential fireplaces can be either prefabricated or custom-built.  Moreover, even though fireplaces are not often used to provide the primary source of heat in most homes, they can contribute to local air pollution problems.  We believe that regulating residential fireplaces would help to encourage innovation in the fireplace industry while ensuring that fireplaces are as clean and efficient as possible. We also applaud the EPA for initiating a voluntary qualification program for fireplaces[3] to build capacity for the industry to adopt cleaner designs.
Finally, we note that the Proposed Rule would not address the significant issue of old, uncertified second-hand wood stoves being resold and installed in new locations.  The market for these uncertified stoves is typically composed of devices that are far more polluting than new stoves.  The Alliance believes that these new installations of existing wood stoves brings these stoves within the definition of “new sources” that can be regulated under CAA section 111(b).[4]  If EPA were to clarify that new installations of second-hand stoves are “new sources” subject to regulation under section 111(b), it would level the playing field between the cleaner, newly manufactured stoves and the dirtier second-hand stoves that are currently being sold and installed in many residences in the U.S.  Consequently, regulating these second-hand stoves would help to hasten the removal of the oldest, most polluting stoves from our air sheds.  We recommend that EPA consider regulating new installations of old and uncertified wood stoves during the agency’s next eight-year review of wood heater new source performance standards, if not sooner.
  III.         Stringency of the Proposed Standards.
Although EPA’s proposed standards for wood heaters, hydronic heaters, forced air furnaces, and masonry heaters are well within the capability of manufacturers to achieve, we believe that data from the hundreds of catalytic, non-catalytic, and pellet stoves that EPA has certified over the years can support a more stringent standard for both wood stoves and pellet stoves. We also suggest that EPA modify the proposed standards for forced air furnaces, and urge EPA to clarify whether its proposed NSPS for hydronic heaters and forced air furnaces will include a binding upper limit on emissions per hour after 2015.
a.     Wood Stove Data Indicates that EPA’s Proposed Step One Standard for Wood Stoves is Too Lenient.
Although we appreciate EPA’s proposal to lower the existing wood stove performance standard from 7.5 g PM/hr (for non-catalytic stoves) to 4.5 g/hr (for all stoves) in “Step One” of the new NSPS,[5]we believe that data in EPA’s possession could support the establishment of an even lower Step One emission limit for wood stoves.  For example, our analysis of EPA’s wood heater certification data[6]indicates that the median emission rate for EPA-certified non-catalytic wood heaters is 4.1 g/hr.[7]The medians for certified catalytic and pellet stoves are even lower: According to our analysis, the median emission rate for catalytic stoves is 3.0 g/hr, while the median for pellet stoves is only 1.88 g/hr.  The median for the entire wood stove category (including catalytic, non-catalytic, and pellet stoves), meanwhile, is 3.6 g/hr, while the average across all stoves is approximately 3.7 g/hr.  Moreover, as Washington State’s comments point out, a review of the HPBA database indicates that the top 20 percent of stoves (a cross-section that includes both catalytic and non-catalytic stoves) are already able to meet a 2.5 g/hr emission limit when the data is converted to 5G equivalents.
The fact that the majority of catalytic and non-catalytic stoves are already meeting (indeed, beating) the proposed Step One emission limits indicates that these limits could be more stringent.  As EPA has correctly stated in other recent rulemakings, EPA’s performance standards under section 111 of the CAA are meant to be technology-forcing, rather than simply continuing the status quo.[8]  Although EPA’s proposed Step Two limits for wood stoves will force some technological innovation, we believe that EPA could further promote this innovation by setting a reasonable, achievable, and more stringent near-term standard in Step One of the proposed NSPS.[9]  Moreover, in light of the current state of wood stove technology, we believe that if the Step Two limits remain at the levels proposed, allowing manufacturers five years to meet the stricter standards with cord wood is reasonable.
b.     EPA Should Establish a Separate, Lower Performance Standard for Pellet Stoves.
Under section 111(b), EPA is permitted to “distinguish among classes, types, and sizes” of regulated sources in establishing NSPS.[10]  The Alliance urges EPA to use this authority to establish a separate, more ambitious performance standard for stoves that burn wood pellets.  As we explain below, we believe that such a decision would comport with the intent of section 111(b) and is supported by data on existing pellet stove emissions.
Section 111 provides that EPA’s NSPS must be based on the “emission limitation achievable through the application of the best system of emission reduction . . . adequately demonstrated.”[11]  Furthermore, under the Clean Air Act, EPA is required to evaluate whether “emission limitations and percent reductions beyond those required by [existing NSPS standards] are achieved in practice,” and to “consider the emission limitations and percent reductions achieved in practice” when setting revised new source performance standards.[12]  Nearly every model of pellet stove manufactured today is capable of achieving a 2.5 g/hr emission limit—an emission rate that is already far below EPA’s proposed Step One (4.5 g/hr) limit for other wood stoves.  In other words, these stoves are already achieving, in practice, an emission rate that is far below both the current NSPS performance standard for pellet stoves and the standard that EPA proposes to establish for Step One of the NSPS.  The Alliance believes that the CAA requires EPA to take into account this information by setting an emission limit for pellet stoves that reflects the emission reductions that these devices achieve in practice. Moreover, we believe that this information demonstrates that the “best” system of emission reduction for pellet stoves is capable of achieving emission rates that are much lower than the limits proposed by EPA.
In addition, pellet stoves are easily distinguishable from other wood stoves because pellet stoves use a different fuel, different pollution control systems, and different mechanics (e.g., mechanical feed) than do traditional wood stoves.  Therefore, the Alliance believes that the better environmental performance of pellet stoves should be recognized and incorporated into the final rule in the form of a separate performance standard with more stringent emission limits for these devices.  Consequently, we urge EPA to consider treating pellet stoves as a separate subcategory of wood stove.  EPA could set lower Step One and Step Two emission limits for the pellet stove subcategory, set an earlier pellet stove compliance deadline for the lower Step Two emission limit, or both.
c.     Additional Changes and Clarifications for the Hydronic Heater and Forced Air Furnace Category.
Although the Alliance generally supports the proposed performance standards for hydronic heaters and forced air furnaces, we believe that the final rule should reflect the following changes.
First, the proposed Step One standards for forced air furnaces is too lenient.  These devices can and should be required to meet the same standards that wood stoves must meet.  For most devices, a Step One limit of 0.48 lbs/MMBTU would be equivalent to EPA’s proposed 4.5 g/hr limit for wood stoves. Therefore, forced air furnaces should be required to meet a 0.48 lbs/MMBTU standard rather than the proposed Step One limit of 0.93 lbs/MMBTU.  The Step Two standard for forced air furnaces should be the same as the standard for boilers.
Second, although a 0.06 lbs/MMBTU Step Two standard is justifiable for pellet boilers, this limit may not be appropriate for cord wood boilers, depending on the test method.  For example, although we think the BNL method should be used for boilers with thermal storage, it is not clear that EPA’s proposed Step Two limit of 0.6 lbs/MMBTU would be achievable for cord wood boilers because the BNL method includes startup emissions. We think that a 0.15 lbs/MMBTU, which EPA has proposed as an “alternative” Step Two limit, would be a reasonable limit for two-step, five-year emission limit for cord wood boilers.
Third, we agree that the NSPS for hydronic heaters and forced air furnaces (proposed as new subcategory QQQQ) should include both a lbs/MMBTU heat output emission limit and a g/hr PM limit. As proposed, these sources would be subject to a 7.5 g/hr limit during the first phase of the NSPS (effective 2015).[13]  However, it is not clear whether sources in subcategory QQQQ would continue to be required to meet both a lbs/MMBTU limit, and the 7.5 g/hr limit after2015.  We urge the EPA to require the 7.5 g/hr after 2015.  If these devices will not be subject to this requirement after Step One, we request that EPA explain its reasoning.
  IV.         Implementation Deadlines.
a.     EPA Should Require All Devices to Meet the Final Emission Limits Within Five Years.
The Alliance strongly supports an approach that requires manufacturers to meet the final emission limits as soon as practicable.  The proposed two-step implementation period for wood stoves, hydronic heaters, and forced air furnaces is clearly achievable.  Indeed, some manufacturers are already meeting the lower emission limits that EPA proposes for five years from the effective date of the rule, even with cord wood.[14]  Most others will be able to meet those standards within five years at reasonable cost.
Further, although the Alliance supports the intent behind EPA’s three-step “Alternative Approach,”[15]we do not support the proposed eight-year deadline for meeting emission limits.  There are aspects of the Alternative Approach that make sense.  For example, a three-step approach would require manufacturers to demonstrate reasonable interim progress toward meeting the final emission limit targets.  Requiring manufacturers to meet an interim goal ensures that progress is being made toward reaching the end target.  Including such an interim target would also ensure that emissions from wood stoves are reduced sooner.  That said, the Alliance does notsupport the Alternative Approach for the NSPS, because we strongly believe that manufacturers do not need eight full years to reach the final emission rate targets (indeed, several commercial models are likely already able to meet these targets today).  Delaying implementation of the more technology-forcing final performance standards in the manner proposed for the Alternative Approach would allow existing, less efficient technologies to remain in use for longer while failing to provide manufacturers and retailers with a near-term incentive to offer better, cleaner, more sustainable options for wood stove users. In addition, because NSPS must be reviewed at least every eight years,[16]the Alternative Approach would effectively require manufacturers to meet the most stringent performance standard just as EPA would be initiating its eight-year review (during which the agency could decide to revise the standards further).  Therefore, we recommend that EPA retain its proposed five-year compliance deadline for the final, Step Two emission limits for all devices.
b.     Recommendations for Grandfathering of Existing Stove Lines and Other Devices. 
The Proposed Rule would allow a “transition period” for stove models certified prior to the effective date of the final rule.  Under this transition period, stoves that were certified under the 1988 NSPS would be “grandfathered in” and could continue to be manufactured and sold for up to 5 years from the date of certification (which could occur at any time before the Proposed Rule’s “effective date”).[17]  Although we agree that a transition period is appropriate, we support a transition period only for appliances that already meet the Step One standards.  As EPA’s certification database demonstrates, there are already numerous catalytic, non-catalytic, and pellet stove models on the market today that are certified at 4.5 g/hr or below.  Allowing existing stove lines with emissions greater than the Step One emission limits to continue to be sold would allow too many high-emitting, inefficient stoves to stay on the market far longer than is appropriate given the state of the technology and the importance of reducing emissions from wood stoves.  In addition, because manufacturers could continue to certify new models up until the effective date of the final rule, we believe the Proposed Rule’s approach to grandfathering provides manufacturers with an incentive to quickly certify all of their high-emitting stoves before the deadline, rather than discontinuing production of less clean devices and transitioning toward a cleaner wood stove fleet.  We note that section 111 appears to anticipate and preempt such a perverse incentive, in that it defines new sources as those sources for which “construction or modification . . . is commenced after the publication of regulations (or, if earlier, proposed regulations) prescribing [an NSPS].”[18] 
In keeping with the intent of section 111, the Alliance recommends that all heaters, regardless of whether they were certified before or after the date of the Proposed Rule—should be required to meet the initial Step One standards for wood stoves and pellet stoves.  Manufacturers and retailers selling heater models certified prior to the Proposed Rule whose emissions are higher than the Step One standards should be given a reasonable, six-month grace period to sell these certified but non-compliant stoves, beginning with the date when EPA issues the final rule.  Following the six-month sell-through period, certifications for any stove that does not meet the Step One standards should be rescinded by EPA—regardless of whether the certificate expiration date extends beyond the six-month sell-through period.  Stoves with emissions lower than the Step One standards that were certified before the Proposed Rule (i.e., under the existing crib wood test methods) should be allowed to be manufactured and sold until their certificate expires or the Step Two standards take effect (by which time those stove models should be required to either be re-certified under the revised test methods or removed from the market).  Currently exempted wood stoves—sometimes referred to as single burn rate stoves, or 35- to-1 stoves —and unqualified wood boilers should not be grandfathered or given any sell-through period.
In addition, we support a two-year sell through period for boilers and furnaces certified under the EN303-5 standards that are Class 3, 4 or 5, or qualified by the EPA. With the exception of these models, EPA should not allow devices that are currently exempt from the regulation to be grandfathered.  As required by CAA section 111, any currently unregulated devices (e.g., hydronic heaters, forced air furnaces, and some wood and pellet stoves) manufactured after the date of the Proposed Rule should be required to meet the Step One emission limit immediately.   
Finally, we do not believe that a small volume manufacturer compliance extension is necessary for either boilers or furnaces.  Even small volume manufacturers currently market their products on a regional or nationwide basis.  Allowing potentially high emitting hydronic heaters or furnaces from small volume manufacturers into areas that are already at risk is not advisable.  However, we do support the proposed five-year small volume manufacturer compliance extension for masonry heaters, because these devices are already sufficiently clean-burning.  In addition, we recommend that EPA carefully consider the comments submitted by the Masonry Heater Association and Norbert Serf regarding how EPA should set performance standards for masonry heaters.
    V.         Proposed Test Methods and Enforcement.
a.     The Alliance Supports the Transition to Cord Wood Testing.
Credible testing and enforcement are essential components of any New Source Performance Standard under the CAA.  In this regard, the Alliance strongly supports the Proposed Rule’s requirement to transition from the crib wood test to the cord wood test for certifying wood heaters and other devices, because the cord wood test more accurately represents “real world” emissions.  EPA has proposed that wood stoves certified during Step One of the revised NSPS would be tested using both crib wood and cord wood and could be certified using either test.[19]  For Step Two, EPA proposes that stoves would be certified using only the cord wood test.[20]  The Alliance believes this approach will allow a reasonable transition period for manufacturers to test and, if necessary, adjust their stove offerings so that they can meet the Step Two emission limits using a cord wood test alone. 
However, the Alliance notes that the vast majority of emissions data that EPA has gathered to date appears to be crib wood data and little cord wood test data exists.[21]  Furthermore, the Alliance is not aware of any simple or technically defensible method of estimating the emissions that a stove tested on crib wood would emit when tested on cord wood. We understand that EPA will be testing additional stoves using cord wood over the next several months.  If EPA can obtain sufficient cord wood test data to adequately support its proposed Step Two standards before issuing a final rule, we would support the emission limits as proposed. 
If EPA cannot obtain sufficient data to make a reasoned determination as to the achievability of its proposed Step Two standards using a cord wood test, we suggest that EPA consider conducting a mid-term review of the Step Two cord wood-based emission limit at least 12 months before the effective date of the Step Two limits.  During this mid-term review, EPA would be able to examine additional cord wood test data obtained from stoves that are certified during the first phase of the new NSPS.  This data would either reinforce EPA’s determination that the Step Two limits are achievable using a cord wood test, or indicate that these limits should be adjusted (either upward or downward).  Following this mid-term review, EPA could amend the NSPS (if necessary) to account for the new cord wood test data the agency receives.  Such a mid-term review is authorized by the Clean Air Act,[22]and would be in line with the approach that EPA has taken for regulating emissions from mobile sources[23](which, like wood heaters, are typically mass-produced devices that are certified and then sold into commerce).
b.     EPA Has Ample Data Showing that Step Two Emission Limits Are Achievable for Pellet Stoves.
In contrast to other types of wood stoves, EPA has not proposed to change the test method for pellet stoves.[24]  These stoves are currently tested using pellet fuel, and the fuel that pellet stoves will use for certification will not change significantly (as it will for cord wood stoves).  EPA has clarified that new pellet stoves would be required to be tested using Pellet Fuels Institute (PFI) approved pellets[25]—a proposal that we support.[26]  We do not believe that using fuel certified under the PFI program will substantially affect the emissions of these devices.  Therefore, as discussed above, EPA already has ample data in its possession showing that the Step Two pellet stove limits are achievable.  (Indeed, as we point out above, EPA’s certification data shows that these limits could be even lower for pellet stoves.)  As a result, no mid-term review would be necessary for pellet stoves.  We believe this distinction in test methods between traditional wood stoves and pellet stoves is yet another good reason for treating pellet stoves as a separate subcategory.
c.     EPA Should Establish a Clear Pathway for Certification of Automated Stoves. 
New sensing and automation technologies could be vitally important to improving wood stove efficiency, lowering emissions, and making wood stoves a viable option for more consumers in the future.  For example, automated stoves that employ this kind of technology can achieve greater emission reductions in practice because they significantly reduce or eliminate the possibility that some users would misoperate their stoves, which leads to less efficient heating and higher emissions.  Several automated stoves were included in the Wood Stove Decathlon,[27]which is sponsored by the Alliance and more will be tested in November 2014 as we develop a test method for them.  These automated stoves represent the exciting, cutting edge of wood stove technology, and EPA should design the new NSPS so as to eliminate all unnecessary barriers to the introduction and use of these stoves in the U.S. market.  Furthermore, automated stoves could be tested on a cold-to-cold basis, as automation can be designed to reduce start up emissions.  This capability to reduce start-up emissions should be built into future test methods, because the current hot-to-hot approach may overlook the significant amounts of PM that can be emitted when a stove is first warming up or cooling down.
We are concerned that the Proposed Rule’s testing protocols do not provide a clear procedure for certifying automated stoves.  We therefore recommend that EPA provide a clearer path to certification for new technologies such as automated stoves.  For example, EPA could clarify that automated stoves (which cannot be manually adjusted by the user) may be tested and certified according to the single burn rate heater testing procedure, adjusted as EPA believes appropriate.  EPA should consult with stakeholders and issue a supplemental notice of data availability that explains how the agency would test and certify an automated stove under the final rule.
d.     Additional Comments on Testing and Certification. 
Transition to Bimodal Test Method.  The Alliance supports the change in the variable burn-rate wood stove test method from an average of four operational modes to a focus on the two modes most likely to emit high levels of particulate matter—Category 1 (the lowest burn rate) and Category 4 (highest burn rate).[28]  This modification will help to ensure that low emissions during the optimal stove operational mode do not hide the potentially higher emissions occurring during very low or high burn rates.
Filter Pulls.  The requirement for one-hour filter pull should be applied only to hydronic heaters and furnaces, and no further than the first five hours of testing.  Requiring additional filter catches from room heaters and other small devices would be overly costly, and would not yield significant amounts of additional information.
Moisture Sampling Techniques for Method 28.  The alliance supports Washington State’s comments on EPA’s proposed changes to the moisture sampling techniques, and urges EPA to ensure that the test method is workable for test labs.
Certification for Multi-fuel Stoves.  Certain pellet stoves are capable of using either wood pellet fuel or corn.  EPA should clarify whether such multi-fuel stoves can or must be certified using corn as well as wood pellet fuel.  If these stoves must be certified using corn, EPA should allow manufacturers to use the Method 28 test with corn to demonstrate compliance with the NSPS.
Potential Issues for Small Test Labs.  Although we generally support EPA’s proposal to require test labs to be accredited under ISO protocols,[29]we are concerned that this requirement could be too costly for small labs, and might lead some of these labs to go out of business or to stop performing wood heating device certification tests.  The elimination of these labs could lead to a testing bottleneck, especially in the first few years of the NSPS, as manufacturers begin to recertify and retest their existing lines using EPA’s revised test protocols.  It could also increase the rule’s impact on small businesses.  Therefore, we suggest that EPA consider allowing laboratories with five or fewer employees that have been accredited under appropriate state laboratory accreditation programs (where they exist) to qualify as certifying laboratories under the NSPS without having to become ISO-accredited.  EPA can and should continue to monitor these and other labs to ensure that they continue to provide accurate certification data.
Public Availability of Test Data.  We urge EPA to make summary data from certification testing available to the public via a central, web-accessible database on the EPA website.  Under section 114 of the CAA, certification test data must be made available to the public unless the manufacturer demonstrates, to the satisfaction of EPA, that making the test data public would “divulge methods or processes entitled to protection as trade secrets.”[30]  We have no reason to believe that posting the results of the required wood heater emissions and efficiency tests would compromise any manufacturer’s confidential trade secrets.  We support EPA’s proposed clarification that all certification test data (including PM, CO, and efficiency data) under the NSPS are public data.[31]  We urge the agency to post this data—including disaggregated information from all burn rates tested for each device—on the EPA website in a timely fashion, and in a format that consumers and others can easily access.  The European Josephinum website provides a good example of how this can be accomplished.[32]
Electronic Submittal of Test Data.  In the past, manufacturers have been allowed to submit their certification test data on paper, a procedure that makes it difficult, if not impossible, for the public to view or access this data.  Although we are encouraged by EPA’s proposal to require manufacturers to use electronic reporting in the future, we note that as proposed, this requirement will apply only if the test data is “collected using test methods compatible with [the Electronic Reporting Tool (ERT)]” and only if the ERT is operational.[33]  These two exceptions raise the distinct possibility that test data will continue to be submitted on paper for some time, notwithstanding EPA’s intention of requiring electronic submission.  Therefore, while we urge EPA to continue working toward the timely implementation of mandatory, industry-wide ERT reporting, we recommend that EPA immediately begin requiring manufacturers and labs to scan and electronically submit any paper data they currently submit (e.g., in Portable Document Format (PDF) or similar format).  EPA should make these PDFs available on its website within a reasonable amount of time (less than 60 days), so that the public can access this data, as required by CAA section 114.
Enforcement.  Effective enforcement of EPA’s proposed NSPS is critical to ensuring a fair market for wood stove manufacturers and retailers.  In the past, compliance with the NSPS has been hampered due to the small number of staff and the limited resources the agency has devoted to enforcement.  EPA proposes to address these issues by delegating some of the agency’s monitoring and enforcement responsibilities to states,[34]as permitted by section 111(c) of the CAA.[35]  The Alliance supports this proposal as one means of improving monitoring and enforcement of these important performance standards, especially where state agencies demonstrate a willingness and an ability to ensure that the federal NSPS is being followed.  However, we urge EPA to further clarify the following elements of this proposal: 1) what specific authorities will states have to monitor, enforce, and remedy potential violations; 2) how will the agency determine whether to delegate these functions to states; 2) how will EPA  monitor and respond to allegations that delegated states are not carrying out their enforcement responsibilities; and 4) how will the standards be enforced in cases where EPA does not delegate monitoring and enforcement authority.  In addition to delegating appropriate authority to the states, EPA should also separately commit to improving OECA’s capacity, and the capacity of enforcement staff in EPA’s regional offices, to ensure that manufacturers and retailers comply with the NSPS.  Furthermore, the Alliance supports Washington State’s recommendation that OECA redirect its resources to examine retailers’ and manufacturers’ sales claims and provide a mechanism for online reporting of false advertising.  Also, because wood stoves are analogous to motor vehicles (in that they are tested, certified, mass-produced, and then sold into commerce),  EPA should consider adopting and adapting elements of its vehicle and engine compliance programs for the wood stove context, as appropriate.  For example, the Alliance would support a rigorous EPA spot-check program to ensure that all market participants are complying with the rule.   
Finally, we also support Washington State’s suggestion that EPA create a mechanism for online reporting of false advertising.  A link to this reporting form can be placed in various locations within the EPA domain (e.g., Burn Wise, Wood Smoke Education, Report a Violation, etc.) allowing the public, industry, and regulators to participate in the elimination of false claims. 
  VI.         The Alliance Supports EPA’s Decision to Gather More Data on Stove Efficiency, with the Understanding that Future NSPS Would Set an Efficiency Standard in Addition to Emission Standards.
Although the Alliance strongly recommends that EPA require new wood stoves to meet minimum efficiency requirements at some point, we support the Proposed Rule’s approach of requiring that data on efficiency be gathered from all new appliances, as long as manufacturers are required to submit their efficiency data within 6 months of publishing the final rule. Having actual efficiency data posted for the duration of the proposed NSPS is reasonable, with the understanding that efficiency requirements could be set in 8 years during when EPA re-evaluates the NSPS for room heaters.  We suggest that EPA clarify in the final rule that it is gathering data with the goal of establishing mandatory efficiency standards in a future rulemaking, so that manufacturers are put on notice that such standards will eventually be promulgated.  Improved efficiency is particularly important to low-income wood stove users because the greater the efficiency of the wood stove, the less fuel the heater must consume to heat a home, and the lower the user’s fuel costs. Lower income families are more likely to be impacted by fuel costs because they typically use the heaters far more than higher income families.
In addition, the Alliance believes that transparency and customer information are critical to maintaining a vibrant, successful, and environmentally sustainable wood stove industry.  Just as car buyers are entitled to know the fuel efficiency of the car they are buying, so too, consumers of wood stoves should be able to compare the efficiencies of different stove models when deciding whether to purchase a new stove.  Therefore, we urge EPA to require that all wood stove manufacturers publicly report the HHV, CSA B415.1 efficiency numbers based on test data from their current certification test within six months of the promulgation of the final rule.  Any stoves certified under the new NSPS should likewise be required to post their efficiency numbers no later than six months after receiving their certification.  Manufacturers should be required to display the efficiency of their stoves in a uniform manner on a permanent tag that is affixed to the stove.
Furthermore, manufacturers and retailers also should be required to immediately stop displaying “default” efficiency numbers on tags or other advertising materials.  These default factors are often grossly inaccurate, and are misleading to consumers.  Where actual efficiency numbers are not available for a stove based on data from a their previous certification tests, manufacturers and retailers should be required to state that the efficiency of the stove has not been tested and is not known.  This requirement will provide more accurate information to consumers who are searching for a more efficient stove and will lead to more purchases of less polluting, more efficient devices.  To avoid misleading consumers further, EPA should also remove the “default” emission factor column from its posted list of certified wood stoves.[36]
Finally, the Alliance urges the EPA to clarify how efficiency will be measured now that certification tests will be required to be based only on the high and low burn rates, rather than on data from all four burn rates.
The Alliance Opposes Elimination of the Hang-Tag, and Supports Development of Additional Incentives for the Most Efficient Stoves.  The Alliance does not support EPA’s proposed elimination of the temporary label or “hangtag.”[37]  Hangtags provide key information on the efficiency and environmental attributes of different devices at the point of sale and play a critical role in incentivizing consumers to purchase the cleanest, most efficient stoves.  The requirement to include a hangtag is generally an almost insignificant expense, and yet the information it provides to customers can lead to greater deployment of more efficient, low-emitting stoves.  Requiring that hangtags include these items, as well as the device’s maximum BTU output as reported by the test lab (not merely as reported by manufacturer), would also assist consumers.  While EPA’s proposal to place efficiency and emissions information on a website is helpful, it is not a suitable replacement for the hangtag.  Most customers are likely unaware that EPA even maintains a website with efficiency and other relevant information, and we do not believe that replacing the hangtag with the EPA’s website will serve the same, important purpose of informing wood stove buyers of the relative efficiency and emissions impact of the stoves they are considering at the time they visit the retailer to make their purchase.
We oppose requiring permanent labels containing language requiring homeowners to cease using a woodstove certified to the Step One standard when Step Two comes into force.
In addition to maintaining the hangtag requirement, the Alliance would also support the development of a voluntary “Green Label” for the “cleanest of the clean.”  Such a label would give customers who value environmental attributes and efficiency an additional, valuable signal in the marketplace, similar to  “Energy Star” label.  Such a signal would encourage consumer decisions that would further reduce emissions and would spur manufacturers to innovate by reducing emissions in order to improve the competitiveness of their stoves.
Furthermore, owner’s manuals for wood stoves and other room heaters should be required to include the actual efficiency and emissions numbers at which the device was certified. Owner’s manuals should also be required to include information about optimum operating temperatures, thermometer location, proper air control regulation, wood moisture testing and proper annual maintenance.
Next, OECA should begin planning now to provide adequate staffing to conduct periodic (no less than yearly) reviews of manufacturer web sites.  All decisions to revoke EPA certificates should be posted online for easy access by state and local regulators as well as the general public. 
Finally, EPA should consider additional incentives to promote clean stoves. These incentives could include: allowing entities to obtain SIP credits for changing out old stoves with new technology; allowing states to incorporate programs in state SIPs that provide additional incentives for using clean wood stove technology; and continuing to allow change-out programs to qualify as supplemental environmental projects in EPA settlements. Moreover, because waste and PM emissions can be dramatically reduced if outdoor wood boilers are professionally sized and installed, EPA should encourage states to establish certification and professional sizing programs for these devices (where such programs do not currently exist).
VII.         Environmental Justice.
One of the core themes of state regulators during EPA’s February public hearing in Boston on the NSPS was a concern about the impact of the regulations on low-income households who rely on wood heat. Additionally, a core theme from industry is a concern that even moderately higher stove prices will put them out of reach of low and middle-income households, resulting in continued reliance on the existing stock of more-polluting, uncertified stoves in these communities.
While people of all ethnicities and economic classes own wood stoves, low-income households burn far more wood and are more likely to use them as their primary source of heat, whereas wealthier homes use wood stoves as a supplementary heating source.[38]  Greater use of wood and wood heating is also likely to lead to greater exposure of PM2.5 air pollution among non-white populations.  For example, a recent NYSERDA report found that “increased non-white population . . . [was] associated with higher downslope woodsmoke PM2.5.”[39]
EPA defines Environmental Justice (EJ) as the “fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. Fair treatment means that no group of people, including racial, ethnic, or socioeconomic group should bear a disproportionate share of the negative environmental consequences resulting from industrial, municipal, and commercial operations or the execution of federal, state, local, and tribal programs and policies.”[40]
Although we applaud EPA for commissioning the “Analysis of Exposure to Residential Wood Combustion Emissions for Different Socio-Economic Groups” prepared by EC/R Incorporated in 2010, we do not believe that report considered the full range of potential impacts on low-income and minority communities from wood heater emissions.  For example, the EC/R analysis focused primarily on cancer correlations, while failing to fully examine many other considerations that could and should be part of an EJ analysis.
While we believe the EJ analysis for this round of revisions to the NSPS is sufficient, we think that it is important for EPA to recognize that some low-income and minority communities are more likely to rely on wood as a primary heating fuel, and that these groups may be forced to rely on older, uncertified heaters which are more polluting and less efficient.  For these reasons, we believe that a full, comprehensive EJ analysis would better account for the significance of reducing PM and other emissions from wood heating devices as a key step in eliminating the disproportionate impact that wood heater emissions can have on low-income and minority communities. Therefore, we urge EPA to undertake a more comprehensive EJ analysis in the context of any future revisions to these wood heater performance standards.
VIII.         Conclusion
The Alliance appreciates the opportunity to provide input on this important rule and looks forward to working with EPA to implement the points we highlight above.

                                                                                    Sincerely
                                                                                    John Ackerly



[1]Standards of Performance for New Residential Wood Heaters, New Residential Hydronic Heaters and Forced-Air Furnaces, and New Residential Masonry Heaters, 79 Fed. Reg. 6,329 (Feb. 3, 2014) [hereinafter “Proposed Rule”].
[3]EPA, Consumers – Choosing Appliances – Choosing the Right Fireplace, http://www.epa.gov/burnwise/fireplaces.html.
[4]The CAA defines a new source as “any stationary source, the construction of modification of which is commenced after the publication of regulations (or, if earlier, proposed regulations) prescribing a standard of performance under this section which will be applicable to such source.”  42 U.S.C. § 7411(a)(2).  Because second-hand stoves must be installed anew when moved from one location to another, each new installation of a second-hand stove constitutes a new “construction” that brings that second-hand stove within the definition of “new source.”
[5]Proposed Rule, 79 Fed. Reg. at 6339.
[6]We analyzed data from all certified stoves listed on EPA’s website as of March 2014.  The list is available at http://www.epa.gov/Compliance/resources/publications/monitoring/caa/woodstoves/certifiedwood.pdf. 
[7]Three hundred and fifteen (315) listed, non-catalytic wood stove models are currently certified with emission limits at or below 4.1 g/hr.
[8]See, e.g., Standards of Performance for Greenhouse Gas Emissions From New Stationary Sources: Electric Utility
Generating Units, 79 Fed. Reg. 1430, 1465 (Jan. 8, 2014) (citing Sierra Club v. Costle, 657 F.2d 298, 347 (D.C. Cir. 1981) and various Congressional Reports interpreting the CAA amendments of 1970).
[9]The Alliance supports EPA’s proposal to set a single standard for both catalytic and non-catalytic stoves, and does not believe that setting a single standard will lead to backsliding among catalytic stove (especially in light of EPA’s proposal that wood stoves meet a more stringent Step Two emission limit within 5 years of the effective date).
[10]42 U.S.C. § 7411(b)(2).
[11]42 U.S.C. § 7411(a)(1) (emphasis added).
[12]42 U.S.C. § 7411(b)(1)(B).
[13]See 79 Fed. Reg. at 6385.
[14]Although we do not believe it is possible to convert between existing crib wood data and the cord wood-based emission limits EPA proposes for Step Two, it is worth noting that fourteen non-catalytic, twenty-one catalytic, and twenty-eight pellet stoves are already EPA-certified at the proposed Step Two emission limit of 1.3 g/hr or less, using a weighted average of all four burn rates.  See EPA, List of EPA Certified Wood Heaters (Mar. 2014), http://www.epa.gov/Compliance/resources/publications/monitoring/caa/woodstoves/certifiedwood.pdf. (Note that if they were retested using just the high and low burns as proposed by EPA for this NSPS, it is possible that fewer of the existing models would meet the 1.3 g/hr standard.)  In addition, Tom Morrissey of the Woodstock Soapstone Company has tested at least one of this stoves using cord wood and found that it can meet the lower, Step Two limits proposed by EPA.  We understand that this data will be submitted to the rulemaking docket. 
[15]See 79 Fed. Reg. at 6339.
[16]42 U.S.C. § 7411(b)(1)(B).
[17]79 Fed. Reg. at 6338-39.
[18]42 U.S.C. § 7411(a)(2) (emphasis added).
[19]Proposed Rule, 79 Fed. Reg. at 6340.
[20]Id.
[21]We note that Tom Morrissey of Woodstock Soapstone has successfully demonstrated that at least one of his stoves can consistently meet the proposed Step Two emission limits when tested on cord wood.  However, our review of EPA’s supporting documentation does not appear to reveal any additional test data from cord wood testing.
[22]Section 111(b)(1)(B) provides that EPA “shall, at least every 8 years, review and, if appropriate, revise” NSPS standards, unless EPA “determines that such review is not appropriate in light of readily available information on the efficacy of such standard.”  42 U.S.C. § 7411(b)(1)(B).  Therefore, EPA may issue the current NSPS with the intention of conducting a mid-term review once it has gathered additional cord wood test data.
[23]See, e.g., EPA and NHTSA, 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards, 77 Fed. Reg. 62,624, 62,633 (Oct. 15, 2012).
[24]EPA has proposed that owners and operators would be required to use the grade of pellet stove used in the certification test of the stove, or better. See 79 Fed. Reg. at 6332.  However, this requirement on the user will not implicate the representativeness of the test data on which EPA bases its proposed standards for pellet stoves.
[25]79 Fed. Reg. at 6341.
[26]We also recommend that the PFI program be expanded to require pellets used in new stoves to comply with the requirements of EN Plus.
[27]See Alliance for Green Heat, Overview and Results of Decathlon, http://www.forgreenheat.org/stovedesign/media.html.
[28]See 79 Fed. Reg. at 6367.
[29]79 Fed. Reg. at 6374.
[30]See 42 U.S.C. § 7414(c).
[31]See 79 Fed. Reg. at 6376.
[33]79 Fed. Reg. at 6382.
[34]See 79 Fed. Reg. at 6367. EPA has appropriately clarified that it will retain authority to monitor and enforce the NSPS even in delegated states.
[35]42 U.S.C. § 7411(c).
[37]See 79 Fed. Reg. 6340-41.
[38]Nianfu Song, et al., Factors Affecting Wood Energy Consumption by U.S. Households, 34 Energy Economics 389 (2012).
[39] NYSERDA, Spatial Modeling and Monitoring of Residential Wood Smoke Across a Non-Urban Upstate New York Region xxii (Feb. 2010), available at http://www.nyserda.ny.gov/-/media/Files/EIBD/Economic-Development/spatial-modeling-monitoring-residential-woodsmoke.pdf.
[40]EPA Region 1, Environmental Justice Program and Civil Rights, http://www.epa.gov/region1/ej/(retrieved May 2, 2014).

Heated Up!

Residence Invoice Seeks to Avert Rigid EPA Wood Stove Regulation

Rep. Luetkemeyer (R-MO)
&nbspAGH EvaluationHome Resolution 4407, the Wood Stove Regulatory Reduction Act of 2014, would

avert the Environmental Protection Agency (EPA) from setting up rigid emission limitations for wood and pellet stoves and boilers.&nbsp The bill does not totally look for to keep the standing quo, as it would nonetheless let out of doors boilers and indoor furnaces to be regulated, which they aren’t in most states.&nbsp It would avert the EPA from placing emission boundaries tighter than four.5 grams an hour for wood and pellet stoves, which has been the de facto nationwide normal because 1995.

The bill was released on April four, 2014 by Missouri Republican Blaine Luetkemeyer and now has 10 co-sponsors, nine of which are Republican and 1 Democrat. GovTrack’s investigation tags Luetkemeyer as a much-right Republican consultant. This identical preeminent bill tracking service, gov.monitor.us, provides this monthly bill an eight% chance of getting earlier committee and a mere two% chance of passing.&nbsp This is the destiny of the majority of expenses introduced every single yr in the Home but it does not mean that they do not provide helpful functions for the users who introduce them or the events who drafted it for the lawmakers.
The bill demonstrates what a lot of stove and boiler manufactures needed to see from the EPA rulemaking approach in the New Source Functionality Expectations (NSPS).&nbsp While Congressional payments can reflect just a specifically industry may possibly want, the EPA’s NSPS is meant to determine the Very best Method of Emission Reduction (BSER) that has been adequately demonstrated.&nbsp BSER can be set up with only a handful of stoves and then be applied to the total market, forcing all manufacturers to undertake the techniques that can make the cleanest burning stove.&nbsp An NSPS can be a “technology forcing” regulation and the primary issue appears to be what percentage of stove versions will be forced to modify and by when.
This invoice would quit the process of necessitating BSER by stopping the EPA from applying the second stage of item emission specifications integrated in the NSPS. The second section is in 2020 or 2023 when the stricter emissions standards would be essential.&nbsp In addition, the monthly bill softens time limitations for makers and retailers offering hydronic heaters and warm air furnaces, enabling them more time to offer present inventory. The bill also helps prevent the EPA from producing any alterations in the auditing and certification strategy for a bare minimum of 3 several years into the new NSPS, in purchase to prevent a backup at testing labs. The bill also compels the EPA to allow merchandise that are currently EPA accredited to be grandfathered into the new regulations.
The bill, drafted by users and workers of the Hearth, Patio &amp Barbecue Association (HPBA), arose when it turned clear that the EPA was determined to suggest rigid emission standards for stoves and boilers.&nbsp According to HPBA, the EPA abandoned a “collaborative approach” to the rule generating and “began to propose radically new concepts dependent on assumptions which went much beyond their available info.”&nbsp Owing to deficiency of funding, the EPA has not been ready to create numerous of its own data sets and frequently has to depend on business for emission info.&nbsp Industry has shared some info but is also strategically withholding some information that they hope will stop the EPA from environment stricter specifications.&nbsp In reaction, for components of this NSPS, the EPA has been turning to data sets from other international locations, relying on data from a couple of makers who share it, performing their possess screening among other strategies.&nbsp

Most of the sponsors of H.R. 4407 are delegates whose constituents have a increased dependency for wooden heat as their major heating resource. &nbspThe national common is about two.one%. A fact sheet supporting HR 4407 put out by Rep. Leutkemeyer’s office erroneously explained that, “12 p.c of all residences burn up wood as their main heating gas.” The table underneath highlights the scores of the co-sponsors in accordance to the The League of Conservation Voters, who rank Condition representative’s “pro-environment” voting heritage on crucial legislation involving environmental, community wellness, and power concerns. &nbspThe lone democrat, Rep. Collin Peterson signifies the district that Central Boiler is in.

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Key Tips for the Proposed Wooden Heat Restrictions

The deadline for submitting responses on the EPA proposed new wood heater laws is in one particular 7 days, on Monday Might 5.&nbsp Shown under are some of the crucial suggestions that the Alliance thinks are necessary to advertise cleaner and a lot more productive wood and pellet heating in the United States. &nbsp&nbsp
The Alliance welcomes any input about these suggestions prior to the Monday submittal deadline. &nbspHere are more comprehensive feedback listed here for your review and enter.

&nbsp&nbsp &nbsp &nbsp &nbspClosing loopholes so that federal emission specifications implement to all wood heating appliances – wooden and pellet stoves, boilers, furnaces and masonry heaters.
&nbsp&nbsp &nbsp &nbsp &nbspFollowing the 5-12 months implementation interval, rather of the different 8-12 months period of time.
&nbsp&nbsp &nbsp &nbsp &nbspRequiring wood stoves to satisfy a 4.5 gram an hour normal and pellet stoves a 2.five normal from 2015 to 2020.
&nbsp&nbsp &nbsp &nbsp &nbspNot grandfathering any system that does not satisfy Step A single standards in 2015 and Action Two standards in 2020.
&nbsp&nbsp &nbsp &nbsp &nbspDemanding manufacturers to disclose the efficiency of their heaters inside of six months of finalizing the rule. &nbspAccess to correct wood and pellet heater effectiveness figures is notably crucial for minimal-income households.
&nbsp&nbsp &nbsp &nbsp &nbspRequiring a buyer hangtag that contains emissions, performance and BTU output as measured by an unbiased 3rdget together test lab.
&nbsp&nbsp &nbsp &nbsp &nbspStrengthening the capability of OECA (Office of Enforcement and Compliance Assurance) to expeditiously make much more testing and other information clear to the general public and to states.
&nbsp&nbsp &nbsp &nbsp &nbspSupporting the EPA to create a database of emission knowledge using wire wooden tests prior to finalizing the emission normal for cordwood in the rule.&nbsp
Simply because this NSPS contains so a lot of variables for both market and the EPA, the Alliance urges the EPA to defer some regulations until the subsequent NSPS, 8 a long time from now.&nbsp This includes regulating fireplaces and dealing with the installation of pre-1988, uncertified stoves as “new sources” and only allowing the set up of qualified stoves made right after 1988.&nbsp
To submit responses to the EPA, click on right here for details.&nbsp

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