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New EPA Stove Regulations Begin Cleaner Chapter for Wood Heating

Posted by Earth Stove on July 4, 2015 with No Commentsas , , , , , ,
Statement by the Alliance for Green Heat on the Wood Heater NSPS

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Full EPA rule and fact sheets

Wood and pellet stoves

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

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

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

Hydronic heaters

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

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

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

Warm air furnaces

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

Large furnaces: 2 years after publication (2017)

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

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

Heated Up!

US to begin mandatory survey of wood pellet varieties, volumes and ingredients

Posted by Earth Stove on June 17, 2015 with No Commentsas , , , , , , ,
Rosalie Bianco founded Boulder-based
New Earth Pellets using bark beetle-damaged
trees to make the pellets.  Her company, like
others, will  have to start filling out this
survey in 2016. 

The US government is poised to begin a monthly survey of pellet producers, much like it conducts similar surveys for coal, oil, gas, and other renewable technologies like solar panels.  The Alliance for Green Heat has been part of a coalition urging the government to include thermal biomass in reports, policies and data collection initiatives.

Some pellet manufacturers may say, “be careful what you wish for, lest it may come true.”  Efforts by the Pellet Fuels Institute and others to gather information about how many pellets are being produced each year have been met with resistance by many manufacturers. 
In contrast, response rates to surveys by the Energy Information Agency (EIA) are often 100% according to EIA staff because response to the EIA energy surveys is mandatory pursuant to Section 13(b) of the Federal Energy Administration Act of 1974.  Failure to respond to EIA surveys is punishable by significant fines.
The EIA-63C “Densified Biomass Fuel Report” will require any company that produces more than 10,000 tons (the EIA expects there to be about 150) to fill out the survey monthly, which the EIA estimates will take one hour to complete.  The EIA aggregates the survey responses and does not release any company specific data, a strict rule that follows with all energy surveys.
The EIA is an independent information agency within the Department of Energy.  Its long hallways are filled with wonky number crunchers who produce some of the most important data that industry and government rely on to understand energy markets.  Thermal biomass being selected at long last to join the club of major energy producers shows recognition of its contributions to heat homes and institutions across America is growing.
The EIA wants to know how much PFI certified and non-certified pellets manufacturers are making for both the bulk and bagged market.  For the PFI certified pellets, the EIA wants to know whether they are premium grade, standard or utility grade.

The survey also asks if pellets are being sold domestically or to foreign markets and even why plants may not be operating at full capacity.  The survey asks if extrusion machinery was not fully utilized, was it a shortage of raw materials, drying capacity, grinding capacity, or lack of a market for them?

As pellet exports for European electric plants have become more controversial, one relevant part of the survey covers the origin of wood fiber.  The survey lists 10 possible sources of fiber: from pulp wood quality roundwood to wood chips to logging residues to sawdust.  Then, it asks if this fiber is from a natural private forest, a planted private forest, or public land.  See more in chart below:
In addition to pellets, the survey includes other densified biomass such as wood bricks, wood logs and briquettes.  The results will likely show a rapidly expanding wood brick/log sector, which has the potential to produce far cleaner fuels than cordwood in residential wood stoves.  However, there is no quality certification process for these types of densified biomass in place yet, as there is for pellets.  As this market matures and supply begins to meet demand in upcoming years, there is likely to be more focus on the ingredients used in the fuel, just as there is now with pellets.
“This survey is a sign that the US government is taking thermal biomass more seriously,” said John Ackerly, President of the Alliance for Green Heat.  “Pellets can provide a clean and efficient alternative to fossil fuels to heat our homes and buildings.  We applaud the EIA for agreeing to undertake this survey so that all stakeholders can have a level of detail and transparency,” Ackerly added.
The survey has already been through one public comment period, where major stakeholders, including the Alliance for Green Heat, provided feedback and suggestions to the EIA.  It is now being sent out for a second 30-day public comment period.  


Heated Up!

US to begin necessary study of wooden pellet types, volumes and substances

Posted by Earth Stove on June 14, 2015 with No Commentsas , , , , , , ,

Rosalie Bianco established Boulder-based mostly New Earth Pellets employing bark beetle-broken trees to make the pellets. &nbspHer organization, like other individuals, will &nbsphave to begin filling out this survey in 2016.&nbsp The US authorities is poised to get started a regular monthly survey of pellet producers, considerably like it conducts similar surveys for coal, oil, […]

New EPA Stove Rules Begin Cleaner Chapter for Wooden Heating

Posted by Earth Stove on February 6, 2015 with No Commentsas , , , , , ,

Statement by the Alliance for Green Heat on the Wood Heater NSPS Key EPA architects of this NSPS includeGreg Green, left, and Gil Wood,  right  andAmanda Simcox. Gil retired on February 3.  Overall, the EPA did a good job and released a fair rule that includes many compromises between industry and air quality agencies.  We […]