Bill McGrath: A pioneer in making electricity from a pellet boiler


Bill McGrath

In 2007, Bill McGrath built a thermoelectric pellet boiler that heated his home for almost 10 years. The story, however, starts in 1998, when Bill and a group of other students at Vermont Technical College entered the “American Tour de Sol” Solar Challenge, a solar car competition sponsored by DOE, not unlike the Wood Stove Design Challenge. The competition taught him about solid state technologies and the important role DOE competitions can play in promoting innovation. 


Building on his own experience and Shuji Nakamura’s discovery of commercially viable LED lighting, Bill helped start LEDdynamics in 2000, an LED circuit and lighting manufacturer. However, in the back of his mind he was also thinking about how thermoelectric generators (TEGs–pronounced T-E-G, like L-E-D) could solve a major problem with pellet stoves and boilers: when the electricity goes out, unless you have a big battery or generator, the pellet stove stops operating.

Bill and his colleagues made the TEG powered pellet boiler from an old oil boiler, a washing machine and other various knickknacks. McGrath recalls turning the fire chamber of the old oil burner into a pellet stove, using metal cat food dishes from the dollar store as burn pans, and using an old washing machine as the hopper by shaping it into a funnel that connected to a DC auger that fed the pellets into the burn pans. The hot water coming from the boiler heated one side of the thermoelectric modules, while the cool water that circulated through the home’s radiator system cooled the other side of the modules. This temperature differential (known as the Seebeck effect) generated the electricity to power the auger, blowers and water pump for the heating system.  The thermoelectric pellet boiler produced up to 60 watts and kept him and his family warm for over 9 years, even during power outages. One goal of the Design Challenge is to improve on Bill’s TEG boiler so that a thermoelectric wood stove or boiler can produce substantially more electricity to help power lights, recharge batteries and augment solar power.
After 9 years of heating Bill’s home and
making its own electricity, the home-
made boiler came out of the basement.


In 2013, Bill and his team created a thermoelectric energy generation division at LEDdynamics called TEGpro to share their expertise with everyone from large multinational corporations to small inventors. Surprisingly, the division has found many opportunities for their thermoelectric technologies’ in the petroleum and gas industry. With miles of piping, this industry has a large demand for TEG powered pressure sensors and wireless devices that measure liquid and gaseous chemicals and fuels as they move through the pipeline.  TEGpro is working with the petroleum and gas industry as an “intermediate step” until they can fund projects that hold larger implications for growth in thermoelectric wood and pellet stoves and boilers. 

TEGpro’s customers are already demonstrating the advantages of thermoelectric technology in residential applications across the world. For example, Bill references many instances of users in Alaska and Canada transferring wood stove heat through their cabins by putting TEGs on their central boiler systems, providing them a critical source of electricity without having to use a generator. 

Bill expects TEGs’ trajectory to be like what he experienced with the rise of LEDs since his start at LEDdynamics. Today’s modern LED light was discovered by Shuji Nakamura in 1994, who received the 2014 Nobel prize in physics for his work. Like the pre-Nakamura LEDs, Bill recognizes that the cost and efficiency of thermoelectric generators remains a challenge, but he believes that thermoelectrics will become as commonplace as LEDs.  With events like the Wood Stove Design Challenge, he is optimistic for the future of TEG power generation. However, commercializing energy alternatives like LED lights and solar power needs support from government agencies like DOE to fund the university research and competitions that can make TEGs as common as LEDs.

Heated Up!

Trump Administration to change Obama era wood stove and boiler emission regulations

Delaying or weakening emission regulations will impact thousands of communities nationwide
The EPA is “taking steps to provide relief to wood heater manufacturers and retailers” according to a statement released by the EPA.  The EPA expects to issue a proposed rule this spring that could potentially weaken parts of the regulations enacted under the Obama administration.
This move is supported  by companies such as Central Boiler, the largest outdoor wood boiler manufacturer in North America, who has been aggressively lobbying to delay and weaken the standards that were to come into effect in 2020. But to some smaller companies who have already invested in the R&D to meet the stricter 2020 standards, the EPA announcement undermines the significant investment they’ve made in designing cleaner and more efficient wood heaters. 
Thousands of cities, towns and communities are impacted by excessive wintertime levels of wood smoke, posing health risks and undermining support for an iconic renewable energy technology.
It is widely expected that part of the relief that EPA will be providing to industry is a three-year delay in the emission standards that were  set to take effect in June 2020.  Republicans in the House of Representatives had already passed legislation for a three-year delay, but the Senate has not.  A court filingby the EPA said that it “intends to take final action on this first proposed rule by this fall,” and that would allow manufacturers to slow down their R&D and certification testing.
But the EPA can pick and choose which parts of the Obama era wood heater regulations that it wants to rewrite and they say they will issue a series of federal register notices asking stakeholders for comment and input on substantive issues.  Experts believe that a statement released by the EPA indicate that emission test methods are being considered. 
Environmental groups, industry and the EPA have been wanting to move away from testing and certifying wood stoves with crib wood – 2x4s and 4x4s – which has been the standard testing fuel since the first set of wood stove regulations in 1988.  All parties want to switch to using cordwood, the fuel used by homeowners, recognizing that stoves have been fine tuned to run better on crib wood, rather than cordwood.  This has resulted in stoves that may run at 4 grams an hour of smoke in the lab, but may be 10 grams an hour or more in the hands of homeowners. In a statement this week, the EPA said it is concerned that its regulation“may not be achieving the environmental benefits it was supposed to provide.”  
The EPA appears likely to accelerate the transition to testing with cordwood but industry seems to favor an ASTM cordwood test method while some states and others are developing a new method that reflects how stoves are used by homeowners.  This method, call the Integrated Duty Cycle (IDC) method is still in draft form and is a drastic departure from the traditional way that stoves have been tested since the 1988.  
The EPA could also decide to weaken emission limits for wood boilers, which would primarily benefit the outdoor wood boiler industry led by Central Boiler.  
Since the 2015 regulations went into effect, scores of wood and pellet stoves and boilers have been tested to meet the 2020 standards and most prices have not gone up significantly.  The 2015 regulations began a process of requiring that manufacturers test and report their efficiencies, and delaying the 2020 deadline would set back efficiency disclosures, harming the ability of consumers to choose more efficient appliances. 
States are allowed to set stricter standards but not looser ones, and if the EPA were to weaken the federal rule too much, some states could either stick to the original standards set by the Obama administration in 2015 or develop new ones. States like New York, Oregon, Vermont and Washington are already battling long-term wood smoke problems and have started to chart their own course for wood heater regulations. If several states adopted a different cordwood test method or stricter emission standards, they could have a “California effect” of moving the entire market.
“We are very concerned that the Trump Administration  may weaken consumer and environmental protections for wood stoves,” said John Ackerly, President of the Alliance for Green Heat, an independent non-profit that promotes cleaner and more efficient residential wood heating. “Wood and pellet stoves are vital to help families affordably reduce fossil heating fuels, but we can’t move this technology forward unless they can burn cleaner in people’s homes,” he said. 

Heated Up!

States attempt to update outdoor wood boiler laws to conform to new federal policies

The EPA’s new wooden heater regulations has left far more than ten states with outside boiler restrictions that now want updating. Most point out rules refer to Stage 1 and Stage 2 boilers, a voluntary plan that has now been superseded by certified boilers in new EPA rules.&nbsp&nbsp

At the moment, at the very least New Hampshire and Maryland are updating restrictions and the province of British Columbia presently integrated language for the new EPA accredited boilers.

The wording in these laws is frequently difficult and several states have produced accidental results in the earlier, these kinds of as Maryland whose laws only permitted Section two outside boilers to be set up, effectively prohibiting the installation of considerably cleaner and more effective indoor pellet boilers.

Scott Nichols, operator of Tarm biomass in Orford New Hampshire, is functioning with New Hampshire officers to steer clear of unintended benefits.&nbsp 1 concern, for example, is his advice to preserve the exemption for out of doors pellet boilers from residence line set again principles, an exemption in area considering that 2010.&nbsp Most states that regulate outdoor boilers have established set backs, from fifty to a lot more than two hundred feet.&nbsp

The Alliance for Green Heat is urging states to retain or set up property line established backs for out of doors wood boilers, like the new certified kinds, given that they can nevertheless emit abnormal smoke if they are loaded with unsplit, unseasoned wooden.&nbsp “We suggest a least of fifty ft from the property line and a hundred and fifty ft from the nearest neighboring residence for qualified wood boilers and far more for non-certified kinds,” explained John Ackerly, President of the Alliance for Environmentally friendly Heat.&nbsp

As of mid-February, 2017, New Hampshire is proposing 50 foot established-backs for certified wire wooden boilers, but Maryland’s draft did not include any established backs.

Yet another concern that retailers of present day indoor qualified wooden and pellet boilers are anxious with is the definition of outside boiler. “The EPA definition is improperly written and is a dragnet that catches each and every boiler in existence given that any boiler can be installed outdoors or in a framework not typically occupied by humans” Scott Nichols said.&nbsp New Hampshire agreed and altered their rules to specify that outdoor boilers are people boilers that are needed to be set up outside, so as not to incorporate indoor boilers that happen to be put in in a garage, for instance. Nichols is urging “all states to adjust their definitions for OWHH as New Hampshire has.”

The EPA’s former voluntary qualification software and current certification program for outside wood boilers (hydronic heaters) has helped to minimize particulate subject when the boilers are operated responsibly.&nbsp In addition to stricter emission standards, most certified boilers now have controls that assist make certain much better combustion through the burn cycle and lessen the impacts of biking.&nbsp

However, a lot of professionals and condition and neighborhood air good quality agencies continue to be involved that EPA-qualified Section two and EPA qualified boilers can make extreme smoke in the hands of many operators.&nbsp One particular key plan reaction has been to set up set backs from house strains and/or nearby residences.&nbsp Most states where outside boilers are well-likedwith the exception of the Excellent Lake states where most outdoor boiler producers are positionedsustain set backs.&nbsp set backs help make certain that outside wood boilers are not installed in densely inhabited regions and even in rural regions, they offer a buffer with the quick neighbors.

Home line established backs: The most frequent sort of established backs are property line established backs.&nbsp They usually assortment from 50 to 200 toes, with a hundred ft becoming the most frequent.&nbsp Maine, Massachusetts, New Hampshire, New York, Pennsylvania, Utah, and British Columbia all use residence line established backs.

Established again from closest neighboring home: Connecticut and Vermont are the only two states that use set again from the closest neighbor’s home.&nbsp They each require 200 toes, symbolizing stricter guidelines.

The two residence line and nearest home: Maine and Massachusetts use the two property line and closest residence. &nbspFor EPA Stage two boilers, Maine needs fifty feet from the residence line or 70 ft from a neighbor’s home. &nbspMassachusetts requires 50 feet from a property line and 75 feet from nearest property.

Seasonal limitations: Two states, Indiana and Massachusetts, do not let outside boilers to work in the summer season as they can result in even far more air pollution in hotter temperature when they are very likely to cycle on and off far more regularly. &nbspIn addition, Maryland just lately wrote draft regulations that would limit use from May 1 to September 30.

Stack heights: Most states that demand set backs also call for minimal stack heights.&nbsp (This memo does not address these.)

Sunset clauses: Most point out guidelines only apply to foreseeable future installations, but some, this kind of as Vermont and British Columbia, have sunset clauses for conventional boilers.&nbsp In British Columbia, only EPA accredited and Phase 2 boilers can be operated soon after November 1, 2026.

Connecticut


Connecticut Law
CGS § 22a-174k, enacted in 2005, bans the set up or operation of OWBs that do not meet up with specified specifications. A violation of the regulation is an infraction.
With a handful of exceptions, the law prohibits any individual from creating, setting up, establishing, modifying, operating, or using an OWB right up until EPA rules governing them consider influence.
The law makes it possible for OWBs if they have been both developed, modified or in use prior to July 8, 2005 or they

one. are put in at minimum 200 ft from the nearest neighboring home

Maine

DEP Details SHEET Regulation of Out of doors Wooden Boilers , Effective Date: November nine, 2007 Contact: 1-800-452-1942 or 207-287-2437 Amended: July 4, 2008

Site SETBACK Needs
OWB installations need to have to meet up with minimum setback requirements made to shield general public wellness. The setback distance required depends on the unit’s emission ranking, with diminished setbacks permitted for cleaner-burning OWB types. The setback table underneath lists the bare minimum length an OWB device requirements to be from any neighboring property line or dwelling. Customers should meticulously consider regardless of whether their house configuration provides the needed area to meet the setback requirements just before getting a boiler device.

OWB Emission Score
(in lbs . per million BTUs or lbs/MMBtu)
Minimal Setback Distances
from Residence Line OR from Dwelling
.32 lbs/MMBtu
50 toes OR 70 toes
.sixty lbs/MMBtu
100 toes OR 120 toes
&gt0.sixty lbs/MMBtu (such as uncertified OWBs)
250 feet OR 270 feet

Massachusetts

310 CMR seven.26(fifty) Outside Hydronic Heaters
On and soon after December 26, 2008 no person shall:
one.&nbsp&nbsp&nbsp&nbsp Web site or install a household-size out of doors hydronic heater that meets the emission standard outlined in 310 CMR 7.26(53)(a), until it is set up at the very least fifty ft from any house line and 75 ft from any occupied dwelling that it is not serving, at the time of installation.
New Hampshire&nbsp
a hundred twenty five-R:three Setback and Stack Height Specifications. –
&nbsp&nbsp I. No person shall install a Stage I OWHH except if it is mounted at least one hundred ft from the nearest house line and has a everlasting attached stack that is at least 2 feet larger than the peak of the roof of a residence or place of organization not served by the OWHH if that home or area of company is situated inside 300 ft of the OWHH.
&nbsp&nbsp&nbsp II. No particular person shall put in a Period II OWHH unless of course it is at minimum fifty toes from the closest residence line.
&nbsp&nbsp&nbsp III. No individual shall put in an OWHH that is not a Section I or Phase II OWHH unless it is found at the very least 200 ft from the nearest abutting home and has a everlasting hooked up stack that is at the very least 2 ft greater than the peak of the roof of a residence or place of business not served by the OWHH if that home or location of organization is situated inside of 300 feet of the OWHH.
Resource. 2008, 362:two, eff. Aug. ten, 2008.
New York
6 CRR-NY 247.4
NY-CRR
SUBCHAPTER A. Prevention AND Control OF AIR CONTAMINATION AND AIR Pollution
Part 247. Out of doors Wooden BOILERS
All new OWBs must meet minimum setback specifications. Residential-measurement new OWBs (thermal output ratings of 250,000 British thermal units for each hour (Btu/h) or considerably less) must be sited 100 toes or far more from the closest residence boundary line. Professional-size new OWBs (thermal output rankings increased than 250,000 Btu/h) need to be sited 200 ft or much more from the nearest property boundary line, 300 ft from the nearest house boundary line of a residentially-zoned residence and one,000 ft or far more from a university.
Pennsylvania
Title 25—ENVIRONMENTAL Security
ENVIRONMENTAL Quality BOARD
[25 PA.CODE CHS. 121 AND 123]
Outdoor Wood-Fired Boilers
[forty Pa.B. 5571]
[Saturday, Oct 2, 2010]
Beneath closing-kind subsection (d), relating to setback requirements for new Phase two out of doors wooden-fired boilers, a person may possibly not set up, use or function a new Section two OWB unless the boiler is mounted a least of 50 feet from the nearest residence line.
Vermont
 
ADOPTED RULE – Powerful Date: July 5, 2014 
                          Company OF Organic Resources                               Montpelier, Vermont 
                     ENVIRONMENTAL Security Regulations                                    CHAPTER 5                              AIR Pollution Manage 
one.&nbsp&nbsp&nbsp&nbsp Set up Needs
(i) After Oct one,1997, no man or woman shall put in or let the set up of any OWB that is not a Period I OWB or a Period II OWB except if the OWB:
  1. (A) &nbspIs found more than two hundred feet from any residence that is neither served by the OWB nor owned by the owner or lessee of the OWB and,
Utah
R307. Environmental High quality, Air Quality.
Rule R307-208. Outside Wooden Boilers.
As in result on January 1, 2017
(two) No particular person shall function an out of doors wooden boiler within 1000 toes of a non-public or community college, medical center or working day treatment facility.
(three) Setback. A new residential out of doors wood boiler shall not be situated much less than a hundred ft from the closest house boundary line. A new commercial out of doors wooden boiler shall not be located much less than 200 feet from the closest home boundary nor 300 ft from a house boundary of a residentially zoned house.

British Columbia (Canada)


PROVINCE OF BRITISH COLUMBIA
Purchase OF THE LIEUTENANT GOVERNOR IN COUNCIL

Purchase in Council No. 650 , Sept. 19 2016
Boilers -setback and operational requirements

seven (one) In this area, “put in” means installed outdoor or m a composition not ordinarily employed as living area.
(2) &nbspAn proprietor of a parcel should guarantee that a boiler that is put in on the parcel soon after November I, 2016 but before May one, 2017 is mounted as follows:
(a) if the boiler is a accredited boiler or a phase 2 experienced boiler, not considerably less than forty m [131 ft] from every single of the parcel’s boundaries
(b) in any other case, not significantly less than 80 m [262 ft] from every single of the parcel’s boundaries.
(3) &nbspAn proprietor of a parcel should guarantee that a boiler that is mounted on the parcel on or right after Could one, 2017 is
(a) a accredited boiler, and
(b) installed not much less than forty m from every of the parcel’s boundaries.

(four) &nbspDespite subsections (2) (a) and (3), if the qualified boiler is made to bum only pelletized gasoline, the boiler need to be set up not Jess than I0 m [32 feet] from each of the parcel’s boundaries.
(five) &nbspA individual need to not work a boiler installed contrary to subsection (2) (a) or (b), (3) or (four).

(6) &nbspOn and right after November one, 2026, a person have to not operate an set up boiler except if the boiler is a accredited boiler or a phase two certified boiler.
Heated Up!

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

On April 15, three air quality groups filed a motion to join the lawsuit that a hearth industry group is bringing against the EPA over their new wood stove and boiler regulations.  These groups said that their interest lies in “defending the Final Rule against challenges brought by industry groups seeking to further weaken or delay it.” This development is likely to make the suit more difficult for the hearth industry.

Add caption
The most prominent of the groups, the American Lung Association (ALA), has a long history of both cooperating with the EPA and also being part of suits against it.  Their motion suggests that the EPA’s new rule could or should be stricter, but they do not appear to be suing for stricter emissions standards.  If the air quality groups had chosen to sue for stricter standards, they would have risked having the rule sent back to EPA for revision, which could backfire as a revised rule may not be issued until 2017 or later, when a Republican nominee could potentially be running the EPA.
The industry strategy may be precisely that –to send the rule back to EPA for revision, then to try to delay the revision until a more sympathetic administration takes over.  But this strategy also poses a risk for industry, as the revised rule could emerge even stricter depending on who takes charge of the EPA.
The hearth industry group, the Hearth Patio and Barbecue Association (HPBA) a loose amalgamation of wood, pellet, gas, grilling and outdoor furniture industries has not yet laid out the basis of its suit and is not required to do so until the DC Circuit Court sets a briefing schedule.  The date for oral argument is usually set 6 to 8 weeks after the date final briefs are due, and the three-judge panel for oral argument typically is not be announced until shortly before the argument.
There is still time for HPBA to file a petition for reconsideration with the EPA.  The most likely scenario is that the rule will become law on May 15, 2015 and the HPBA will be focusing on challenging the stricter Step 2 emission standards, which take effect in 2020.  Other parties can still file a suit, or a motion to join this suit, until May 15. 
The other two air quality groups who joined the suit along with ALA are the Clean Air Council (CAC) and Environmentand Human Health, Inc.(EHH).  CAC is based in Philadelphia and focuses on a wide array of energy and environmental issues.  EHH is a small group based in Connecticut and has worked on outdoor wood boiler pollution for many years.  All three groups, the ALA, CAC and EHH, were active in the comment process on the rule.  Earthjustice, a public interest law firm that does not charge its clients, is representing the groups.   The Environmental Defense Fund, which had teamed up with these three groups on earlier litigation, did not join this intervention.
In the groups’ motion to intervene, they said, the “Hearth Association will likely seek to weaken or delay the Final Rule’s requirements, as their comments during the rulemaking sought to weaken protective measures required under the Final Rule. For example, the Hearth Association objected to EPA’s use of emissions testing as a quality assurance tool to verify manufacturers’ ongoing compliance with emission standards.”
One strategic point of this lawsuit will be the selection of the 3-judge panel, which is done at random.  Generally, insiders tend to consider Republican appointees more industry-friendly and Democratic appointees more inclined to support public health groups.  History has shown that judges can be less-than-predicable in terms of how they deal with threshold legal issues such as standing, ripeness, procedural issues, or deference owed to the agency, and their decisions on these issues rarely break down along party lines.  Although everyone will be interested in knowing the three judges that will form the panel, knowing who they are is rarely enough to predict how the case will turn out.
The new EPA rules cover everything from very clean pellet stoves to extremely dirty outdoor and indoor wood boilers.  Most pellet stoves and some wood stoves, for example, already meet the 2020 standards and are very affordable. The industry lawsuit is likely to focus on 2020 standards that some indoor and outdoor wood boilers will struggle to meet, as well as 2020 wood stove standards that will raise the cost for some stoves.  In the 6 months leading up to the announcement of the rule, the industry focused mainly on delaying the rule’s implementation for indoor wood boilers.
For more information about the rule, see “What Consumers Need to Know about the NewStove Rule.”

Heated Up!

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.

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Pellet Boiler Also Helps make Enough Electricity to Electricity Residence

Austrian company OkoFEN has brought to marketplace the very first household electricity making pellet boiler, the Pellematic Sensible_e. The boiler makes use of a pellet-condensing module from an before pellet boiler design, the Pellematic Wise and outfitted it with with a Microgen Stirling Motor. The motor employs a heated/cooled helium hydraulic system. The consequence of these two systems is a exclusive boiler that is capable of outputting fourteen kW (47,770 Btu/h) of thermal power and one kW of electricity.
The Pellematic Wise_e can help save households’ income on equally heat and electrical energy payments. Switching from oil, propane, or electrical energy to pellets typically results in substantial savings. The warmth is employed for area heating of the dwelling area and domestic very hot h2o generation. Additionally with the included Stirling Engine, the electrical energy you make in your own residence can offset element of a home’s regular monthly electricity bill. A full load of 24 several hours can create 24 kWh of electrical power at 1kW.
At 24 kWh per working day, the Pellematic Sensible_e could produce enough electrical energy for most or all of a home’s average everyday electrical energy needs. Nonetheless, in get to produce this electric power, the boiler need to operate at total potential, which can develop a considerable amount of excessive warmth. The surplus heat may be saved whilst the electric power is even now produced but even with the heat storage abilities, some of the heat may possibly be dropped, and the effectiveness of the boiler falls. For the Pellematic Smart_e to meet up with the electric power needs of a property, it would have to lengthen much over and above the heating demands of that home.
“The concern is the big 14:1 ratio amongst thermal and electrical power on this unit, and the (very likely) slim output curve,” explains Norbert Senf, one of the judges for the Wooden Stove Design and style Obstacle, “In a thermal electricity making station, you get about a 2.5:1 ratio.”
Even though it is possibly not the most successful when it will come to making electricity, OkoFEN’s revolutionary boiler demonstrates the possible of this hybrid technological innovation. The achievement of this solution is most likely to lead to additional sector advancements to manufacture and distribute pellet boilers able of generating even greater amounts of electrical energy.
For more info verify out OkoFEN’s web site listed here
Also, their FAQ website page right here


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EPA Requests Outdoor Boiler Organizations to Remove Disputed Efficiency Scores

On May possibly nine, the EPA sent letters to manufacturers of outside boilers requesting that they get rid of effectiveness details for EPA competent designs tested with EPA’s Method 28 OWHH from websites and all printed components. The EPA sent them new hangtags with out efficiencies to exchange the aged kinds.&nbsp
The letters, signed by Gregory Green, Director of the Outreach and Training Division, requested that this be accomplished by June fourteen, giving organizations about seven months to comply. The businesses are also requested to tell their retailers to discontinue use of the aged hangtags and printed components utilizing the aged efficiency numbers.
The EPA’s transfer to quit the use of those discredited efficiency numbers was welcomed by the Alliance for Green heat and a lot of condition organizations and business users.&nbsp&nbsp&nbsp
The request is the most recent twist in a voluntary program that eroded each the EPA’s trustworthiness to test effectiveness and the boiler organizations who continued to use the impossibly substantial numbers. It also gave a significant advertising edge to outdoor boilers who could assert far larger efficiencies than wooden and pellet stoves and automatic European boilers.&nbsp Outdoor boilers analyzed under the unique EPA accepted check have been earning efficiencies of up to ninety seven%.&nbsp
The EPA taken off the performance quantities from their site in 2011 and requested makers to end utilizing them.&nbsp Makers reportedly balked, expressing they would not stop utilizing the higher efficiency quantities until finally their opponents stopped.
Right now, it is unclear how effective Stage two outdoor boilers really are. According to a paper from Intertek, one particular of the leading wood stove examination labs: “With the exception of a variety of examination reports indicating impossibly large efficiencies, the weighted regular efficiencies of appliances conference EPA Stage II emissions limits typical fifty five%.”&nbsp The Point out of Maine gives an estimate of sixty five% effective to Period two outdoor boilers on its fuel calculator and 55% for unqualified boilers.
Relevant stories:


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Invoice to overturn out of doors wood boiler rules fails to pass Utah Legislature

Salt Lake Metropolis, Utah – The Republican dominated Utah Senate upheld laws on outside wood boilers by not voting on a invoice that experienced very easily handed the Utah Residence. &nbsp The monthly bill, HB 394, would have overturned restrictions on outside boilers that was handed nearly unanimously by a Property committee and then by the full House on Tuesday by a vote of 59 to twelve. The bill most likely would have handed the Senate experienced it not been for the initiatives of advocacy groups these kinds of as the Alliance for Green Heat, the Wasatch Clear Air Coalition and other people anxious about the damaging impact out of doors wood boilers can have on regional air high quality.

Proponents of the invoice had been distributing a flyer with inaccurate and deceptive information to legislators. The flyer mentioned that OWBs are cleaner and far more productive than EPA certified wood stoves and that forty nine states permitted what the new Utah restrictions would not. In reality, the Utah restrictions authorized the set up of certified outside wooden boilers in most of the point out but did not allow their installation in the more populated locations that had been in air good quality non-attainment.

The Alliance for Green Heat contacted the Senate sponsor of the invoice who turned extremely concerned about the accuracy of flyer as nicely as a key proponent of the monthly bill who experienced represented himself as a concerned citizen but who was in fact becoming paid by Central Boiler to guide the campaign. The Alliance collected forty five signatures in under 24 hours for an open sign-on letter to the Utah legislature urging them not to vote for this invoice that would overturn affordable restrictions the state set on outside boilers this February. The signatories represented leaders in the biomass sector, nonprofits, professors and clean air advocates and citizens who experienced been personally influenced by OWB smoke and more.

A important concern, related to a lot of towns and valleys in the West, like locations like Libby Montana, is regardless of whether EPA competent outside wooden boilers need to be permitted in populated valleys that encounter inversions and are in non-attainment. Central Boiler and HPBA sent remarks to Utah officials that had been really crucial of the restrictions that only permitted out of doors wooden boilers to be mounted in rural, attainment locations.

For far more history and data on the position of the Alliance, click below.

Click on here to see the letter to the Utah legislator signed by fifteen leaders of the wooden stove and boiler sector and other professionals and here to see the letter signed by forty six men and women.

Thanks to everybody who lent their voice to this marketing campaign. With your support, we ended up ready to assist the Utah legislature comprehend the disinformation campaign that the invoice was dependent on.
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An Open Letter to the Utah Legislature in Help of Outdoor Wood Boiler Restrictions

The Utah legislature is transferring rapidly to overturn quite reasonable and reasonable laws on out of doors wooden boilers. You should consider introducing your signature to the open up letter under, urging Utah to preserve the laws approved by their Air Top quality Board.

Utah’s rules permit the installation of EPA Section 2 outdoor wooden boilers in most of the condition, but ban them from the extremely populated regions about Salt Lake which are in air top quality non-attainment.

An outdoor boiler maker is aggressively battling to get the legislature to overturn these regulation dependent on a lot of misleading statements. Simply click below for the flyer becoming circulated to Utah Senators, which argues that outside boilers are much a lot more productive and cleaner than stoves.

The legislation, HB 394, was handed by the Utah property yesterday by a vote of 79 to twelve. It moved to the Senate today and will be voted on Wednesday or Thursday with no becoming referring to any committee for a hearing. This laws will “amend the powers of the Air Top quality Board” and prohibit them from “regulating the sale, set up, alternative or procedure of an out of doors wood boiler any in different ways from any other sound gas burning products.”

If the Senate passes this evaluate, unregulated and unqualified outside wooden boilers will be permitted to be installed in Utah.

If you can incorporate your title to the letter under, remember to email your identify (and affiliation if you want your affiliation to appear on the letter) to melissa@forgreenheat.org by no later than 4:00 pm on Wednesday, March thirteen.

For a lot more information about this, click on here.

*****

Expensive esteemed users of the Utah Senate,

We, the undersigned, are producing to urge you not to vote for HB 394 which would overturn Utah’s out of doors wooden boiler laws.

The Utah rule finalized by the Air Top quality Board is very realistic, reasonable and constant with attempts and regulations in a lot of other states. Revoking the rule is unwarranted and unwise and will open up a market for boiler organizations to offer very polluting and unregulated appliances.

The efforts to overturn this regulation are dependent on misleading and inaccurate claims, as set forth in the flyer “Some Specifics About HB 294.” For example, the flyer statements:

“Out of doors wooden boilers are completely legal in forty nine other states and only banned in Utah’s non-attainment locations.”

“Outside wood boilers are a lot of moments much more productive than EPA certified indoor wood burners.”

States all more than the region are enacting rules comparable to the ones Utah created. These restrictions are sensible and required to avoid the spread of the most polluting wood burning gadget in The us — outdoor wooden boilers that are not EPA competent.

At the really minimum, this bill justifies a entire hearing and must not be voted on rapidly at the extremely conclude of the legislative session. We urge you to defend the reputation of the Utah Senate and not vote for this flawed bill that is based on so a lot of misrepresentations.

Sincerely,

[Your identify]
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Outside boilers cleaner than wood stoves, boiler lobby tells Utah legislators

Legislators go to overturn outside boiler restrictions

In a heated combat over no matter whether out of doors boilers ought to be authorized in regions of Utah with inadequate air quality, the outside boiler lobby is swaying lawmakers with information showing that boilers are cleaner than wood stoves.

The lead Utah resident pushing for rules that would permit out of doors boilers, Daniel Leavitt, represented himself as a worried citizen to the Utah Air Top quality Board, and the Utah paper refers to him as a resident who operates his out of doors wooden boiler to heat his property. But what the paper failed to mention is that Leavitt is also a prominent Utah lawyer specializing in authorities relations and the brother of the previous Governor of Utah. What is actually more is that Leavitt is being paid out by Central Boiler, the boiler manufacturer foremost the marketing campaign.

In February, Utah adopted regulations that permitted the installation of Section 2 out of doors boilers in most of the condition but banned them in populated regions that do not meet federal air high quality attainment specifications. Central Boiler had fought against the laws but had been eventually unsuccessful.&nbsp

Following the restrictions were promulgated, the boiler company took its scenario to the legislature. On March 7, a around unanimous legislative committee sided with Central Boiler. They accredited HB394, which “prohibits the Air Quality Board from regulating the sale, set up, alternative, or procedure of an outside wood&nbsp boiler otherwise than other solid fuel burning
 units.” Om March 11, the bill was handed by the Utah Property and moved to the Senate.

Central Boiler submitted comments arguing that Period 2 out of doors boilers “are cleaner than EPA qualified wooden stoves.” David Leavitt, the “worried citizen” hired by Central Boiler, is also carrying that concept. “These outside wooden boilers are vastly a lot more productive than burning anything at all indoors,” he informed the Deseret News.&nbsp&nbsp

“Utah legislators ought to comprehend that even the best wood stoves and wood boilers are only as clean as the wooden that is loaded in them,” mentioned John Ackerly, President of the Alliance for Environmentally friendly Heat, a unbiased non-revenue marketing cleaner and much more successful wood heating.&nbspOutdoor wood boilers have fireboxes normally ranging from 14-sixty cubic ft even though a wood stove firebox is 2-three cubic toes.
“Outdoor boilers are often loaded with huge, unseasoned and unsplit logs and trash, in contrast to stoves.&nbspThis is a important reason that states control out of doors wood boilers and not stoves. Central Boiler adverts exhibiting efficiencies in the 90s are dependent on calculations that have been repudiated by the EPA,” Ackerly additional.

The Utah Section of Environmental Good quality (DEQ) explained the objections that that Central Boiler and Hearth, Patio and Barbecue Association (HPBA) experienced with the laws ended up “similar” and publicly responded to them. Privately, some people say the positions of Central Boiler and HPBA had crucial distinctions but the community document does not expose what they have been.&nbsp&nbsp

According to the Utah DEQ, the troubles raised by Central Boiler and HPBA included:
  • DEQ appears to spot increased excess weight to a variety of out-of-point out companies and other individuals who are generally skeptical towards the emissions reduction outcomes reached under the US EPA hydronic heater software.
  • DEQ has not offered scientific information or other rationale supporting what varieties of outside wooden boilers ended up authorized beneath the rule.
  • DAQ has not released any knowledge demonstrating that outdoor furnaces presently make impacts within the nonattainment and routine maintenance regions or that they will contribute to the exceedance of the NAAQS.
  • The 1000 ft. setback from schools is not necessary primarily based on modeling carried out by the State of New York.
In reaction to the initial proposed restrictions, Central Boiler argued that the “rule lacks scientific help and would unfairly prohibit Utah inhabitants from acquiring and employing thoroughly clean-burning wooden furnaces.” A principal thrust of Central Boilers argument is that Period 2 boilers “are cleaner than EPA certified wood stoves.” Exclusively they claim that “average emissions for a Stage 2 OHH are 77% considerably less than these from EPA-Qualified woodstoves.” The total submission by Central Boiler can be discovered&nbspright here.
“These outdoor wooden boilers are vastly more effective than burning everything indoors,” Levitt stated.

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