Excerpts of comments from the Advance notice of proposed rulemaking

The Alliance for Green Heat did an analysis of stakeholder positions which can be found here and also pulled out these excerpts for those who do not want to download and wade through hundreds of pages of comments, much of it repetitive.

The following excepts are what we view as key positions taken by stakeholders in the Advance response to the EPA’s request for comments on a range of issues, including:

·      compliance date for the Step 2 emission limits, 
·      Step 2 emission limits for forced-air furnaces, hydronic heaters and wood heaters, 
·      Step 2 emission limits based on weighted averages versus individual burn rates, 
·      transitioning to cord wood certification test methods,
·      compliance audit testing, 
·      third-party review, 
·      electronic reporting tool, and 
·      warranty requirements

We have taken key excerpts from all sides of the debate to highlight differences, The full comments can be found here.   Many other comments can be found in response to the EPA’s request for comments of the Proposed Ruleto give a sell-through for boilers and furnaces.  We only excerpted language for comments to the advance notice of proposed rulemaking, which elicited a far wider range of responses.

Excerpts are organized by: State Agencies, Industry, Retailers, Air Agencies, Federal Office and Non-profits. 


The Attorneys General of New York, Connecticut, Illinois, Maryland, Massachusetts,

Minnesota, New Jersey, Oregon, Rhode Island, Vermont, and Washington and the Puget Sound Air Quality Agency 

The step two compliance date is feasible and necessary to protect public health. Any delay in the implementation of the step two standards would have significant adverse public health consequences. Moreover, EPA has not provided any basis to change its previous determination that five years was an adequate amount of time for manufacturers to develop cleaner burning devices. 
·     The step two standards for wood boilers and forced-air furnaces are also feasible. 
·     Finally, the evidence shows that the 2.0 g/hr. emission limit is already too lax. In 2014, EPA proposed to set a limit of 1.3 g/hr, which the Attorneys General of New York, Maryland, and Massachusetts supported based on demonstrated cost effective design technologies that could reduce emissions. 

New York State Department of Environmental Conservation (DEC) and New York State Energy Research and Development Authority (NYSERDA)
Albany, NY 

1.     The 2015 New Source Performance Standards for wood stoveshydronic heaters, forced air furnaces (40 CFR 60 Subparts AAA and QQQQ) should not be reopened. Any changes to the rule (see items 23 below) should be addressed during the first review period for these rules in 2023. 
2.     The Environmental Protection Agency should adopt the Integrated Duty-Cycle (IDC) Test Methods under development by Brookhaven National Laboratory and the Northeast States for Coordinated Air Use Management prior to the 2023 rule reviews. 
3.     The 2023 rule reviews should lead to PM emission standards based on performance data generated using the IDC Test Method
4.     EPA should ensure that third-party certification reviews are not conducted by the laboratories conducting the certification tests

In the event that EPA weakens the 2015 NSPS rulesit is likely that several states, including New York, may consider backstop regulations to bring the NSPS provisions back into effect, potentially resulting in a patchwork set of state regulations that may increase compliance costs to manufacturers. 

Western Governors Association
Denver, CO

The emissions from wood heaters represent a critical public health and environmental issue in the West. Since the 1980s, states have implemented regulatory and voluntary strategies to address these emissions. The efficacy of such strategies depends on an effective NSPS.
The Western State Air Resources Council (WESTAR) requested that EPA extend the comment periods for the NPRM and ANPRM for an additional 45 days to provide sufficient time for state regulators to fully evaluate these proposals. WESTAR also requested that EPA hold a second public hearing in the West, as the only hearing on these proposals was held in Washington, D.C., with a minimal two-week notice. EPA summarily denied these requests, hampering the cooperative federalism that this Administration has made a priority.
Western Governors request that EPA maintain the current NSPS compliance deadlines for new residential wood heaters. 

Oregon Department of Environmental Quality
Salem, OR

Oregon communities depend on the NSPS and particularly the 2015 NSPS for residential wood heaters to complement our efforts to attain the National Ambient Air Quality Standards for PM2.5 to protect community health and environmental quality. Since wood heaters are not manufactured in Oregon, any public health costs associated with EPNs proposed rules in the NPRM or this ANPRM are disproportionately accrued to Oregon. 
Cordwood test methods

ODEQ is concerned that this language [in the ASTM 2515 cordwood test method]  allows manufacturer instructions to change almost any aspect of the emissions test method, without the requirement, such as fuel species or loading, to include these changes in the test report or the owner’s manual. 

This language is highly problematic and opens up the test to significant modifications that impact emissions measured during the test. The manufacturer should not be provided the discretion to determine what information is provided to owners or regulators regarding test results. 

Considering the test method research described above, EPA should build upon this multiyear effort by adopt a requirement now, to take immediate effect, for the concurrent use of a tapered element oscillating microbalance (TEOM) test method to measure real-time particulate matter (PM), using the NESCAUM Standard Operating Procedures, along with standard filter measurements for all EPA residential wood heating device NSPS certification testing, including pre-burn activities. For all testing, a complete real-time emission profile should be submitted as part of the non-confidential business information (CBI) portion of the test report.

EPA compliance audit testing
With respect to the selection of the lab to perform audit testing, one independent, third-party lab should be selected to conduct all compliance audit testing so that there is consistency across the program. The audit testing lab must not be allowed to complete certification testing for devices that it is auditing to ensure that the audit process is unbiased. 

With respect to variability in the compliance audit testing program, wood stoves that certify at less than 1 gram per hour (g/hr) should be allowed a variability of ± 1 g/hr. For units that certify at more than 1 g/hr, the current variability provision is adequate. 

Warranty requirements

EPA seeks comment on retention, revision or elimination of the warranty requirements included in the 2015 NSPS Rule. DEQ supports the retention of the warranty requirements for catalytic devices. For non-catalytic devices, EPA should add warranty requirements, particularly ones for key components related to controlling emissions from the device (including, among others, tubes). 

Mass. Dept. of Environmental Protection
Boston, MA

In summary, MassDEP opposes any delay or weakening of the existing Step 2 emission limits, which would defer needed reductions in air pollutants that adversely affect the health of Massachusetts citizens. The existing NSPS has resulted in manufacturers developing cleaner wood burning devices that are achieving real emission reductions, and it is critical that the NSPS be fully implemented according to the schedule in the 2015 rule. MassDEP supports the development of new test methods that better reflect real world operations of wood heating devices, which should be included in the next update of the NSPS in 2023. 

Wisconsin Department of Natural Resources,
Madison, WI

EPA should therefore recognize that modifying the Step 2 limits or adjusting the Step 2 compliance date for wood heaters would disadvantage manufacturers who already completed the Step 2 certification process to comply with EPA’s original deadline. 


Hearth, Patio & Barbecue Association
Arlington, VA
Test methods

Since 2009, HPBA has led efforts to move from crib wood testing to cordwood testing for all residential wood heating product categories, and we continue to support that transition. 


HPBA believes that a two-year sell-through period is critical to the health of the hearth products industry for —wood stoves, pellet stoves, hydronic heaters, and forced-air furnaces. 

Revising the current standards to provide a two-year sell-through period (from May 2020 to May 2022) for Step 1 stoves, roughly three-quarters of which are well under the 4.5 g/hr emission limit, would have a relatively miniscule environmental impact. 

Central heaters

EPA cannot remedy the errors in the Step 2 emission limits for central heaters by extending the compliance dates for central heaters. EPA should repeal those standards altogether. 
The Step 2 limit for forced-air furnaces was not based on any data. 

The Step 2 emission limit for hydronic heaters is not achievable at reasonable costs. 

Weighted Averages vs. Individual Burn Rates 

Compliance with all emission limits should be on a weighted average basis. Manufacturers often focus on performance at more heavily weighted burn rates. 

Compliance audit testing

EPA should limit audit testing to instances where there is suspected fraud in certification test results. Alternatively, EPA should add language to the regulations that prohibits audit testing for appliance categories until there has been a determination on variability for the applicable test. 

ISO-Accredited Third-Party Review 

EPA should rely on ISO-accredited third-party certification bodies to issue certificates of compliance rather than continue to issue every final certification application itself. This would allow EPA to focus its limited resources on performing oversight and enforcement functions. 

US Stove
South Pittsburg, TN 

Transition from Crib Wood to Cord Wood Testing 

USSC is fully supportive of working towards a cordwood test method that better represents real world use of residential wood heaters. Our company was actively involved in the ASTM standards development process for ASTM E3053 

As of today, there are companies testing and certifying stoves under this cordwood alternative, however hindsight is not a rulemaking mechanism that the EPA can or should use to regulate industry. The “limit” had already been set at 2.5 g/h before a test method even existed, and thus the EPA has artificially put its thumb on the scale. The only test reports that the EPA is going to see are those manufacturers who have been lucky enough to meet the 2.5 g/h limit. That is not how standards should be set. 

Feasibility of  the 2020 timeline

The EPA has stated it has given 5 years to meet the Step 2 2020 requirements. Although that may be true when looking at the actual dates, we, nor our industry as a whole, have not been given those 5 years to meet these requirements.  The 5 years that the EPA intended, effectively moved to 3.5 years in the eyes of the wood heater marketplace. 

At USSC we analogize the 2015 rule for residential wood heaters to the feat of climbing Mt. Everest, you have to strategically take one step at a time. 

It is our opinion that EPA also did not consider the reduced revenue which has occurred because of the lack of sell-through. Therefore, we have not benefited from 5 years of revenue required to fund the work necessary to meet the 2020 deadline. 

Forced air furnaces

The Step 2 requirements for forced-air furnaces as stated in the 2015 NSPS should be repealed; Step 1 standards for forced-air furnaces should be revisited at a future date to determine whether more stringent standards would be appropriate. There was no justification or data on the EPA’s part to warrant the Step 2 requirements. As we have stated above, the economic feasibility in the marketplace of a Step 2 compliant forced-air furnace is impractical given today’s technology. To move from a previously unregulated product (with no voluntary program) to Step 1 where these products are approximately 75% cleaner, and then in just 3 or 4 years later (small vs large forced air furnaces) move to approximately 97% cleaner (EPA estimates) at Step 2, without any data to justify a Step 2 limit, is preposterous and unrealistic.
Hearth & Home Technologies
Lakeville, MN

Test Methods – Transition to Cordwood

HHT strongly supports moving to a cord wood standard as it better aligns with the fuel type used in the real world, but manufacturers have invested millions of dollars designing, testing and certifying to Step 2 crib wood standards and will need additional selling time to recoup their investment to fund future cord wood designs. 

HHT recommends using ASTM E3053 until such time there is data showing that the ASTM method doesn’t replicate real-world cord wood emissions or that a new Federal Reference Method is needed. 

Step 2 Emission Limit for Wood Heaters 

The wood stove and pellet stove users tend to be very different people. With respect to different emissions standards, we believe this is a secondary issue to the EPA first understanding the precision and repeatability of the different fuels before making any more changes to emissions standards. 

The EPA Compliance Audit Testing 

It is not appropriate for the EPA to select a lab to perform audit testing. With so much variability, it makes more sense to keep compliance audit testing with the same lab.

ISO-accredited Third-party Review 

The only way to streamline the process would be to allow accredited third-party laboratories to do the emissions testing and grant the certificate of compliance. Having the EPA review the application and test report, which can take as long as 90 business days/16weeks to complete, is not a good use of time and resources. Instead, they should rely on their ISO-accredited third-party laboratories to issue certificates and the EPA retain oversight and enforcement with the laboratories. 

Warranty Requirements for Certified Appliances 

We would support eliminating the warranty requirements of the NSPS. All manufacturers already have warranty language that if the appliance is not installed and operated according to the installation/owner’s manual, the warranty will be voided. This language would be the warranty whether the EPA required it or not, it is standard warranty language for an appliance. 
Lamppa Manufacturing, Inc
Tower, MN

If our small compan(Lamppa Manufacturing, Inc.) can pass the Phase 2 NSPS mandate (we were actually 40% cleaner than thPhase 2 mandate), these other manufacturers with their sizeablR&D resources should also be able to meet the mandate within the timeframe. Lamppa Manufacturing achieved the mandate solelby hard work and determination and by borrowing from our family’s retirement funds. 

Lamppa Manufacturing adhered to the law and the timeline and has created a businesplan based on meeting the NSPS. Our new manufacturing facility ibeing built at a cost of $ 1.8 million, plus the cost of additional production capital equipmenThis investment would not havbeen undertaken if we knew the EPA was gointo weaken or re-write the standard. 
Blaze King
Walla Walla, WA

We feel strongly that had EPA taken into consideration our comments for the 2015 NSPS, EPA and state regulators would have cordwood data that is real-world. 

Blaze King feels that Method 28R should be retained with crib fuel testing. We also feel that the goal of regulators, from various parts of the country with various species of wood, could be addressed. 

When a manufacturer advises EPA of an upcoming test of a wood heater, required by law, EPA would then direct the lab of record to conduct a randomly selected additional cordwood run. EPA would direct the test lab to conduct 1 run from low or medium low or medium high or high burn categories. Additionally, EPA would direct a species of wood for that run. The one extra cordwood run emissions result would not influence the weighted average. This would eliminate the need to have a cordwood standard specific passing grade and yet provide cordwood data. As an example, regulators from Washington would shortly have data for how catalytic wood heaters perform on low with Douglas Fir. Meanwhile, Eastern regulators would soon receive data on how secondary combustion stoves perform on hardwood on another burn category. 

Blaze King Industries, Inc. is aware of a letter sent to EPA date September 7, 2018 from the State of Maine Department of Environmental Protection (DEP). We are deeply concerned about a concerted effort by a state agency and a single manufacturer to work in concert to spread false, misleading and out of date information in an effort to secure market share. It appears the DEP is interpreting EPA’s solicitation of comments to include not just the bifurcation of pellet heaters from cordwood heaters, but additionally the return to bifurcated standards amongst cordwood heaters. The letter sent to EPA contains outdated and misleading falsehoods and statements. Blaze King Industries, Inc. is 100% in opposition to the bifurcation of cordwood heaters based upon current data and sound reasoning. 

In reviewing comments filed by retailers in the NOPR regarding sell through, we recognized the names of dealers that submitted the form letter provided to them by the manufacturer mentioned previously. We contacted those dealers to inquire why they signed a form letter that contained false statements regarding catalytic wood stoves. The response we received each time was…”Didn’t even read it, we thought it was about getting a sell through.” 
Blaze King encourages EPA to make their decisions, as they have in the past, on science and data. Not the claims of two parties working in concert to benefit a single manufacturer. 
Masonry Heater Association
North America

Although the MHA has submitted numerous comments, data research, and proposals, the EPA has not moved forward to consider the implications of adding masonry heaters to the EPA Certified List of Products. 

By leaving masonry heaters out of the EPA Certified Products List, the EPA is drastically limiting clean burning heating choices for American consumers, which is against the EPA’s purpose.

The inclusion of masonry heaters in the NSPS would allow a cottage industry to grow into an industry that could encompass masonry contractors and hearth retailers throughout North America and promote the replacement of inefficient masonry fireplaces into safe, clean burning hearth systems. MHA research is “open source” and MHA intends to continue to share test data and assist state and federal agencies to promote clean burning options for customers who want the benefits of radiant heat and single batch burning appliances. 
Heat Master, 
Manitoba, Canada

We hope that the following improvements can be made to the regulations:
·       Eliminate Step 2 emissions until more data on cordwood testing using a widely accepted testing method can be collected to determine an effective, achievable level that reflects real world results as accurately as possible. 
·       Go back to the weighted average rather than individual run criteria in testing 
·       Use ISO Accredited 3rd party view to speed up the approval process for newly tested models 
·       Start categorizing pellet fuel appliances and cord wood appliances separately 


Yoder Outdoor Furnaces LLC
Floyd, VA
My biggest concern has been the complete lack of enforcement by the EPA. Any person willing to take an hour or two can find on the internet numerous smaller manufacturers advertising untested and unapproved models of wood stoves and hydronic heaters. This has been a huge hindrance to sales of approved Step 1 units (like our G series) as they are $ 1,500 to $ 3,000 higher than these cheap polluting models. Our sales post 2015 are about 50% of pre-2015 levels. HeatMaster is promoting that their dealers comply with the 2015 NSPS. Which we should, but it has come at a cost.I would guess that until enforcement actually happens no manufacturer can afford to invest heavily in testing as these cheap illegal models will not allow them to recoup costs. 
RLS Energy
Eaton Rapids, MI
Currently there is very little enforcement of the law. In my area I have heard of installs that to not comply. A commercial stove, legal at a business is not legal at a home. But no one checks. Any law without enforcement is nothing more than a request. Honest manufacturers and dealers will follow the law and the unscrupulous characters will cheat. I lose out when the cost of a compliant stove is above the cheater stove. If EPA wishes to regulate our products, they need to enforce it so that the good dealers and manufacturers who are acting 
in good faith don’t get punished. All we ask is for a level playing field.
Anonymous (retailer)

 In the last 3 years, I have lost approximately 50 sales to other manufacturers and dealers that have completely ignored the law and sell illegal appliances to customers. I support reducing emissions from wood burning appliances, but I feel as though the EPA needs to enforce their lawmaking if they are making laws. We are trying to follow the laws but feel as we are being punished for it by lack of enforcement on companies who aren’t. 


Northeast States for Coordinated Air Use Management (NESCAUM)
Boston , MA

NESCAUM opposes any changes to the emission standards promulgated under the 2015 NSPS. There is simply no need or basis to delay or weaken the standards in light of the large body of evidence demonstrating they are technically feasible and cost-effective. 

NESCAUM does not support any sub-categorization scheme under the NSPS and urges EPA to maintain the current single standards for all space heating devices and for all central heaters. Establishing different emissions standards based on control technology is contrary to the fundamental construct of the NSPS program, which embodies the notion that emissions standards are established according to the best system of emission reduction (BSER), rather than on specific control technologies. If EPA decides to sub-categorize, it must provide details as to the data used to deem the current BSER analysis deficient and complete new BSER analyses for each potential category to support sub-categorization. 
EPA must require that a different lab be used for audit testing than was used for certification testing to minimize biases associated with the pre-existing relationship between test facility and manufacturer. NESCAUM suggests that EPA consider using a single and independent federal lab, such as Brookhaven National Lab, for all compliance audit testing. 

NESCAUM recommends that EPA use the Integrated Duty-Cycle (IDC) approach as the platform for certification testing of all residential wood heating appliances in the future. This procedure is designed to be accurate, representative, repeatable and affordable. It incorporates emission measurements during typical operating situations, including start-up, reload, and transition across various heat output loads. The single-day test allows for replicate testing without increasing certification test costs. 

NESCAUM does not believe that the ASTM or CSA cordwood test methods for heaters, furnaces and boilers, as currently designed, effectively replicates real-world conditions nor do they provide solutions for precision and variability concerns. 

Existing information indicates that redesigning wood heating devices to comply with Step 2 emission standards has not generally resulted in increased retail prices. In fact, verified consumer cost data from state woodstove change-out programs show that on average, cordwood stoves with emission performance levels below the Step 2 standard of 2.0 grams per hour are priced somewhat less than those with certified emissions above 2.0 grams per hour. Many states in the Northeast provide incentives that further reduce the cost of purchasing and installing high efficiency, low emissions wood heating appliances. 
NESCAUM requests that EPA sunset EN303-5 as a qualified certification method for the NSPS as soon as possible, but no later than the May 2020 deadline in the rule. 

EPA should adopt a requirement, to take effect immediately, for the concurrent use of a tapered element oscillating microbalance (TEOM) test method to measure real-time particulate matter (PM) during certification testing. We recommend using the NESCAUM Standard Operating Procedures. 
National Association of Clean Air Agencies (NACAA)
Wash. DC

Compliance dates

EPA must undertake a review of the 2015 NSPS in 2023 and, based on its review, must revise the standards, if needed, to reflect improvements in methods for reducing emissions. EPA should reserve any review of or amendment to the level of or compliance dates for the 2015 NSPS until the statutorily required NSPS review, to begin in 2023. 

Transition to cordwood

NACAA does not, however, support any changes in this regard at this time. Rather, the agency should begin now to develop new test methods as described in these comments, above. With a rigorous schedule these methods could be completed and available for the statutorily required NSPS review in 2023. We urge that EPA work closely with state and local air agencies, as well as other stakeholders, throughout this test-method-development initiative. 

Also related to testing, EPA should adopt a requirement now, to take immediate effect, for the concurrent use of a tapered element oscillating microbalance (TEOM) test method to measure real-time particulate matter (PM), using the NESCAUM Standard Operating Procedures, along with standard filter measurements for all EPA residential wood heating device NSPS certification testing, including pre-burn activities.

Weighted Averages Versus Individual Burn Rates for Hydronic Heaters and Forced-Air Furnaces 

In the final 2015 NSPS Rule EPA did not include a weighted-average approach for HH and FAF Step 2 compliance and, instead, called for these devices to meet the standards at each individual burn rate to prevent large emission discharges. 

NACAA opposes the use of a weighted-average approach, which minimizes peak emissions, thereby presenting a less accurate reflection of in-field performance and would have the effect of weakening the Step 2 standards. The best system of emission reduction (BSER) analysis conducted by EPA for the 2015 NSPS Rule, and which underlies the Step 2 standards, did not include use of a weighted average. If EPA believes compliance should be determined with a weighted average instead of an individual burn rate the agency should conduct another BSER analysis to make this case and also demonstrate why its analysis for the 2015 NSPS Rule resulted in a different conclusion. 

EPA Compliance Audit Testing 

With respect to the selection of the lab to perform audit testing, one independent, third-party lab should be selected to conduct all compliance audit testing so that there is consistency across the program and that a lab that conducts certification testing is not permitted to conduct audit testing. 

With respect to variability in the compliance audit testing program, wood stoves that certify at less than 1 gram per hour (g/hr) should be allowed a variability of ± 1 g/hr. For units that certify at more than 1 g/hr, the current variability provision is adequate. 

ISO-Accredited Third-Party Review 

NACAA does not support allowing the EPA-approved lab that conducted the certification testing to also act as the third-party reviewer of the test results and recommends that EPA amend the 2015 NSPS Rule to prohibit this from occurring. 
California Air Resources Board
Sacramento, CA

Test methods

CARB supports the progress of the integrated duty-cycle test method being developed by Brookhaven National Laboratory and the Northeast States for Coordinated Air Management (NESCAUM).The proposed test methods address what is absent in the current test methods. 

The ANPRM’s requests for information with respect to the emission limit for wood heaters do not request the right information, are biased and outcome seeking towards collecting evidence for weakened standards and miss the opportunity to collect the data necessary to perform an accurate and complete economic and regulatory impact analysis. 

Step 2 Emission Limits

Asking “whether Step 2 is achievable at a reasonable cost” is not the correct framing of the question. The answer to this question seems predetermined, particularly for those who ostensibly have “been unable to design a wood heater to meet the Step 2 standard.”28 There is no information provided as to how to identify what is “reasonable,” nor is there any request for the necessary evidence to back up a claim that a cost is not “reasonable.” Leaving a regulated entity to decide what cost is “reasonable” will undoubtedly provide a biased and outcome-seeking response. 

Electronic Reporting Tool (ERT) 

CARB supports the use of modern electronic reporting tools for both the certification process and subsequent public use. Electronic submission will speed up the certification process, increase transparency, and give the public up-to-date information on certified devices and those waiting certification, as well as information on devices that been denied certification and why. U.S. EPA should insure that information in the database will remain available. Wood heating appliances are made to last decades and the public should be able to get information on any certified stove, no matter when the certification was achieved.
Warranty Requirements for Certified Appliances 

The requirement to offer a warranty on a new residential wood heater is particularly critical in low-income households. Due to financial constraints, low income households often buy the least expensive devices; if problems arise, they may not have resources to buy replacement parts, leading to unsafe and higher polluting operations. 
Minnesota Pollution Control Agency
St. Paul, MN

This notice requests comments on nearly every aspect of the standard: test methods being used or planned for use; the feasibility of meeting the promulgated compliance deadlines; the feasibility of the promulgated emission limits; revising averaging periods used to determine compliance with the standard; how testing companies are regulated; and how testing data is provided to EPA. 

Some of these concerns may merit evaluation, however, the MPCA believes that conducting this assessment prior to final implementation of the standard is premature. EPA is already required to re-evaluate the NSPS under Section 111(b)(1)(B) of the Clean Air Act (CAA)-the Act requires EPA to re- evaluate NSPS eight years after adoption. The MPCA believes that EPA should reserve any review of or amendment of the 2015 NSPS, and instead conduct its revisions or re-evaluations under its authorities of the statutorily-required NSPS review after the compliance deadline. 

Weighted averages vs individual burn rates 

EPA is soliciting comment on determining compliance with weighted averages instead of individual burn rates. A federally enforceable emissions standard is composed of an emissions limit, a method for measuring or determining emissions, and an averaging period. Similar to our comment about using a new emissions test method, revising the averaging aspect of the emissions essentially revises the standard. In order to consider a weighted average, EPA must evaluate all aspects of the standard- emission limits, averaging periods and the emissions testing method that the emission limit is based on. 


The record also highlights the several decades EPA and states have worked with the wood heating industry to develop clean, efficient heating products. To that end, the compliance deadline should come as no surprise to any party involved in developing, testing, or manufacturing the equipment. The contemplated changes are deeply impactful to public health; implementation of the standard should not be delayed. 

Missoula Public Health Department, 
Missoula, MT

When the EPA considers rule changes to the 2015 NSPS, the Board recommends the following: 

1. Maintain, at a minimum, the 2015 NSPS Step 2 emission limits for new residential hydronic heaters, forced-air furnaces and wood heaters. 
2. Keep the 2020 compliance date for the Step 2 emission limits for forced-air furnaces, hydronic heaters and wood heaters as specified in the 2015 NSPS. 
3. Cord wood testing methods should continue to be developed and provided as an option for emission testing since cord wood more closely mimics how consumers use wood heating devices. 
4. As more is learned about appropriate cord wood testing methods, a path for switching exclusively to cord wood testing for wood heating devices should be incorporated into the wood stove NSPS. 

Any delay or weakening of the 2015 NSPS would harm public health and make it harder for local jurisdictions to maintain or achieve the National Ambient Air QualityStandards for particulate matter in the air 


Advocacy Office, Small Business Administration
(This office does not necessarily reflect the position of the SBA or the Administration.)
Wash. DC

Because Advocacy is an independent office within the U.S. Small Business Administration (SBA), the views expressed by Advocacy do not necessarily reflect the position of the Administration or the SBA. 

Advocacy strongly supports the proposal to provide a “sell-through” for hydronic heaters and forced-air furnaces and strongly supports extending a similar provision to wood heaters. 
In addition, in response to the Advance Notice of Proposed Rulemaking, Advocacy recommends EPA consider the following measures to reduce the burdens on small businesses. 

·       Delay the step 2 compliance date by at least two years. Small businesses have lost the sales of their step 1-compliant appliances for the 2019-2020 winter, which has had the effect of forcing exit from the market and delaying R&D for step 2-complaince appliances. 
·       Review certification procedures to eliminate delays that do not contribute to environmental benefits. EPA should examine its records of step 2 certification to determine whether EPA pre-approval has prevented non-compliant appliances from coming to market. If the significant delays reported by industry are a result of incomplete submissions that have not required subsequent changes to the underlying appliance, then EPA should allow self-certification based on third-party testing. 
·      Reconsider treating all residential wood heaters as one product category. EPA regulates residential wood heaters fueled by wood pellets the same as those fueled by cord wood. While this is consistent with EPA’s stated desire to not show preference to any particular fuel in its air quality regulations, it may not be appropriate in a market where the vast majority of intended air quality benefits come from replacements rather than new installations. A customer seeking to replace a wood heater fueled by cord wood is discouraged from changing out if the available replacements are mostly fueled by pellets. 


Earthjustice, Environment and Human Health, Inc., Environmental Defense Fund, Environmental Law & Policy Center, and National Parks Conservation Association
Wash. DC

Weighted Averages 

EPA’s suggestion that the agency may revisit the possibility of using weighted averages instead of requiring compliance with emission standards at each burn rate for central heaters would needlessly reopen an issue that was thoroughly examined and resolved in the 2015 final rule. See 80 Fed. Reg. at 13,684, 13,690. In order to ensure that wood burning devices do not harm public health in any reasonably anticipated operating mode, EPA must require units to comply at each burn rate, not merely on a weighted average of the unit’s performance at each tested rate.
Fuel-Specific Standards 

EPA’s observation that more pellet stoves meet the Step 2 standards than crib or cord wood stoves does not support the adoption of weaker emission standards for crib or cord wood-fired heating devices. The fact remains that the Step 2 standards are achievable using crib or cord wood. Section 111 does not require EPA to establish standards of performance that can be met by all types of sources using all types of fuel. 

Integrity of the testing and certification process. 

EPA seeks comment on whether compliance audit testing “should be performed by the same lab that did the certification test for a given wood heater appliance.” 83 Fed. Reg. at 61,592. EPA does not suggest what advantages this approach might have, but it has at least two clear drawbacks. First, engaging different labs to conduct audit testing will likely help to reveal ambiguities in the application of EPA’s test methods to specific products, by increasing the opportunities for different personnel at different testing labs to apply the same test method provisions to the same model of wood burning equipment. 

American Lung Association
Wash. DC

The Step 2 Standards adopted in 2015 were more than two decades overdue, despite explicit requirements in the Clean Air Act that such standards must be updated every eight years. They already included an unusually long implementation period. Normally, new source performance standards must be met immediately by the affected industry, particularly when the technology needed to meet these standards exists and is in use today. The European System showed in 2010 that comparable units were possible and produced greater efficiency in wood use and heat production (MusilSchläffer et al., 2010). Furthermore, as EPA notes, more and more American manufacturers produce many product lines that already meet these standards. However, the 2015 standards afforded industry five years to meet the new requirements, far longer than other industries, such as the automobile industry, receive. 
Alliance for Green Heat
Takoma Park, MD

Cats vs. Non-cats

AGH believes it is premature to artificially protect the market for non-catalytic stoves by extending a sell-through to all classes of stoves, including pellet stoves. 

Insufficient cost data on Step 2 stoves 

While we are likely to see a small rise in the price of many stoves as a result of Step 2 compliance, there is a noticeable lack of data supporting such a conclusion. 

Insufficient data that consumers will hold off buying new stoves 

There is very little data about the proportion of consumers buying a wood or pellet stove for the first time, as compared to those who are replacing an older stove. And often families switch from wood to pellet stoves, or vice versa. First time stove buyers and those who will buy a stove anyway, may be far more numerous than those who would have bought a new stove if it were $ 100 cheaper. 

Minimal public support for sell-throughs 

In 2014, EPA received 1,750 Comments in response to proposals that set 2020 as the deadline for Step 2 compliance. Just 5 years later, the process led by the current administration’s EPA generated only 75 comments for the sell-through for furnaces and boilers, including comments from less than 10 individual citizens. In addition, there is no state, county or city that supports providing a sell-through for what constitutes the dirtiest appliance class among wood heaters. 
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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.

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Adventures in masonry stove testing from 1988 to 2017

by Norbert Senf, 
Chair of the Masonry Heater Association Technical Committee

Left to right: Mark Champion (in his 
VT test lab), Boris Kukolj (Tulikivi), 
Chris Prior (MHA President), Norbert 
Senf (blog author)  and Jean Francois 
Vachon (soapstone supplier). 
Photo credit: Mark Seymour.

EPA started regulating wood burning stoves for particulate (PM) emissions in 1988. Regulation was limited to airtight heating stoves. Masonry heaters were not regulated, the stated reason being that they were likely to be clean burning.

In Europe, only carbon monoxide (CO) emissions were regulated. CO is easy to measure, however PM can be very tricky. Wood smoke includes  compounds that will only be captured by a filter if you cool them down and condense them. This is done in the laboratory by mixing them with air in a dilution tunnel, and this is thought to simulate what happens in the ambient air in the real world.
State and county air quality authorities soon started to address wood smoke, and would often pass a generic local regulation that banned all appliances except those that were EPA certified. We, the fledgling Masonry Heater Association (MHA), decided to seek EPA certification.
Although we “knew” that masonry heaters were cleaner even than EPA stoves, nobody had ever measured the PM on one with the dilution tunnel method. With funding help from the Wood Heating Alliance (now HPBA), we were able to participate in a $ 100,000.00 test method development project for masonry fireplaces and masonry heaters. The project took place at Virginia Polytechnic Institute (VPI) in 1989 and was headed by Dr. Dennis Jaasma.
The results were interesting, with some surprises. EPA did not accept the proposed test method. We immediately realized that we needed do a lot more testing,  and that we would need to develop the capability to do it ourselves.
We were fortunate in being able to arrange for training with OMNI-Test, one of the leading EPA-accredited certification testing laboratories, then and now. OMNI developed a training session for us that took place in September 1996. It included presentations by regulators, an emission chemistry expert (Dr. Jim Houck),  and laboratory testing personnel. Dr. Stockton (Skip) Barnett showed us the low cost portable dilution tunnel that he invented, known as the Condar. He developed it while working for the Condar Company. It was widely used at the time by the major stove manufacturers for in-house testing to develop their certified  stoves.

The attached Powerpoint, Repeatability of Cordwood Combustion Particulate Measurements,  presents a summary of the work we have done at the Masonry Heater Association to calibrate the Condar against the EPA Method 5G laboratory dilution tunnel. It includes a close look at the PM testing repeatability issues,  a major discussion point over the years. We have recently completed 2 cordwood studies, using very carefully matched loads in a masonry heater. Repeatability was within plus or minus 15% – 25%, depending on the ignition method. With crib fueling, we were able to get within 10% repeatability on PM, and within 1.5% repeatability on CO.

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20 Stunning Wood Fired Hot Tubs from Around the World

Wood fired baths are an ancient tradition, dating back at least to Roman times when baths called hypocausts were built by running hot flue gases under a stone tub.  Those Roman tubs were also off the grid, as are these.  Some are quirky, some romantic, some practical and some just downright hedonistic.  Which is your favorite?
See our other photo essays: Wood Stoves from Around the World, and and Firewood Collection and Stacking from around the world. 

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20 Beautiful Wood Fired Hot Tubs from All around the Planet

Wood fired baths are an historic tradition, relationship again at minimum to Roman instances when baths known as hypocausts had been built by working sizzling flue gases below a stone tub. &nbspThose Roman tubs have been also off the grid, as are these. &nbspSome are quirky, some passionate, some sensible and some just downright hedonistic. &nbspWhich is your favored?
See our other picture essays: Wooden Stoves from Close to the Globe, and and Firewood Assortment and Stacking from about the entire world.&nbsp

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Last Report on Wood Stove Decathlon from Brookhaven Lab

Reproduced underneath are the absract and introduction of a seventeen-website page paper that provides an excellent overview of the specialized aspects of screening stoves on the Nationwide Mall for the Wood Stove Decathlon, held in November 2013. &nbspTo go through the whole report, click on listed here.

Progressive good particulate measurement systems for the Wood Stove Design Problem&nbsp
R. Trojanowski1, T. Butcher1, C. Brown1, G. Wei1, Y. Ahn2 , and J. Wong2&nbsp
one. Vitality Conversion Team, Brookhaven National Laboratory, Upton, New York, United states of america&nbsp
two. Chemical and Molecular Engineering Office, Stony Brook College, Stony Brook, New York, United states of america&nbsp
The increasing price of fossil assets has contributed to the enhance in the amount of wooden-fired household heating appliances. Wood stoves are typically neglected by the community as a cleanse and renewable source owing to worries about particulate (PM) emissions. In purchase to achieve acceptance in the market the Alliance for Eco-friendly Heat and
Popular Mechanics magazine initiated a Wooden Stove Style Challenge (WSDC). The selected groups created stoves that included the greatest methods in style and procedure to maximize performance and reduce PM and carbon monoxide (CO) emissions given that most frequently high emissions are noticed as a result of incomplete combustion. Additional, a screening protocol for the obstacle was produced exclusively to measure the emissions in a non-laboratory environment. Normal screening procedures may possibly not be agent of in-use fuel and operational techniques and, thanks to the opposition location and timetable contstraints, could not be utilised for the WSDC. New transportable PM sampling technology introduced in the European market place recently was adopted for the competitors and evaluated to present U.S. PM measurement approaches to construct a correlation.&nbsp

Tom Butcher makes use of the Wohler transportable
particulate sampler to test a stove.
&nbspAs the value of heating oil has improved, much more people in the northeastern location of the United States have returned to heating with wooden. Most present wooden stoves date from ahead of the Environmental Security Agency (EPA) carried out emission certification demands for these products. These much less effective wooden stoves often cause higher amounts of smoke, yielding particulates identified to set off coughs, throat and mucosal irritation, acute respiratory bacterial infections, occurrence of asthma and other conditions over extended exposure. A evaluation from Bølling et al. described residential wood combustion has also been reported to contribute substantially to raised stages of air air pollution regionally, each with respect to enhanced stages of fine particles (particulate make a difference with an equal aerodynamic diameter &lt 2.5 μm PM2.five), the natural and organic particle portion, particle sure polycyclic fragrant hydrocarbons (PAH) and volatile organic compounds. Even people wooden stoves that do meet up with EPA’s Section II requirements might have unacceptably large emissions once in use. This is thanks to many factors like the style of the equipment,&nbspweather designs and location, combustion exercise, wood species and good quality, and operator habits. Whilst the EPA is establishing new laws, the take a look at strategy used for certification is not representative of in-use fueling and operational procedures.&nbsp
Types that enhance combustion and emission functionality, thermal effectiveness, and operational &nbsp
The Decathlon tent on the Nationwide
Shopping mall, in between the Capitol and
the Washington monument

variability are required in the U.S. heating marketplace. Modern wooden stoves have revealed diminished described emission aspects in contrast to typical wooden stoves, 34-330 mg/MJ from 50-2100 mg/MJ, respectively. Nevertheless, if the modern stoves are not operated appropriately the combustion overall performance can be compromised yielding increased emissions.

This function showcased superior systems that could help tackle the dilemma of enhanced particulate emissions and empower the continued use of wood as a renewable gasoline. The groups chosen arrived from various backgrounds, ranging from set up wooden stove companies to independent inventors and engineering pupil groups. Some of the stoves chosen for the WSDC were controlled by microprocessors and connected to smartphones whilst other folks were extremely-successful stoves primarily based on seventeenth century Scandinavian styles. A number of condition-of-the-art hybrid stoves that are previously on the industry ended up also included4. 6 of the twelve finalists have been from Europe.&nbsp
Groups had been judged on their innovation, emission and effectiveness overall performance, affordability and buyer relieve. In November 2013 on the National Mall in Washington D.C., ten judges (produced up of top experts from Popular Mechanics, the New York State Energy and Research Advancement Authority (NYSERDA), the U.S. Forest Support, Washington Point out Section of Ecology, DOE’s Brookhaven National Laboratory (BNL), The Biomass Thermal Strength Council (BTEC), the Osprey Basis, the Masonry Heater Association and UC Berkeley) examined and assessed the 12 stove finalists and announced an all round winner as properly as winners in certain classes.&nbsp
A essential challenge in this opposition was measuring the particulate emissions accurately in a discipline atmosphere. This task sought to create an energy effectiveness and emissions testing protocol for the WSDC which decreases the variability due to gas and functions. The present normal examination strategy (EPA Strategy 28) entails testing stoves utilizing a dilution tunnel. Given that the WSDC was held&nbspat the mall in Washington D.C., this take a look at strategy would not suit and so there was the&nbspchallenge of measuring the emissions in a repeatable actual-time way, in a non-laboratory atmosphere. Just lately, new moveable particulate measurement programs have been launched in Europe for area inspection of biomass heating systems. Two particular products were chosen for use in this project the Testo 380 and Wöhler SM 500. Equally analyzers are a low price selection and supply the advantage of relieve and portability.&nbsp
To establish the precision, precision, instrument variety, and applicability for use in the WSDC for thermal performance and emissions of these transportable immediate evaluate analyzers, an analysis was executed even though at the same time adhering to the regular methods for deciding the emissions. &nbspFrom laboratory screening, BNL created a screening protocol implementing the analyzers for the competition.

To go through the entire PDF report, click right here.

For far more information about the 2013 Decathlon, click here.

For details about the 2014 Collaborative Stove Design Workshop, click here.

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Summary of NSPS Remarks from the Alliance for Environmentally friendly Warmth

The Alliance for Inexperienced Warmth is sharing its draft summary responses with all stakeholders to advertise transparency and dialogue and to solicit input on how we can enhance our feedback. &nbspWe also urge stakeholders to consider incorporating the points that you concur with, into your feedback. &nbspPlease truly feel cost-free to leave input or suggestions for the Alliance on this site or if you want them to continue to be personal, ship to john@forgreenheat.org. &nbspComments have to be despatched to the EPA by Monday, Might five.

-draft –

Alliance for Environmentally friendly Warmth

Responses on
EPA’s Proposed Requirements of Overall performance for New Household Wood Heaters, New Household Hydronic Heaters and Pressured-Air Furnaces, and New Residential Masonry Heaters
Docket ID No. EPA-HQ-OAR-2009-0734
April 30, 2014&nbsp


The Alliance for Inexperienced Heat (Alliance), appreciates the possibility to remark on EPA’s proposed New Source Efficiency Standards (NSPS) for wooden heating devices.[1] &nbspThe Alliance is an unbiased non-income business that operates with environmental and forestry corporations, air quality experts, the wood and pellet stove market, and other individuals in the wood burning community to market substantial-efficiency wood combustion as a low-carbon, sustainable, nearby and cost-effective heating resolution.&nbsp The Clear Air Act demands EPA to overview and revise, if suitable, the NSPS at least every 8 several years.&nbsp The Alliance strongly supports EPA’s decision to update the standards for wooden stoves and to require a number of formerly unregulated wood heating devices to reduce their emissions.&nbsp We also imagine that the new requirements, which replicate important advancements in wood heating technological innovation, are the two acceptable and extended-overdue.&nbsp

We have numerous suggestions for bettering the proposed NSPS, which we outline below.
In our responses on the NSPS, we make the pursuing points:
&nbsp &nbsp &nbspVery first, it is important to understand that wood heating is renewable heating and should be acknowledged as this kind of by EPA.

·&nbsp&nbsp&nbsp&nbsp&nbsp 2nd, the Alliance strongly supports EPA’s decision to problem revised overall performance requirements for wooden stoves and other wood and pellet heating appliances.
o&nbsp&nbsp The Alliance supports EPA’s determination to shut existing loopholes and to include all main types of wooden-fired heating gadgets in the new performance expectations. &nbspBeforehand exempted gadgets and units earlier mentioned Action One particular emission restrictions should not be “grandfathered.”&nbsp&nbsp
o&nbsp&nbsp The Alliance supports a nine-month promote by way of for qualified stoves that emit greater than Step 1 emission expectations and a two-calendar year market by means of for boilers or furnaces that are EN303-5 accredited or EPA competent.
o&nbsp&nbsp In the following NSPS, the Alliance urges the EPA to control uncertified, pre-1988 stoves as new resources if they are installed in a new spot.&nbsp Performing so will help to hasten the removal of the oldest, most polluting stoves from our airsheds.
o&nbsp&nbsp In the up coming NSPS, the Alliance also urges EPA to control fireplaces.

·&nbsp&nbsp&nbsp&nbsp&nbsp 3rd, the Alliance thinks that the proposed emission limitations, however affordable, could be more stringent for specific gadgets:
o&nbsp&nbsp Data from at the moment licensed stoves look to justify a a lot more technologies-forcing, lower Action 1 performance normal for wooden stoves.
o&nbsp&nbsp Pellet stoves are plainly able of conference a lower restrict for Stage One particular.&nbsp The bulk of pellet stoves accredited by EPA are currently emitting much less than 2.five grams for each hour (g/hr).
o&nbsp&nbsp Forced air furnaces could attain a Step 1 emission restrict of .forty eight pounds per million BTUs (lbs/MMBTU), as an alternative of the proposed .93 lbs/MMBTU. A .forty eight common corresponds to the lbs ./MMBTU of a typical Washington accredited wooden stove.
o&nbsp&nbsp In addition, despite the fact that we feel a .06 lbs/MMBTU Step Two standard for pellet boilers is justifiable, this limit may not be appropriate for wire wooden boilers, based on the take a look at technique.&nbsp &nbsp

·&nbsp&nbsp&nbsp&nbsp&nbsp Fourth, the Alliance strongly supports a shorter, 5-12 months implementation period of time for the NSPS. &nbspThis deadline is the two achievable and reasonable given the state of wooden heating technology these days.

·&nbsp&nbsp&nbsp&nbsp&nbsp Fifth, the Alliance believes that credible testing and enforcement are important parts of any New Resource Functionality Standard below the Clean Air Act (CAA).
o&nbsp&nbsp The Alliance supports the proposed changeover to wire wooden screening, and phone calls on EPA to increase its cord wood tests software to get further information on the overall performance of present wooden stove versions making use of cord wooden prior to promulgation of the ultimate rule.&nbsp Alternatively, we urge the EPA to dedicate to re-analyzing the achievability of the Phase Two standards for stoves that have to be accredited on wire wood just before people requirements turn into successful.
o&nbsp&nbsp The Alliance urges EPA to create a clearer route to certification for sophisticated systems like automatic stoves.&nbsp The Alliance is also inspired by ClearStak’s responses and urges EPA to consider some of the ahead-contemplating ideas put forth in those comments.
o&nbsp&nbsp The Alliance supports EPA’s proposal to delegate some oversight and enforcement authority to the states, and urges EPA to increase the capacity of the Business office of Enforcement and Compliance Assurance (OECA) to aid make sure that point out enforcement packages are successful and that companies and merchants comply with the NSPS.

·&nbsp&nbsp&nbsp&nbsp&nbsp Sixth and last but not least, the Alliance believes that mandatory effectiveness expectations are needed. Better performance is specifically import to minimal-income wooden stove customers since it can decrease their heating expenses by demanding less fuel to warmth their houses.&nbsp Even so, the Alliance supports EPA’s decision to get much more data on wood stove effectiveness, with the knowing that future NSPS would set obligatory effectiveness standards.
o&nbsp&nbsp The Alliance strongly supports a necessity to put up B415.one HHV effectiveness quantities on all wooden heating appliances on the marketplace inside of six months of the rule’s promulgation.&nbsp Versions that are EN 303-5 certified or certified by an EPA voluntary plan must be permitted to use HHV quantities till they turn into EPA accredited.
o&nbsp&nbsp The Alliance opposes the elimination of the hangtag prerequisite and urges EPA to take into account extra consumer details resources this sort of as a Inexperienced Label and state incentives for shifting out old stoves and putting in the most effective new stoves.
o&nbsp&nbsp The Alliance agrees that the two particulate subject (PM) and carbon monoxide (CO) emissions information, as properly as efficiency information, need to not be considered Confidential Business Info (CBI), and urges EPA to make emissions and effectiveness data about all four burn rates community on its site.
o&nbsp&nbsp The Alliance urges EPA to right away start requiring producers and labs to scan and electronically post all paper info submissions, even as the company works to build a much more streamlined Electronic Reporting Tool (ERT).&nbsp
o&nbsp&nbsp Lastly, to stay away from deceptive shoppers further, EPA need to also remove the “default” emission element column from its posted listing of certified wooden stoves, and demand producers and merchants to stop employing these default factors in their promoting materials.

We appreciate your interest to our responses and appear ahead to operating with EPA to efficiently employ this crucial rule.&nbsp The full text of our comments is under.

[1]Standards of Efficiency for New Residential Wood Heaters, New Residential Hydronic Heaters and Compelled-Air Furnaces, and New Residential Masonry Heaters, seventy nine Fed. Reg. 6,329 (Feb. 3, 2014) [hereinafter “Proposed Rule”].

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EPA Lists Efficiencies of Qualified Out of doors Boilers from 39% to seventy eight%

On April 8, the EPA&nbspposted efficiencies for outside wooden and pellet boilers, also acknowledged as hydronic

heaters.&nbsp Efficiencies ranged from 39% to 78% as measured utilizing greater heating value.

The common certified outside wood boiler is sixty three% efficient and the typical pellet boilers is 70%.&nbsp However, of the 39 units qualified under the EPA’s voluntary program, efficiencies have been only shown for 20 models.&nbsp Nineteen of the models do not have efficiency figures offered due to the fact they ended up analyzed utilizing EPA’s earlier Strategy, which resulted in excessively high efficiency quantities.
The maximum effectiveness boiler in the EPA’s experienced system is Central Boiler’s E-Vintage 1450 at seventy eight% HHV.&nbsp The most affordable is Marway Welding’s Stage two – two hundred at 39%.&nbsp An additional boiler has 47% performance, which demonstrates how boilers can qualify for the EPA’s voluntary program emission standards without having substantial thermal efficiency.&nbsp Thermal efficiency measures heat transfer from the combustion chamber to the h2o that heats the property.
The putting up of these efficiency figures was welcomed by the Alliance for Eco-friendly Warmth who has extended advocated for shoppers getting entry to reliable efficiency data.&nbsp The listing of dependable efficiencies helps make hydronic heaters the first class of wooden heating appliances to give efficiencies to the standard public.&nbsp It may possibly just take many years for the general public to get reliable efficiencies on most wood and pellet stoves, as most manufacturers have been unwilling to share that information with the public right up until it is necessary by legislation to do so. &nbspTo day, only nine stove companies have provided 3rd party effectiveness quantities for the EPA to publicly post.&nbsp&nbsp
These boiler efficiencies display that most boilers are not increased in effectiveness than top carrying out wooden stoves.&nbsp They reveal that there is even a wider range in boiler effectiveness than wooden stoves, such as several that are quite low efficiency units.&nbsp
The saga to give customers with such knowledge has taken numerous twists and turns.&nbsp In 2011, the EPA removed efficiency figures that ended up in the ninety% range following condition regulators questioned their precision.&nbsp Scott Nichols, who sells European indoor boilers that are not part of the EPA voluntary program, is a single of handful of to create about these problems that have faced EPA and the boiler sector.&nbsp
The EPA asked for outdoor boiler makers to stop employing the discredited large efficiency quantities in their marketing, but few stopped utilizing them, major to a letter from the EPA in 2013, which strongly urged manufacturers to cease employing the performance figures.&nbsp The Alliance for Environmentally friendly Heat documented on that growth and documented several instances the place out of doors boiler companies have been participating in other misleading promoting practices.&nbsp

The EPA again sent a letter to certified boiler makers on January 31, 2014 simply because “misleading data has appeared on many spouse manufactures and retailer websites.”&nbsp This data provided language such as EPA “certified” or “approved” boilers and promises that their boilers were up to 90% productive.

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