Wood stove industry faces unified opposition to deregulation

A 2018 portrait of the Western
Governors Association who
oppose delays in the NSPS timeline.
Amid the scores of comments filed in response to the EPA’s proposal to weaken Obama-era wood stove and boiler regulations, not a single state came out in support of the Trump Administration’s proposals.  
Attorney Generals from eleven states (CT, IL, MA, MD, MN, NJ, OR, NY, RI, VT & WA) filed detailed comments and are likely prepared to sue if the EPA tries to weaken the existing regulations.  Even Alaska and the Western Governors Association is backing the Obama-era timeline. A more troubling sign for the wood stove and boiler industry is an energized, engaged and knowledgeable array of states, air agencies and non-profit organizations that have lined up to oppose virtually all the changes that the stove and boiler industry is seeking from the Administration.

“We are seeing a polarization of stakeholders who once used to make alliances and find common ground,” said John Ackerly, President of the Alliance for Green Heat, an independent non-profit that promotes cleaner and more efficient wood and pellet heating. “The Trump Administration efforts has energized states and unified them across a range of issues, from compliance deadlines, to test methods, to regulation of wood pellet composition, to warranties and audits for stoves,” Ackerly said.

Key excerpts of stakeholder comments which this analysis is based on can be found here for those who don’t want to download and read through hundreds of pages of comments.

John Ackerly, head of the Alliance
for Green Heat.  Photo courtesy of
Popular Mechanics magazine.
Trump Administration proposes a delay
The biggest issue on the table is whether the EPA will extend a deadline and allow retailers to sell dirtier wood boilers and furnaces – and possibly wood stoves – until 2022 instead of 2020. The EPA has indicated an interest to provide this relief to wood boiler and furnace manufacturers and retailers, but time is running is out and the agency has been moving slowly on this issue.  It’s also unclear if states would be able to get an injunction to prevent such a move while it was being litigated.  
Scores of comments submitted to the EPA depict an industry that has few friends standing up for it outside its own network of manufacturers and retailers.  Attorney generals from three states with Republican governors – Maryland, Massachusetts and Vermont – sided with democratic-led states in opposing any delay in stricter emission standards taking effect.  
Among industry, there is widespread unity to allow retailers two more years to sell Step 1 boilers, furnaces – and stoves – that are set to go off the market in May 2020, although a handful of small manufacturers and importers support the existing timeline.  
While manufacturers argue forcefully that they need a two-year sell-through, they are also having to assure their retailers that they will have 2020 compliant products.  For example, in comments submitted to the EPA, Jotul says it faces dire economic consequences with $ 2.5 million in raw cast iron at stake if a 2-year sell-through is not granted.  But in an industry magazine read by retailers, Jotul says they are doing “very well” certifying their 2020 models and expect to release their new 2020 models later this year.  Based on the EPA’s list of certified wood stoves, it appears that Jotul is one of the manufacturers who is far behind schedule, as they do not yet have a single 2020 compliant stove on the list.  Industry sources have said that the list of EPA certified stoves far underestimates the preparedness of many manufacturers who may be waiting to submit test data for 2020 compliant stoves until they are closer to the required date.

Richard Corey, CEO of
California’s Air Resources

While northeast and northwest states have been the principal state actors, California is making a big investment in challenging the EPA’s deregulatory proposals.  They filed extensive comments to both the Proposed Rule Making (PRM) and the Advance Notice of Proposed Rule Making (ANPRM).  They and many of other states challenge the legality of the EPA’s approach, setting the scene for what is likely to be a legal battle.  They argue:

“The [EPA’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.  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.”

Letita James, the Attorney
General of New York, is the
lead among eleven attorney
generals opposing a sell-
through and other changes.
Perhaps the most detailed argument for a two-year sell-through came from North East Distributors, one of the largest distributors of stoves made by many manufacturers.  They say that they “are in favor of manufacturers having to meet the May 15, 2020 deadline for stopping production of non-2020 compliant models” but against “holding distributors and retailers to the same May 15, 2020 deadline for sales of already manufactured products. Having the one date for all entities (manufacturers, distributors, and retailers) inhibits the results you are trying to accomplish.” 

A push to deregulate outdoor wood boilers

The main regulatory focus has been on a sell-through for outdoor wood boilers, also known as hydronic heaters, and inexpensive indoor wood furnaces.  Leaders of those companies have been testifying to Congress and lobbying the administration. 
For central heaters like boilers and furnaces, the main industry association, the Hearth, Patio and Barbecue Association (HPBA) is calling on the EPA to “repeal those standards altogether.”  Strengthening emission standards for wood boilers and furnaces was one of the largest goals of the 2015 New Source Performance Standards (NSPS), and this call to deregulate that industry altogether represents a new front in the widening gulf between industry, states and air quality agencies.  
HPBA’s John Crouch, an
architect and mediator of
HPBA policies.
US Stove, the dominant manufacturer of indoor wood furnaces is also calling on the EPA to repeal emission standards for furnaces because the “economic feasibility of meeting the standards is impractical” and the emission levels are “preposterous and unrealistic.”  However, a far smaller competitor, Lamppa Manufacturing already has a furnace that meets the 2020 standards.
When it comes to outdoor wood boilers, fringe voices are not uncommon. There is a group of retailers and consumers supporting the “Hawken Proposal”, which calls for getting rid of federal emission standards for outdoor boilers altogether and letting states and municipalities voluntarily adopt standards.  The proposal is being led by Hawken Energy, a Missouri based company that believes the federal government should not interfere with how people heat their homes. 
In contrast, Central Boiler took a more moderate position and refrained from calling on the EPA to repeal Step 1 and/or Step 2 standards, instead asking the agency to “revisit the cost effectiveness and feasibility of the Step 2 emission limit.”
Lack of enforcement undermines certified boilers

Warren Walborn, CEO of Hawken
Energy with Rep. Bill Huizenga (R-MI).

An important concern among the outdoor wood boiler community is that the EPA has no enforcement capability to rein in the many manufacturers of unregulated outdoor boilers.  Yoder Outdoor Furnace, a HeatMaster retailer in Virginia said, “until [EPA] enforcement actually happens no manufacturer can afford to invest heavily in testing as these cheap illegal models will not allow them to recoup costs.”  That sentiment was echoed in many comments from industry, and it would seem to be an issue of concern to states and air quality agencies as well.  However, states and air quality agencies did not mention this problem in their comments.  
By opening the door to changes in the compliance timeline for stricter emission standards, the EPA may have built far more momentum for a new NSPS process in 2023.  The NSPS is supposed to be reviewed every eight years, and states and groups are likely to sue again to keep the EPA to that timeline.  Virtually all the states and air quality agencies engaged in fighting EPA’s proposed changes are now calling for far-reaching changes in the 2023 NSPS. If a democrat is in the White House in 2023, this momentum may result in even stricter emission limits and test method changes.  A group of eleven Attorney Generals said the 2020 emission standards are already “too lax.” If President Trump is re-elected, industry is likely to keep the upper hand and consolidate its goals, barring defeats in court.
Lisa Rector, a leader at
NESCAUM on wood
smoke reduction.

In addition to seeking input on granting a two-year sell-through for retailers for boilers and furnaces, and possible stoves, the EPA identified a half a dozen other issues for which it wanted feedback, from cordwood test methods to compliance testing.
The transition to cord wood testing

One area on which industry, states, air quality agencies and other groups all agree is the need to move toward testing and certification that more closely represents in-field operating conditions and performance.  This means testing and certifying stoves with cordwood, instead of crib wood (2x4s and 4x4s), capturing start-up emissions and potentially making even more structural changes to how stoves are tested.  The agreement may end there, however, as states and air quality agencies have now coalesced behind a test protocol being developed by Northeast States for Coordinated Airshed Management (NESCAUM) and the New York State Energy and Research Development Authority (NYSERDA), called the Integrated Duty Cycle (IDC) method.  Industry is firmly behind the ASTM E3053 method that they developed through a consensus-based process from 2015 to 2018. 

VP Berger, one of Hearth &
Home Technologies senior
leaders on NSPS issues.
Neither side is proposing a rapid change to mandatory cord wood testing.  States and air quality agencies are looking to the next NSPS in 2023 to consolidate their positions and interests.  The State of Oregon, home to most of the test labs and the very first certification testing in the mid 1980s, submitted comments that were particularly critical of ASTM methods.  
Hearth & Home Technologies (HHT), whose comments were often more moderate than some of their peers, said, “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.” 
States want labs to start using TEOMs immediately
While states and air quality agencies say that they do not want to change the existing NSPS and believe that any changes to testing and emission standards should be taken up in the 2023 NSPS.  However, they are calling on EPA to “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.”  Such a requirement would seem to involve a change to the current NSPS, unless it were a voluntary measure that labs could undertake as part of a research effort outside of it.
Third-party certification of stoves 

Once stoves or boilers are tested by third party labs, those labs currently send the test reports to the EPA for review and then the EPA issues the certification allowing the manufacturer to make and sell the appliance.  
Industry urged the EPA to ask for comments about a change in this process, whereby the lab would test the appliance and grant the certification, bypassing review by the EPA. Industry points to delays and backlogs at the EPA enforcement office, which takes up to 90 days to grant certificates once the lab provides the necessary documentation.  
 EPA officials, including Amanda
Aldridge and Rochelle Boyd, listen
to testimony on Dec. 17, 2018
on proposals to revise the NSPS.
Again, states and air quality agencies have lined up to oppose this proposal, arguing that the same lab that is paid by the manufacturer to test the stove should not be paid by the manufacturer to issue the certification.  With cutbacks to EPA funding, it does not appear likely that the EPA would hire additional people to help streamline the certification process and at the same time provide other oversight and enforcement of the NSPS, such as cracking down on manufacturers of uncertified outdoor wood boilers. 
Compliance audit testing

Another topic on which the EPA solicited comments is how and when stoves could be retested and audited for emissions compliance.  Auditing the accuracy of the lab that did certification testing of a pellet stove is far easier, as the variability of emissions in pellet stoves is not nearly as great as in wood stoves.  Industry, led by HPBA and Central Boiler, took the position that an audit test should only happen “where there is suspected fraud in certification test results” not random spot checks.  HPBA took an even stronger position, saying that EPA should “prohibit audit testing for appliance categories until there has been a determination on variability for the applicable test.”
Blaze King’s Chris Neufeld, an
ardent promoter of catalytic stoves.
Others in industry, such as Hearth & Home Technologies, took the position that if a stove is to be audited, it should be done by the same lab that tested it initially or another lab chosen by the manufacturer.  
States and air quality agencies are taking a uniform position that “only an 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.” NESCAUM proposed that Brookhaven National Lab be designed as the independent lab.
Warranty requirements
Currently, the NSPS has warranty requirements for catalytic stoves, but not for non-catalytic stoves.  The industry position is that the NSPS should not have any warranty requirements. Hearth & Home Technologies commented that “all manufacturers already have warranty language… [and] whether the EPA required it or not, it is standard warranty language for an appliance.”
This topic drew less attention from states and air agencies, but most supported the retention of warranty language for cat stoves and the addition of warranty requirements for non-cats, “particularly ones for key components related to controlling emissions from the device (including, among others, tubes).”  Blaze King, a vocal leader on this issue, agreed that if any type of stove is required to provide warranty language, then all stoves should have that requirement.   
Steve Muzzy, head of Central Boiler.

Different emission standards for pellet and cordwood appliances
Some industry players see a solution to emission standards by holding pellet appliances, and possibly also catalytic appliances, to a stricter standard.  Central Boiler charged that the EPA was “negligent” to hold stick wood and pellet appliances to the same emission standard.
HPBA and industry leader Hearth & Home Technologies are not calling for a bifurcation of emission standards based on fuel type or whether a stove has a catalyst.  The first NSPS in 1990 originally set a 7.5 gram an hour standard for non-cat stoves and a 4.1 standard for catalytic stoves.  States and air agencies also do not support setting separate emission levels based on fuel or inclusion of a catalyst.  Tim Ballo, an Earth Justice attorney, commented, “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.”
Bret Watson says Jotul is
doing “very well” in
certifying their 2020 models.
In an exasperated and testy comment, Blaze King accused Jotul of working with the State of Maine to “spread false, misleading and out of date information in an effort to secure market share.”  Jotul has been a strong advocate for non-catalytic stoves and was instrumental in distributing a form letter to retailers to submit to the EPA that severely criticized catalytic technologies.  An unspoken rule in the stove industry is never to criticize another manufacturer by name, but the Blaze King feud with Jotul has only become more intense as the NSPS revision process increased the stakes of the game.  It should be noted that in Jotul’s official comments to the EPA, they did not call for a bifurcation of emission standards. 
A renewable, low carbon energy source
The role of wood and pellets as a renewable, low carbon fuel is virtually lost by the EPA, industry, states and air agencies.  Technically, the renewability of wood plays no legal role in setting emission regulations or other EPA policies governing wood and pellet heating.  However, many industry comments referred to the important role that wood heating plays in the lives of rural, lower income households, allowing them an affordable alternative to fossil fuel heating.  While it didn’t appear in their comments, many of the states urging the EPA to maintain cleaner emission standards are also providing incentives for more deployment of wood and pellet heaters.  New York, Vermont, Massachusetts, Maryland and others all have programs aimed at strengthening modern wood heating.  The Alliance for Green Heat was founded to promote the role of biomass as a low carbon fuel source and has tried to gain industry support for innovation leading to the automation of wood stoves.  But for now, the sides have been drawn on this issue based mostly on affordability vs. cleanliness, not on carbon.

What comes next?
The EPA has said that it may make a decision on whether to grant wood boilers and furnaces a two-year sell through in the spring of 2019.  As for all the other issues, including a two-year sell-through for stoves, they have only issued an advance notice and still have to decide if they will issue a formal proposal.  That proposal would also be followed by a public comment period and it is difficult to imagine a scenario that the EPA could announce any “relief” for manufacturers before winter of 2019/2020.
Bill Wehrum, in charge of weakening
air pollution rules at the EPA for the
Trump Administration, has little time
to deliver on wood heaters.
Industry came close to securing a more robust compliance extension from Congress in 2018 but fell short in the Senate.  With Democrats now in charge of the House, Congressional support for weaker or delayed emission standards is not an option in 2019 or 2020.

Clearly, the attempt to dilute the NSPS by the Trump Administration has coalesced and unified states and air agencies behind positions developed by NESCAUM and others.  They are looking to 2023 to regain the ascendancy that they lost under Administrator Pruitt and Wheeler’s leadership at the EPA.  If democrats take the White House in 2022, rewriting the NSPS starting in 2023 could be a possibility.  But a democratic White House and EPA would, in turn, energize Republican governors who seem to have been complacent during this comment process.  Under Republican Governor LePage, Maine was the one state that was emerging as a vocal supporter of the EPA’s deregulation of wood appliances, but during the comment process, a Democratic Governor was elected.  

At this point, time is critical as May 2020 approaches. It appears that the issue was not important enough for the EPA to put on a faster track and members of Congress supporting the hearth industry were not able to change that.  With a little more than a year to go, the question is – is it too late anyway?

Heated Up!

Despite claims of “devastating” impact, wood stove industry positioned to meet new emission standards

With the Step 2 deadline for wood and pellet stoves just a year away, most stove manufacturers say they are ready or will be soon. Many retailers also say they are ready, while others prepare to deeply discount stoves that can’t be sold after May 2020. Gone are the days when industry was trying to convince Congress and the Administration that EPA’s new stove regulations would have a “devastating” impact. Such claims are common in Washington, as groups try to rally their base, but it can also lead to a diminished credibility for an industry association if the hyperbole goes too far.
From the start, it was clear that the boiler and furnace manufacturers needed relief far more than stove companies and retailers.  Heads of outdoor boiler companies and indoor wood boilers that cost less than the average wood stove were leaders of a campaign to get Congress to give all classes of heaters a three-year delay in meeting the new standards.  At the same time, the industry association Hearth, Patio & Barbecue Association (HPBA) was challenging many of these standards in court, meaning a three-year delay could be permanent for some classes of heaters, if courts agreed with HPBA.  But it was never clear that stoves needed any delay and industry effort would have stalled innovation and efficiency improvements and put tens of thousands of families at higher risk of more wood smoke exposure.  The fallback position was that industry needed a two-year sell year, allowing manufacturers to sell Step 1 product during the fall and spring of 2019/2020, and retailers to sell Step 1 product until May 2022.  

At first, it appeared that the EPA under the current Administration was open to providing a two year  sell-through for stoves, but they have only issued a Notice of Proposed Rulemaking (NPRM) for boilers and furnaces, not for stoves.  Theoretically, the EPA could still issue a Notice of Proposed Rulemaking for a sell through for stoves but at this point it may be too late to provide any meaningful relief.
Many states pushed back strongly against watering down the NSPS and no state filed comments backing the Trump Administration’s proposals.  States also began preparing their own plans in the event the EPA does change NSPS timelines, which could create a patchwork of regulations and more antagonistic relationships with a renewable energy industry.

If some manufacturers were not taking the 2020 deadline sufficiently seriously from 2016 – 2018, they are all likely to be doing so now.  Instead of focusing on government relief, HPBA’s outreach to industry stakeholders is taking an a more urgent tone that everyone needs to focus on heeding the May 2020 deadline. However, almost all manufacturers were already focused on May 2020 for their own financial health and to assure their retailers that they are a reliable future partner.  And, many manufacturers and virtually all retailers already are well-diversified with gas fireplaces and stoves which often outsell their wood and pellet appliances.

The list of stove manufacturers who are ready for 2020, almost are or “well-positioned” to be 2020 ready grows by the week. As of May 1, they include:  APR Industries, Blaze King, Even Temp, ExtraFlame, Foyers, Heat Tech, Hearthstone, Innovative Hearth Products, Jotul, Kuma, Laminoux, MF Fire, Napoleon, Pacific Energy, Rais, Regency, Roby, RSF Fireplaces, SBI, Stuv, Supreme, Thelin, Travis and Woodstock Soapstone.  Hearth & Home Technologies, by far the largest manufacturer, says a majority of its stoves will be 2020 certified this year.
The 2020 deadline will undoubtedly be tough for much of the industry, but it remains to be seen if it’s tougher than lean shipment years such as 2007 and 2012.  Overall, the threat to industry does not appear to be as serious as industry claimed even a year ago.  The 2020 deadline is also bringing about benefits. some foreseen and others not. Some retailers still have stocks of Step 1 stoves and there is likely to be some heavily discounted stoves in the final year leading up to the deadline.  Retailers are still ordering some Step 1 stoves, but in much smaller quantities.  Many retailers are only buying Step 2 stoves but may face still competition from fire sales of Step 1 stoves by competitors.  Sending Step 1 stoves to Canada could have been a good outlet, but the more populous Canadian provinces have either adopted the 2020 deadline or are in the process of doing so. Other foreign countries are still a good option.  Most big box stores have the buying power to protect themselves by requiring manufacturers to buy back unsold inventory, influence that specialty hearth retailers don’t have. 

Over the last six months, HPBA has developed more clear and insistent messaging for retailers and is using social media more to get the message across.  A facebook post outlined 5 things retailers need to know to survive the NSPS. Included is also a fear that in the race to meet the 2 gram an hour standard, some manufacturers may be putting out stoves that haven’t been sufficiently beta-tested and simply won’t work well in the real world.  This could jeopardize retailers who unknowingly carry those stoves.  HBPA urged retailers to test the stoves themselves, before selling them to customers, a tall order for retailers over the summer season.  The message for consumers is that the next twelve months will be a buyers’ market with unprecedented sales and discounts of Step 1 products
For the most part, the hyperbole from industry that consumers would be priced out of new stoves and there would be very little variety of product on floors, is not materializing.  Some manufacturers that were well known for disparaging catalytic stoves are now embracing them, swelling the ranks of “hybrid” stoves that only mention the catalyst in the fine-print. Presumably, this new crop of hybrids learned the tough lessons of the 80s and 90s, and their catalyst are well protected from flame impingement.

The 2020 deadline is also providing industry a gradual transition to cordwood testing, as some manufacturers opt to test with it.  Some groups idealistically hoped for a far quicker transition to cordwood.  Stoves tested with cordwood can emit up to 2.5 grams an hour, although many of them are coming in under 2 grams.  Despite messaging in advertisements from HPBA that it “shares the same goals as regulators,” the 2.5 gram an hour standard for cordwood is one of the many emission standards that HPBA is challenging in federal court.  The many delays to the lawsuit may make it tougher for HPBA if enough stove models come in under 2.5 grams an hour using the broadly applicable alternative ASTM cordwood test method.
Many stakeholders are already looking past the 2020 deadlines toward the next NSPS, which by law should be scheduled in 2023.  Whenever the 2015 NSPS is superseded, there is likely to be intense controversies over certification protocols for cordwood testing and a timeline for all stoves to be tested with cordwood.  Key northeastern states believe the consensus driven ASTM Method is deeply flawed and are working behind the scenes on new test methods.

Unlike the 1988 wood heater NSPS that decimated the ranks of small stove manufacturers, the 2015 NSPS does not appear to be forcing manufacturers out of business. The 1988 regulations drastically improved the functioning, safety, cleanliness and efficiency of stoves while also driving up prices of those that were not claimed to be exempt.  The question remains whether the 2015 NSPS will significantly improve the functionality of stoves as they become cleaner and more efficient in the lab. Pellet stoves may the winners as their lab numbers should hold up in homes of consumers, a significant benefit that is rarely acknowledged by most in industry.  We can all agree that there will be both intended and unintended consequences which will take years to unfold.  Stay tuned.


Heated Up!

Opinions of top wood stove industry insiders revealed in 1998 interviews

The late Paul Tiegs, one of the
greatest authorities on wood
stoves, conducted the
interviews for the EPA. 
Long before the regulatory debate about wood stoves heated up in the 2010s, the EPA commissioned a series of fascinating interviews with the top wood stove experts in the country on a host of technical and policy issues.  These interviews give a glimpse of the opinions and philosophies of industry and academic leaders at a time when they apparently felt free to go on the record about what became controversial topics. 
The content of these interviews remains very relevant today for anyone interested in a behind-the-scenes look at many of the underlying issues in the 2015 EPA stove and boiler regulations.  The interviewers – Jim Houck and Paul Teigs (who are top experts themselves) – asked questions ranging from whether masonry, pellet, boiler and furnace appliances should be regulated, to the vulnerabilities of catalytic stoves, to how lab testing can better reflect real world use of stoves. 
These interviews remain a valuable resource because each of the nine experts was asked the exact same questions.  Thus, if you are interested in masonry heaters, or catalytic or pellet stoves, or how labs coax the best numbers from stoves, it is relatively easy to scroll down and see how each person answered the question.  Of the nine interviewees, four are from industry (John Crouch, Bob Ferguson, Dan Henry and Michael Van Buren), two from test labs (Rick Curkeet and Ben Myren), two from academia (Skip Hayden and Dennis Jaasma) and one from EPA (Robert C. McCrillis). Their full titles and affiliations are at the end of this blog along with the full list of questions asked.  The full set of questions and answers are in Appendix B on page 58 and can be downloaded here (pdf).
In general, Bob Ferguson and Dan Henry tended to oppose further regulation, and felt, for example, that pellet stoves and wood-fired central heating appliances did not need to be regulated.  Ben Myren tended to favor a blanket approach of closing loopholes and regulating all appliances.  This difference in views between two industry experts and one test lab expert can be viewed through their respective economic interests and how it would affect their livelihoods.  But these interviews also show deeper philosophical differences and illuminate the reasons for their positions, whether they concern the health impacts of wood smoke, profitability, practicality of test method changes, etc.
We have chosen to reproduce the answers to two questions and invite readers to refer to the full set of interviews to find issues that they may be more interested in, such as the impact of wood species on emissions, stress testing to see how durable stoves are, and options to promote or require education or maintenance of stoves by consumers. 
When the Alliance for Green Heat began ten years after these interviews in 2009, much of the content had already been seemingly lost or obscured.  Very few people, for example, knew of the origin or impact of the 35:1 air-to-fuel ratio loophole that allowed pellet stove manufacturers to make low efficiency stoves in order to avoid regulation.  Right up until 2014, state and federal government agencies, along with top industry outlets, continued to propagate myths about pellet stoves.  Even the EPA never advised consumers that uncertified pellet stoves were likely to have lower efficiencies due to the 35:1 loophole they created.  These interviews provide the best information anywhere on how this came to be and what impact it had on the pellet stove industry and consumers.
We chose the question about whether central heaters should be regulated because this turned into one of the biggest issues in the 2015 regulations.  Only one interviewee – John Crouch – saw a causal relationship between the rise of outdoor wood boilers and the 1988 emissions regulations. 

Question: The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves — those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loop-hole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification?

John Crouch, HPBA’s
foremost wood stove expert.

John Crouch, HPBA: I wouldn’t use the term “close the loop-hole”. I would say, “is the proper place to cut off the definition of a wood heater?” We all know the whole discussion during the Reg-Neg ignored this emerging category of pellet stoves. So this gets back into my other broader comment, which is, instead of going back in and changing the NSPS in a piecemeal fashion, there needs to be a true revision of the whole thing that deals with the category of pellets and masonry heaters and outdoor furnaces.

Rick Curkeet, Intertek: Yes. The way to amend the regulation is to simply remove the 35:1 air/fuel ratio exemption. This has never been required by fireplaces (they meet the 5 kg/hr minimum burn rate exemption criterion anyway). Pellet units are readily able to meet emissions requirements and the exemption only encourages making these units less efficient to avoid the regulation.

Bob Ferguson, Consultant: The 35:1 cutoff was intended for fireplaces. However, pellet stoves are the only product that even take advantage of the air-fuel exemptions. Fireplaces generally use the burn rate exemption. Pellet stoves probably don’t need to be regulated at all. They are all quite clean burning. Let the marketplace decide if exempt stoves are acceptable. If pellet stove users demand products that use fewer pellets (more efficient), the manufacturers will respond. 

Skip Hayden, Researcher: Yes. In Canada, we recommend that people buy only EPA-approved pellet stoves. We have developed a high ash pellet stove that’s operating around 85% and its emissions are about 0.3 g/hr or less. 

Dan Henry, a founder of Quadrafire
stoves is one of industry’s most
articulate spokesmen.

Dan Henry, Aladdin: There is no data that indicates that even a poorly operating stove is a dirty burning appliance. They are inherently clean, becoming more and more reliable, and don’t fix them if they aren’t broken.

Dennis Jaasma, University of VA: Pellet stoves are inherently clean burning unless there is something very bad about their design. I am not concerned about regulating the currently uncertified units unless their field emissions are bad compared to certified stoves.

Robert C. McCrillis, EPA: Yes, all pellet stoves should be affected facilities and not subjected to that 35:1.

Ben Myren one of Amreica’s most
thoughtful and experienced stove tester.

Ben Myren, Myren Labs:  I agree, no more loop-holes. The new technology stoves that are coming on the market are going to be totally new critters. I don’t think that turning down the air- to-fuel ratio, to make it whatever it is, should get you out of the loop. Some of those suckers have got to be just filthy. I mean you look at the flame. I’ve seen them burn at the trade show; you know, the glass is sooting up on the edges. You can just see it.

Michael van Buren was a technical
expert with The Hearth Products
Association, now HPBA

Michael Van Buren, HPBA: I don’t know what that loop-hole does, whether it really affects the operation of the stove and the efficiency of the stove.

Question: According to a Department of Energy survey out of the 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified?

John Crouch: The [1988] EPA New Source Performance Standards killed the indoor furnace industry and created this little loop-hole which the outdoor furnace industry is beginning to exploit and kind of underscores the need for a more comprehensive wood burning regulation which sets out over a several year period to codify all forms of wood burning technology.

Rick Curkeet tested stoves for Intertek
labs and is one of industry’s top experts.

Rick Curkeet: I don’t know how many new units are being produced but I’m sure it’s a very small number. Still, one really poor unit can be a significant problem if it’s in your neighborhood. There have never been any standards for testing this type of product for emissions and efficiency. However, we have adapted existing methods and can say that the performance range is very wide. Poor designs may be 30% or less efficient and produce nearly 100 grams/hr emissions rates. Good designs are able to approach certified wood stove performance levels.

Bob Ferguson: I don’t feel there are enough units being sold to merit any activity what-so-ever. There are only a handful of manufacturers. I don’t think there has been anything published–so if testing has been conducted, it is probably a good assumption that the numbers aren’t that good. They shouldn’t be certified, as you would have to develop test methods and standards. The country would be better off using the money to pay manufacturers to phase out of production, sort of like the agricultural method of paying farmers not to grow certain crops.

The late Skip Hayden, one of the main
wood stove authorities during the 1980s
and 1990s.

Skip Hayden: The number of central wood furnaces in Canada, certainly in comparison to the United States, would be higher. In our Eastern provinces, it’s a relatively common add-on to existing oil furnaces. Generally, they are as dirty as can be.

Dan Henry: I think a lot of these are used in rural areas and considering the fuels that are out there, I don’t think they should be regulated. Maybe just a spot check of some sort. I think the only thing that would benefit would be the testing laboratories. If it emits particulate into an air shed where it can have an adverse effect on the industry (my ability to make a living), then yes.

Dennis Jaasma
also ran a research
test lab at the
 University of VA.

Dennis Jaasma: Yes, central heaters merit further evaluation. I don’t know how many models are available. I think EPA has done some work on them, but I do not know any results. Yes, they should be certified. They are in danger of becoming extinct if they don’t wind up with a certification program.

Robert C. McCrillis: In some localities I think these furnaces are a problem; I don’t know how many are commercially available. I think I can name off six or eight companies and each one makes several models, but I don’t know what the total market is, maybe 10,000 – 15,000 a year. The little bit of testing that we did here, says that they are probably on a par with a conventional wood stove. The way those things work, they have a thermostatically operated draft and when the thermostat shuts off the draft closes, so you get this real smoldering burning situation. Secondary combustion technology probably wouldn’t work. Possibly a catalytic technology would, but I just don’t think it stays hot enough in there. I guess that really depends on the impact.

Ben Myren: I don’t think they should be exempt for any reason. As to the rest of it–are there emissions data for them? I suspect there are. Should they be certified? Yes they should be certified. Nobody should be exempt from the process.

Michael van Buren: I think there should be some type of testing on them.

List of Experts Interviewed
Mr. John Crouch, Director of Local Government Relations, Hearth Products Association (CA) [now HPBA]
Mr. Rick Curkeet, P.E., Manager, Intertek Testing Services (IL)
Mr. Bob Ferguson, President, Ferguson, Andors and Company (VT)
Dr. Skip Hayden, Director, Combustion and Carbonization Research Laboratory (Ontario, Canada)
Mr. Daniel Henry, Vice President, Aladdin Steel Products, Inc. (WA) [now Quadrafire]
Dr. Dennis Jaasma, Associate Professor, Department of Mechanical Engineering, Virginia Polytechnic Institute and State University (VA)
Mr. Robert C. McCrillis, P.E., Mechanical Engineer, Air Pollution Prevention and Control, Division, U.S. EPA (VA)
Mr. Ben Myren, President, Myren Consulting (WA)
Mr. Michael Van Buren, Technical Director, Hearth Products Association (VA) [now HPBA]
Interview Questions
RWC Technology Review
Environmental Protection Agency Order no. 7C-R285-NASX
prepared by
OMNI Environmental Services, Inc.
Beaverton Oregon 97005
1. State-of-the-art of wood stove combustion and emission control technologies.
  1. 1.1  Are in-home emission reductions as compared to conventional stoves shown in Table 1 for catalytic and non-catalytic certified stoves reasonable?
  2. 1.2  Are efficiencies shown in Table 2 for catalytic and non-catalytic certified stoves reasonable?
  3. 1.3  Can catalytic technology for use in wood stoves be fundamentally improved?
  4. 1.4  Is the use of manufactured fuel (densified and wax logs) a credible emission
reduction strategy? See Tables 1 & 2 .
  1. 1.5  For non-catalytic stoves the heat retention adjustment with refractory material of various densities can reduce particulate emissions. How big an effect can this have?
  2. 1.6  Approximately one half of the particulate emissions occur during the kindling phase for non-catalytic wood stoves and more than half for catalytic wood stoves. Are there improvements in technology that can mitigate this problem? Can specially designed high BTU wax logs be used to achieve a fast start and reduce kindling phase emissions?
  3. 1.7  Should masonry heaters with tight fitting doors and draft control be classified as a wood stove and be subject to some type of certification even though most weigh more than 800 kg?
  4. 1.8  Are the emissions and efficiencies for masonry heaters, based on in-home tests, shown in Tables 1 and 2 reasonable?
  1. 1.9  The OMNI staff feels the emissions per unit of heat delivered (e.g., lb/MBTU or g/MJ) is a more appropriate way to rank the performance of wood burning appliances than emission factors (lb/ton or g/kg) or emission rates (g/hr). — Comments?
  2. 1.10  Default efficiency values are used for wood stoves. This coupled with the fact that emission factors or rates (not g/MJ) are used to rank wood stoves does not provide an incentive for manufacturers to increase the efficiency of their stoves. — Comments? Should an efficiency test method as described (FR v. 55, n 161, p. 33925, Aug. 20,1990) be required to be used and the results listed?
  3. 1.11  Have certified stove design and performance improved since the first certified stoves? If so, how?
  1. State-of-the-art of fireplace emission control technology.
    1. 2.1  Are the emission factors and efficiencies for the in-home use of fireplaces and inserts shown in Tables 3 and 4 reasonable?
    2. 2.2  There appear to be only a few practical design or technology options for fireplaces that will potentially mitigate particulate emissions. — What designs and technologies are available? What retrofit options are there?
    3. 2.3  The use of wax fire logs reduces emissions over the use of cordwood. Can the formulation of wax logs be changed to produce even less emissions?
    4. 2.4  What are the distinctions between a masonry fireplace and a masonry heater?
    5. 2.5  As with wood stoves, the OMNI staff believe that the mass of emissions per unit of heat delivered is a better way to rank the performance of fireplaces than emission factors or emission rates.
  2. State-of-the-art of wood-fired central heating furnace emission control technology.
3.1 According to a Department of Energy survey out of the 20.4 million households that used a wood burning appliance in 1993, less than 0.3 million used a wood burning furnace as their primary source of heat. Are there enough wood-fired central heating furnaces in use to merit their closer evaluation? How many commercially available models are there? Are there emissions data for them? Should they be certified?

4. State-of-the-art of pellet-fired wood stove technology.
  1. 4.1  Are the emissions and efficiencies for the in-home use of pellet stoves shown in Tables 1 and 2 reasonable?
  2. 4.2  The 35:1 air-to-fuel ratio cut-off for certification has produced two classes of pellet stoves — those that are certified and those that are not. The latter class may have models that are less efficient and have higher emissions than the former. Should the regulations be amended to close the loop-hole and discourage the practice of intentionally designing models with a higher air-to-fuel ratio to avoid certification?
  3. 4.3  Have pellet stove design and performance improved since the first models were introduced? If so, how?
1. Ramifications of ISO.
5.1 The International Organization for Standardization (ISO) has a technical committee for developing emissions, efficiency and safety test standards for wood-fired residential heaters and fireplaces. (See Table 5 for comparison of the draft ISO method 13336 with EPA methods 28, 5G and 5H.) Do you feel that the EPA methods should be replaced with or be made comparable to an international standard?
  1. Correspondence between in-home and laboratory emission test results.
    1. 6.1  How accurately do certification tests predict in-home performance?
    2. 6.2  How would you design research testing in the laboratory to simulate in-home use?
  2. EPA Method 28 strengths and weaknesses.
    1. 7.1  Method 28 is in part an “art”. Fuel loading density, fuel moisture, fuel characteristics (old vs new growth, grain spacing, wood density) and coal bed conditioning can be adjusted within the specification range of the method to influence results. In your experience what things have the most effect on particulate emissions? How much influence can they have?
    2. 7.2  Burn rate weighting is based on very limited data and the cities from where the data were obtained are not very representative of wood use nationwide (see Table 6). How can the weighting scheme be improved to be more representative of the nation as a whole?
    3. 7.3  The equation for the calculation of the air-to-fuel ratio as in Method 28A is in error. The error produces a small but significant difference in the calculated air-to-fuel ratio. Should the method be corrected or should it be left as a “predictor” of the air-to-fuel ratio?
7.4 The assumed mole fraction of hydrocarbons (YHC) is defined as a constant in the air-to-fuel ratio calculations in Method 28A. The mole fraction of hydrocarbons in the vapor phase will vary significantly with fuel and combustion conditions. Should hydrocarbon vapors (more appropriately, organic compound vapors) be measured as part of the method?
4. EPA Methods 5G and 5H correlations.

8.1 The comparison data to demonstrate the correlation between 5G and 5H are limited. Should the correlation between the two methods be reevaluated?
  1. Performance deterioration of EPA-certified wood stoves in the field.
    1. 9.1  It is the opinion of many in the wood stove industry that catalysts last only five years and that a stove designed for a catalyst operated without a functioning catalyst can produce as much emissions as a conventional stove. — Comments?
    2. 9.2  Field studies in Glens Falls, NY, Medford, OR, Klamath Falls, OR and Crested Butte, CO showed that emissions from some catalytic stoves became appreciably worse even after two to three years of use. Inspection of stoves in Glens Falls showed that catalyst deterioration and leaky bypass systems were responsible. Have improvements been made in the design of catalytic stoves to minimize these problems? Is it reasonable to require homeowner training on the proper use of catalytic stoves and/or to incorporate into their costs an inspection and catalyst replacement program?
  2. Stress test pros and cons.
    1. 10.1  A short-term laboratory woodstove durability testing protocol was developed to predict the long-term durability of stoves under conditions characteristic of in- home use (see EPA-600/R-94-193). It was concluded in that study that damage occurs during those occasional times when a woodstove is operated in the home at exceptionally high temperatures. The laboratory stress test was designed to operate a woodstove at very high temperatures over a one to two week period to predict long-term durability under in-home use. Is this a reasonable approach?
    2. 10.2  Should a stress test be made part of the certification process?
  3. Feasibility of developing separate emission factors for dry and wet wood and for
softwood and hardwood species classes.
  1. 11.1  Optimum wood moisture for low particulate emissions seems to be in the 18% to 20% range. Are you aware of any data that will allow the impact of wood moisture to be isolated from other variables? Could it be different for wood from different tree species?
  2. 11.2  Wood from different tree species clearly burns differently. The chemical make-up and density of wood from different tree species is different. For example wood from coniferous trees has more resin than wood from deciduous trees. It is believed that particulate emission factors will be different for wood from different tree species. If this is true different parts of the country may have different emissions factors for residential wood combustion. Are you aware of any data that document different emission factors for wood from different tree species?
8. Routine maintenance.
12.1 Would routine maintenance of stoves once they were in a home reduce particulate emissions? Would this be more relevant for catalytic stoves than non-catalytic stoves? Would this be relevant for pellet stoves with electronic and moving parts?
  1. 12.2  Should the home owner be provided with a maintenance manual or a training course at the time of purchase? Should a maintenance program be part of the purchase price particularly for catalytic stoves?
  2. 12.3  What would the key elements of routine maintenance be?

– end –

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New Paper Undermines Stove Industry Variability Research

A new paper written by Woodstock Soapstone, a New Hampshire wooden stove maker, phone calls a essential stove business examine misleading and flawed.&nbsp The market research suggests the inherent variability in wood stove testing implies that the EPA cannot reduce emissions requirements under four.5 grams an hour.&nbsp
The EPA posted the 7-web page Woodstock Soapstone paper today as portion of the formal file that the EPA can use to figure out the ultimate rule because of in February 2015.&nbsp It was composed by the company’s CEO, Tom Morrissey, and claims the industry variability review is “based on a info sample that is modest, previous and deeply flawed.”&nbsp
The late Paul Tiegs from OMNI
&nbsptest labs was a &nbspprominent
critic of variability becoming caused
primarily by gas.

Morrissey’s paper argues that variability has considerably more to do with regardless of whether a producer is spending&nbspfor emission certification than inherent variability in the combustion approach. “When a manufacturer pays for certification screening, why are the results so a lot much better than at any other time the same stove is analyzed?” Morrissey asks. &nbspThe Alliance for Eco-friendly Warmth thinks, as the Morrissey paper also suggests, that check labs have a range of running procedures allowed by the EPA that can consequence in variable emission results. &nbspThe late take a look at lab icon Paul Tiegs, a founder of Omni check labs, turned a champion of tightening testing protocols to achieve regularity in tests, and rejected the notion that variability was primarily induced by reliable fuel, as the business review argues.

If the EPA, states, and air companies just take the Woodstock Soapstone paper severely, it could unhinge a major industry lawful method in the combat towards stricter air pollution boundaries.&nbsp Several officials in the EPA and point out air agencies ended up presently essential or at the very least skeptical of the sector variability research.&nbsp However, there has not been this kind of a in depth critique from inside (or outside) the stove industry prior to this.

The variability review was developed and composed by Rick Curkeet, a fireplace merchandise engineer at the Intertek testing lab and Robert Ferguson, a specialist who is now functioning for HPBA on the proposed EPA rules.&nbsp It was launched in October 2010 in anticipation of the proposed EPA regulations and is known as the “EPA Wooden Heater Test Technique Variability Research: Analysis of Uncertainty, Repeatability and Reproducibility.”&nbsp

The examine showed that there is a really broad range of variability among proficiency screening and certification screening of wood stoves.&nbsp HPBA contends that “it is arbitrary for EPA to determine … a worth that is decrease than the precision range” of the check technique. &nbspHPBA says the minimum justifiable emission restrict is 4.five grams an hour, which Washington Condition adopted in 1995 and has because become a de facto nationwide standard.&nbsp The variability review does not say who paid for it but HPBA confirmed that they provided partial funding and thoroughly vetted early drafts in late summer and early fall of 2010.

Even though Morrissey’s paper is by much the most direct critique of the variability examine, most specialists concur that the understanding of variability in wood stove screening can be assessed in numerous much more approaches than the info established used by this business review.&nbsp For illustration, compliance test knowledge could be utilised.&nbsp The EPA demands that all stoves be retested soon after they make in between two,five hundred and ten,000 units.&nbsp This data, if it could be attained from the EPA, would provide possibly a far more crucial info established than the a single the sector examine chose to use.&nbsp An additional info set will be from the “K list” changes.&nbsp Most stove producers are re-certifying their stoves in progress of the new EPA principles so they will have five a long time before they have to take a look at again.&nbsp HPBA has been encouraging its users to recertify stoves with “K list” changes as they are allowed to do by the EPA so that they will not have to encounter higher tests expenses that consist of twine wooden screening and the uncertainty of a new check strategy that may be tougher to go.&nbsp HPBA had urged the EPA to grandfather all stoves below four.five grams an hour until finally 2020.&nbsp In any scenario, these retests will give a new and far better info established to evaluate variability.
Even if substantial variability could be proven and verified making use of different methods and info sets by unbiased professionals, the poor relations in between market and point out air agencies and other essential gamers has undermined the ability of the two sides to concur on much.&nbsp At a November 2012 assembly in Minneapolis convened by NESCAUM, Greg Eco-friendly of the EPA remaining the place and urged the two sides to chat much more among on their own.&nbsp That technique did not operate and quite little effective interaction occurred for more than a yr, a consequence that is most likely not helpful to the passions of HPBA sector members.&nbsp
Greg Environmentally friendly, Alison Simcox and Gil&nbsp
Wood&nbspof the EPA listening to testimony&nbsp
at&nbspthe Boston listening to on the NSPS.
The tough line technique to critics is what prompted Morrissey to create his rebuttal of the variability review which begins as a defense of test reports of his personal stoves that experienced been named into serious issue by HPBA, Rick Curkeet and Roger Purinton at Jotul stoves in official responses to the EPA.&nbsp Ironically, proof that catalytic or non-catallytic wooden stoves can be regularly clear has grow to be the largest danger to the mainstream stove market that HPBA represents.&nbsp This conflict between cleaner catalytic stoves and not-as-thoroughly clean non-catalytic stoves turned very heated and community in an EPA listening to in Boston on February 26, 2014.&nbsp But it was preceded by the release of research in 2013 by non-catalytic makers that dismissed the performance of catalytic stoves to reduce wood smoke in real entire world settings.&nbsp If this community rift inside of HPBA had not occurred, the stove sector would most likely have manufactured it via the EPA rule producing with a a lot far more unified voice.&nbsp
According to interviews with non-catalytic stove companies, they felt it was important for the EPA to realize that quite low emission figures from catalytic stoves in screening labs did not accurately replicate emissions in peoples’ houses as catalysts often clog, are not replaced, and are not correctly engaged and used by buyers.&nbsp This problem has proved to be essential because the EPA proposed emission restrictions of one.3 grams an hour in 2020, a amount that only a few catalytic stoves can seem to meet.&nbsp The firm that has made checks displaying it can fulfill it is Woodstock Soapstone.
The Woodstock Soapstone defense of its take a look at results and critique of the variability research will come at an essential time when the EPA is finalizing its new wood heater requirements, recognized as the New Supply Overall performance Expectations (NSPS).&nbsp It is considered that as of September or October, the EPA personnel will have produced most of their important selections to ship to Washington for overview and acceptance by senior EPA officials and EPA legal professionals.&nbsp Makes an attempt among HPBA and air agencies to attain any agreements driving the scenes could even now be fruitful, but time is running out.&nbsp And even if any agreements could be attained, the EPA might not undertake them.
The regulation and emission restrictions for out of doors wooden boilers are also hotly contested but the testing variability for boilers is not a massive problem, nor is it an concern with pellet stoves.&nbsp A single remedy, supported in portion by the Alliance for Green Warmth, would be to set independent emissions specifications for pellet stoves, catalytic stoves and non-catalytic stoves, based mostly on how thoroughly clean each technologies has become.&nbsp The argument for separating pellet stoves from cat and non-cat wood stoves could be even stronger since they use a various and very uniform gasoline and are burned in a much far more managed combustion location.&nbsp The Catalytic Fireplace Caucus, of which Woodstock Soapstone is a member, strongly opposed separate emission limits for cat and non-cat stoves as effectively.&nbsp&nbspUltimately, HPBA did not recommend setting separate emission restrictions that Jotul and other non-catalytic producers initially appeared to help.&nbsp At this position in the procedure, the EPA may possibly have presently decided to established a one emission normal for these very various technologies, as they had proposed.
If senior management at EPA sees reputable data that at minimum a single stove can constantly be tested under one.3 grams an hour, they now have a greater authorized foundation to adhere to their proposed one.three gram an hour normal.&nbsp And this is the nightmare state of affairs that HPBA and non-catalytic stove makers worry.
Stove authorities like Tom Morrissey, Robert Ferguson and Rick Curkeet are not only savvy about how stoves are tested, they are also competent amount crunchers.&nbsp Decoding stove examination info is like any other knowledge established: it can generate extremely diverse conclusions dependent on what information is employed, how it is interpreted and what statistical approaches are used.&nbsp The EPA in turn has to evaluate the trustworthiness of each research and they can fairly assume that their assessments will be challenged in courtroom.
Tom Morrissey, leading, 2nd from correct and
the staff that developed and built the
Perfect Metal for a 2013 competitiveness

The stove that Tom Morrissey says is reliably and constantly much less than one.3 grams an hour was exclusively constructed to acquire the 2013 Wood Stove Style Obstacle, and it did. The Wooden Stove Decathlon judged stove on five classes: emissions, effectiveness, affordability, customer attractiveness and innovation.&nbsp The Excellent Metal Hybrid is licensed by the EPA at 1. grams an hour and receives 82% efficiency.&nbsp A 2nd location winner, the Cape Cod, was a equivalent hybrid stove by Travis Industries that is qualified at even reduce&nbsp .05 grams an hour.&nbsp Travis however does not say that they can reliably or constantly take a look at at this kind of lower emission quantities, specifically with wire wooden.&nbsp Woodstock Soapstone says tests shows that their Excellent Metal Hybrid is as clean with twine wooden as it is with crib wooden.

The Alliance for Environmentally friendly Warmth encourages cleaner and a lot more productive residential wooden heating to minimize our reliance on fossil fuels and assist people affordably warmth their houses.&nbsp Started in 2009, the Alliance is based in Takoma Park, Maryland and is registered as a non-revenue, 501c3 instructional firm.

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Pro-wood heating group suggests EPA rules sensible and will help industry increase

The Alliance for Green Heat welcomed the release of proposed EPA laws on residential wooden and pellet heating products, expressing that new, stricter emission requirements “will support The us embrace wood and pellet heating as a crucial renewable power that can help significantly lessen fossil gasoline usage.”

More than ten million American homes heat with wood and pellets, ten occasions far more than photo voltaic and geothermal mixed, in accordance to information from EIA and the US census. “We can harness the massive demand for this variety of renewable power if the stoves and boilers are thoroughly clean ample,” mentioned John Ackerly, President of the Alliance for Inexperienced Heat. “We imagine the emissions quantities unveiled by the EPA these days are affordable and achievable and will support the wood stove market increase and thrive in coming decades,” Ackerly continued.

The proposed rule has number of surprises in phrases of emission figures. Almost all the key quantities have been integrated in draft proposed policies shared with market, states and non-profits during 2013. But the proposed rule does replicate the considerably stricter numbers the EPA developed soon after states and air quality agencies intervened in 2012. Previously, the EPA was contemplating 2.five grams&nbspper hour to be the strictest level for wood and pellet stoves. But final calendar year, the EPA floated a one.3 grams&nbspper hour for all pellet and wood stoves and that is the amount that was unveiled right now.

The EPA is proposing that wooden and pellet stoves at first satisfy a 4.5 grams&nbspper hour standard, and then fulfill a considerably stricter regular of one.3 grams&nbspper hour 5 several years soon after promulgation. Alternatively, the EPA proposes a three-phase procedure of heading to 2.5 grams&nbspper hour soon after 3 a long time and then one.three grams an hour soon after 8 a long time.

Likewise, the EPA is proposing two alternatives for furnaces and boilers. The first would set up rigorous emission boundaries soon after 5 several years, and the next would have an intermediate phase after 3 years, and then the stricter standard right after 8 several years. Initially, heat air furnaces would only be held to .93 lb/MMBTU, while hydronic heaters would be held to .32. Ultimately, the two would need to have to get to .06 lb/MMBTU both five or 8 years right after promulgation. It is commonly expected that industry will advocate for the 3-stage approach and that EPA would be open up to this as effectively.

The EPA’s press launch stated that “when these expectations are totally carried out … [c]onsumers will also see a monetary benefit from performance advancements in the new woodstoves, which use much less wooden to warmth houses.” However, the EPA decided not to contain any effectiveness common, leaving open up the chance that some extremely inefficient units may continue to be on the market place. Wooden and pellet heating appliances are the only HVAC tools with no bare minimum efficiency standards.

Each performance and CO would have to be recorded and noted underneath the new proposed rules. To stay away from logjams in screening to the new requirements, the EPA is proposing “to allow ISO-accredited laboratories and ISO-accredited certifying bodies to boost the availability of laboratories and certifiers.”&nbsp

The EPA is scheduling a public hearing on these laws in Boston on February 26. Interested get-togethers need to register by February 19 at http://www2.epa.gov/household-wood-heaters if they want to make community responses. Every person will be constrained to 5 minutes. The community has 90 days to comment on the laws following they are posted in the Federal Sign up, which is anticipated to come about in the up coming week or two.&nbsp

The proposed rule does offer you an abnormal glimpse into disagreements in between the EPA, the Little Business Company (SBA) and the Office of Price range and Management (OMB).&nbsp&nbspIn the Panel Report, the “SBA and OMB advisable that the EPA not go ahead with proposed emission boundaries for pellet stoves, indoor hydronic heaters, biomass pellet stoves, masonry heaters.”&nbspThe EPA even so rejected this suggestion and provided a sound foundation for their proposal to incorporate pellet stoves, all hydronic heaters and masonry heaters.

The SBA and OMB also advised that the NSPS only protect parts of the country exactly where wooden smoke air pollution was substantial. They advised that states and areas where wooden smoke is not high be authorized to issue their own restrictions and consider voluntary expectations. The EPA selected to emphasize and counter these recommendations in its proposed rule, demonstrating that they have regarded these choices but discovered they ended up not justified.

The Alliance for Inexperienced Warmth is a non-earnings client advocacy group that fights for cleaner and much more efficient wood and pellet heating to help households affordably switch to a renewable heating fuel.

For the full rules see: http://www2.epa.gov/household-wooden-heaters

A summary of the restrictions well prepared by EPA, without emission figures, can be found listed here:
www2.epa.gov/internet sites/manufacturing/data files/2013-twelve/paperwork/proposed_wood_heater_nsps_overview_simple fact_sheet_1.pdf
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EPA Inaction and an Industry Faction Are Holding us Back

On Oct 9, seven states and five environmental teams sued the EPA for failure to promulgate new emission specifications for household wood heaters.&nbsp If EPA had carried out its occupation many years ago, as it was obligated to do below the Cleanse Air Act, the stove sector and customers would be much far better off nowadays.

Rather, we have all been dragged down by an agency that has not taken residential wooden heating seriously ample.&nbsp And some the outdoor wood boiler producers have opposed realistic condition and local regulations on their items, top to controversies with condition air organizations and environmental groups that could be averted.
Privately, most people in the wooden heating industry concur that outside wooden boilers have presented us all a black eye.&nbsp These gadgets, notably concentrated in the Excellent Lakes location, are contributing in direction of a damaging view of wooden heating at a time when the public and policymakers could have been building a a lot more optimistic check out, as they have in Europe.&nbsp
But some outside boiler manufacturers, even though officially declaring that they want to be regulated, have fought in condition after point out to keep promoting old-fashioned polluting boilers.&nbsp And now they are fighting the EPA above what they feel are considerably also burdensome rules.
In the meantime, in Europe, exactly where such technologies really don’t exist, governments are vigorously supporting wood heat systems through rebates and incentives.&nbsp
A single purpose Europe has been in a position to incentivize wood heating is that virtually each place has a inexperienced label to identify the cleanest and most successful stoves and boilers, which presents lawmakers the potential to give rebates and incentives to the very best merchandise.&nbsp In the US, there is no Vitality Star system for wooden heaters and market has place the brakes on a state initiative to develop a environmentally friendly label program.&nbsp When we have a eco-friendly label program, I believe we will start to see the tide flip, with states starting to shift consumer buys in direction of the cleanest and most productive wood and pellet stoves and pellet boilers.
In polluted city locations, like Denver and Montreal and areas of the Pacific Northwest, we are likely to see much more bans on the new set up of wood stoves and a shift toward pellet stoves.&nbsp This may possibly not be ideal, but it is also a sensible response.&nbsp Cordwood is not an proper energy answer for lots of people in densely inhabited city locations, especially these that knowledge temperature inversions, when the technology is so dependent on operators utilizing seasoned wood and giving the equipment adequate air.&nbsp
In coming months, our neighborhood will be increasingly in the community spotlight as these lawsuits from the EPA get underway and we have a ninety-working day community comment period of time over the EPA’s extended awaited regulations.&nbsp We are in an period exactly where engineering can make wood and pellet stoves considerably cleaner, even though nevertheless becoming cost-effective. &nbspNumerous of these stoves had been on show the National Shopping mall at the Wooden Stove Decathlon in mid-November.&nbsp There, plan makers noticed what stove engineers are functioning on and are capable of generating.&nbsp They saw very first hand that wood warmth technological innovation is developing quick and can be a vital part of our renewable strength future, not just a relic of the earlier.
Outside wooden boilers are the most polluting class of residential wood heaters on the market these days, and as this sort of they will be the most in the information. &nbspBut the EPA restrictions are still essential in demanding equally wooden and pellet stoves to turn out to be cleaner and a lot more effective.&nbsp As soon as that takes place, public opinion can get started to change in a more favorable way toward deploying present day wooden and pellet engineering to reduce our reliance on fossil gas, and shrinking the divide between US and European coverage.

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Confirmed Pellet Stove Efficiency Essential to Industry Success

The pellet sector has been developing certification standards to make certain that consumers know the top quality of the pellets they are getting, but a comparable problem is currently being ignored when it comes to the products that makes use of the pellets—the performance of the stoves.

There is virtually no credible info offered to consumers that signifies which stoves are really successful, and which are pellet guzzlers. The federal and point out governments must be clamoring for this data, because pellet stoves and boilers are the biomass heating appliance that most justifies incentives, and incentives are virtually always tied to effectiveness.

For full tale, click right here.
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