AGH Remarks to the EPA on New Stove Information

Alliance for Inexperienced Heat
Feedback on the
July 1, 2014 Discover of Data Availability
Concerning EPA’s Proposed Expectations of Overall performance for New Residential Wood Heaters, New Residential Hydronic Heaters and Pressured-Air Furnaces, and New Household Masonry Heaters
Docket ID No. EPA-HQ-OAR-2009-0734
July 31, 2014
The Alliance for Inexperienced Heat (Alliance), appreciates the opportunity to comment on EPA’s July 1, 2014 Notice of Information Availability (NODA) concerning the agency’s proposed New Source Performance Standards (NSPS) for wood heating gadgets.[one]&nbsp The Alliance is an impartial non-earnings group that works with environmental and forestry corporations, air good quality experts, the wood and pellet stove sector, and other individuals in the wooden burning neighborhood to market high-efficiency wooden combustion as a reduced-carbon, sustainable, nearby and affordable heating solution.&nbsp The Clean Air Act needs EPA to assessment and revise, if appropriate, the NSPS at minimum each 8 a long time.&nbsp As we explain in the original comments we submitted on the Proposed Rule, the Alliance strongly supports EPA’s decision to update the expectations for wooden stoves and to need a variety of beforehand unregulated wooden heating units to decrease their emissions.&nbsp We also feel that the new expectations, which replicate considerable enhancements in wood heating technologies, are each acceptable and long overdue.&nbsp We offer the subsequent extra remarks in reaction to EPA’s July 1, 2014 NODA.

1st and most importantly, it is essential that, heading ahead, all stoves be essential to comprehensive a take a look at at the most affordable achievable burn up fee placing.&nbsp The knowledge released in the NODA supplied a vital perception that couple of people know: 80% of non-catalytic stoves can’t be effectively tested at the Class one melt away charge (.8 kg/h or less). &nbspUnder the present EPA check approach, Approach 28, these stoves have been authorized to take a look at at the increased Category 2 burn off price, as extended as they can successfully full a take a look at at one. kg/h or less in Category 2.

The possibility of staying away from testing a stove at the least expensive melt away rate—which is when emissions of PM and other toxics are usually the highest—has seemingly developed a loophole that has incentivized some companies to style their stoves so that they fail to hold a flame for a enough volume of time in Class 1, so that they can be tested at the less difficult-to-meet 1. kg/h burn up rate in Class two.&nbsp

If EPA finalizes its proposal to certify stoves based on only the optimum and least expensive burn off charges[two], this prospective loophole could turn into even more critical. &nbspEPA should make clear in the ultimate rule that all stoves qualified underneath the new NSPS must be capable of being analyzed at their lowest burn charge, and that stoves that are not able to successfully complete a check melt away at their least expensive charge will no for a longer time be eligible for certification.

This will still permit stoves to be analyzed at one kg/h but assures that the consumer can’t work the stove at a decrease burn up price.&nbsp We are not opposed to permitting stoves to use a bare minimum burn off price of up to 1.fifteen for cordwood screening, but yet again, they must be productively analyzed at their cheapest melt away price.&nbsp Normally, the proposal to increase the minimum to 1.fifteen kg/h could just enlarge the loophole of stoves tests at higher burn costs than shoppers could run them.

Second, it has turn out to be abundantly distinct in recent months that more and far more producers are using the K listing to make minimal changes in their stoves to ensure five much more several years of sales daily life prior to retesting.&nbsp While the K checklist supplies an critical perform, it is now currently being utilized to drastically hold off retesting of what could be a greater part of EPA certified stoves.&nbsp 1 of the final results of this is that manufacturers can keep away from testing at their least expensive melt away charge and avoid releasing their efficiency data till 2019 for a lot of or most or in some cases, all of their stoves. For this reason, we yet again urge the EPA to demand that effectiveness numbers using HHV be submitted to the EPA inside of six months of promulgation.&nbsp

The information released in the NODA confirmed prior info sets, that the performance range of pellet stoves is considerably broader than wooden stoves.&nbsp These certified pellet stoves ranged from 62 to eighty% effective with a common deviation of eight.5, double the common deviation of non-cats and four instances the deviation of cat stoves.&nbsp Since of this extensive variation of efficiencies, it is in the general public curiosity to demand efficiencies be introduced as shortly as practicable.&nbsp Manufacturers presently have performance info for most or all of their stoves so there would not be any substantial stress to them.

In addition, we be aware that the information presented in the NODA seems to set up that an emission charge of one.three g/h is currently being attained by some resources in the source group employing twine wooden.&nbsp The Alliance proceeds to assist EPA’s proposed strategy of permitting stoves to be licensed with possibly crib wooden or wire wooden throughout the first phase of the NSPS, and to need certification with cordwood thereafter.&nbsp In addition, the Alliance suggests that EPA keep on to gather take a look at info on wire wood emission prices for non-catalytic stoves more than the following five several years and think about revisiting the emission limitations in the NSPS if extra info propose that the NSPS need to be adjusted for non-catalytic stoves.&nbsp

Lastly, the Alliance has published a blog publish that addresses a variety of troubles related to the data introduced in the NODA.&nbsp We have appended this submit to these responses and request that EPA think about it together with our other responses as it finalizes the Proposed Rule.
&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp Sincerely,
&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp /s/ John Ackerly
&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp&nbsp Alliance for Green Heat

[1]Expectations of Efficiency for New Household Wooden Heaters, New Household Hydronic Heaters and Compelled-Air Furnaces, and New Household Masonry Heaters, Observe of Data Availability, 79 Fed. Reg. 37,259 (July 1, 2014) [hereinafter “NODA”].
[two]See Proposed Rule, seventy nine Fed. Reg. 6,329, six,367 (Feb. three, 2014).

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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 &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 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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