As Utah debates seasonal stove ban, Salt Lake County adopts stricter rules

The proposed state seasonal
ban affects 75% of the Utah
population. 
As Utahns debate a seemingly doomed proposal to ban seasonal stove use,  Utah’s most populous county enacted its own rules banning stove use on both mandatory and voluntary air actions days as of Jan. 1, 2016. In other counties, voluntary air action days continue to be voluntary.

This will impact about half of all wood burning appliances in the non-attainment counties and could contribute significantly to reducing wood smoke.  Salt Lake County has nearly 102,000 wood burning appliances, with fireplaces accounting for a majority of that with 60,000 units, according to EPA figures.  There are nearly 20,000 uncertified wood stoves and about the same number of pellet stoves and certified wood stoves.  

This stove inventory was provided by EPA who use a variety of databases and sources to estimate the deployment of wood burning devices.
The governor’s seasonal ban proposal that would impact 7 counties in and around Salt Lake City is drawing intense and sustained criticism from Utah residents, with only a few people speaking up in support of the ban.  It’s also drawing national attention from the wood stove industry that wants a 2-stage system, where EPA certified stoves could be used in stage 1 and all stove use banned in stage 2.
On the other hand, Salt Lake County, which has a more than a third of the state’s population and nearly half of the population and half the stoves in the Wasatch front non-attainment area, went the opposite direction, including all stoves, certified and uncertified, in both stages of air action days.  “This is a significant measure and with more enforcement could achieve a quarter to a half of the reductions that the Governor’s plan sought,” said John Ackerly, President of the Alliance for Green Heat.

The issue has become an emotionally charged debate about individual rights vs. government control, striking a nerve within a deeply conservative part of the country.  In the public hearings, many people have testified about not being able to afford any other fuel than wood, and not wanting to be forced to use fossil fuel when they can use a cheaper renewable. 
But for air quality officials, the issue is simply about cleaning up the air and meeting federal air quality goals that are tied to highway funding.  The discussion quickly becomes about what the state can enforce and what it can’t.  The problem is that the state compliance capacity is already overstretched, with little ability to take on wood stoves.
However, that is different in Salt Lake County, which is moving ahead to enact stricter rules.  The County has decided to undertake the investigations of wood burning on mandatory no burn days itself, instead of leaving those to the state, which now only issues the fine.  Typically the initial warning is viewed an education process that leads to compliance, so that while many $ 25 fines have been given, rarely has the maximum of $ 299 been imposed. 
The new Salt Lake County rules, which take effect on Jan. 1, 2016, were not a reaction to the governor’s proposal or a rejection of the stove industry’s recommendations.  The County’s process began before the state’s process and ended before the stove industry got involved and helped set up the advocacy group Utahns for Responsible Burning.
According to officials at the Salt Lake Country Health Department, there was virtually no support for exempting EPA certified stoves from the county rule.  Both certified and uncertified stoves can produce excessive smoke, depending on operator behavior and moisture content of wood, with uncertified ones performing worse, on average.  While most EPA certified stoves produce 2 to 4.5 grams of particulates an hour in the lab when they are tested with specially prepared dry wood, they often produce far more in the real world.
The Alliance for Green Heat is urging Utah officials to consider phasing out uncertified stoves, since reducing the number of wood stoves will have the biggest impact.  “It may be that only about half of wood burners are really burning responsibly, whether they own a certified or uncertified stove,” Ackerly said.  “The uncertified stoves made before 1988 are now obsolete and most should not be used in densely populated areas,” Ackerly continued.

The current debate over wood heating comes less than 2 years after the outdoor wood boiler industry fought against Utah regulations that would prevent the installation of wood boilers on the Wasatch Front.  That debate also brought national attention of industry who hired lobbyists in Utah.  The industry effort to keep the market for outdoor boilers open in the non-attainment area was partially based on the now discredited argument that outdoor boilers were cleaner than wood stoves.

That case, like the current debate, involved questions of emissions data from test labs vs. emissions in the real world, and the likelihood that operators would be burning responsibly.


Heated Up!

Flurry of Lobbying on Furnaces and Test Methods on Eve of New Stove Rules

The Office of Management and Budget
is in the Old Executive Office Building
next the White House.

Sources confirmed that the EPA is set to announce the new wood heater rules on Tuesday, February 3rd, the court ordered date.  After years of debate and anticipation about cost impacts and emission standards for stoves and outdoor boilers, the issue that has become the most contested on the eve of the announcement is warm air furnaces.

The Office of Management & Budget (OMB) cleared the rule on Feb. 1 “with changes” setting the stage for it to be signed by Administrator McCarthy and publicly released.  (Rules often take 2 – 4 weeks to appear in the Federal Register after they are publicly released by an agency.)

Even though the big decisions were all supposed to be made last fall, there has been intensive lobbying by stakeholders right up until Friday afternoon, January 30th – one business day ahead of the expected announcement. At least 2 groups met with the Obama Administration through the Office of Management & Budget on Friday, January 30th. During January, interest groups had at least six other meetings with OMB, lobbying for last minute changes to the proposed rule.

The patterns, attendees and paperwork left behind at OMB meetings this month offer a unique glimpse into some of the most contested areas of the rule. Thanks to sunshine laws that make records of meetings with government agencies public, the public can see a list of who met with the OMB in the weeks leading up to the announcement of the rule.

The short term fate of warm air furnaces (WAF) appears to be the top priority of the hearth industry because they represent the only product category where most existing models cannot be made or sold for a period of time after the rule becomes law and before they become certified. HPBA participated in two meetings in January along with their legal counsel and consultant, Jack Ferguson, and various of their member companies, including US Stove, Central Boiler, Hardy, Heatmor and Hawken Energy.

Jack Goldman, CEO of the Hearth Patio & Barbecue Association, said in a letter to EPA that this is “clearly a death sentence” to most of the companies making warm air furnaces. The EPA says that they do not have the legal authority under the Clean Air Act to delay implementation of emissions standards. Warm air furnaces are the only class of wood heaters that will be required to meet emission standards, but are still unregulated and have little ability to be tested and certified until the rule is announced.  US Stove Co may be the leading manufacturer of warm air furnaces in the U.S. and they often sell for less than $ 2,000 – less than most wood stoves.

Another hot topic that emerged in recent months is a dispute over the opposite end of the spectrum from unregulated hot air furnaces – high performance indoor boilers, often made in Europe, but now being made in the US. The EPA certified test labs refuse to use a test method for these appliances developed by DOE’s Brookhaven National Lab and funded by NYSERDA, which captures some start-up emissions and uses cord wood instead of cribs. This is emblematic of a long simmering rift between test methods for outdoor wood boilers and European style indoor boilers with thermal storage, which offer the potential for cleaner combustion. NYSERDA and Econoburn, a NY manufacturer who makes these furnaces ask, “Who should really benefit? Those who innovate or those who refuse to?”

Other meetings in January with OMB and key stakeholders include one with about a dozen air quality agencies and states; with representatives of the Pellet Fuels Institute and a pellet testing facility; and with Intertek Test labs. Attendees in meeting between OMB and indoor and outdoor boilers and furnace manufacturers, and with NYSERDA and New York manufacturers are also in the public record.

If participants of the meetings provided OMB with documents, those documents are also public. Three key documents were provided this month, two from HPBA on a their legal argument (PDF) to delay compliance for hot air furnaces and a survey (PDF) commissioned by HPBA of HPBA member retailers on sell through trends. Four of the groups that met with OMB did not leave materials and there is as of now no record of the topics raised at those meeting. The only other document from the final month of intensive lobbying was from NYSERDA, NESCAUM and New York based companies (powerpoint).


Heated Up!

What Consumers Need to Know about New EPA Wood Stove Rules

Updated: May 31, 2015

In the long lead-up to the EPA’s new rules on wood and pellet stoves and boilers, there have been many claims, predictions and fears.  Here is a summary of the key points in the rule that will impact you, the consumer.


The rule becomes law on Friday, May 15, 2015 but don’t expect to see many, if any, changes in your local hearth store until Jan. 1, 2016.   Scroll to the bottom to see a timeline of implementation. This rule is an NSPS – a New Source Performance Standard  – established by the EPA with input from industry, states and other stakeholders.

Wood stoves: Consumers will barely notice any change until 2020.  As of 2016, stoves must not emit more than 4.5 grams an hour of particulates and after May 15, 2020, 2 grams an hour.  The biggest near term change is that the really cheap, uncertified stoves will no longer be on the market after Jan. 1, 2016.  (These stoves, often made in China, sold for $ 300 – $ 600.)

Pellet stoves: Consumers will not notice much change here either.  As of Jan. 1, 2016 all pellet stoves will have to be certified by the EPA.  Some models are also likely to get more efficient.  In 2020, pellet stoves also have to emit no more than 2 grams an hour.  Most pellet stoves already meet the 2020 standard.


Prices: There should be no short term price rises, but in the longer term some manufacturers say their stove prices may go up $ 300 – $ 400 in 2020.  Others say their prices won’t rise at all.

Retail “sell-through” period: Retailers have until Dec. 31, 2015 to sell existing stock.  Many retailers don’t carry anything that can’t be sold under the new rules anyway. Beware of sales this summer and fall that are trying to unload inefficient stoves and boilers before its unlawful to sell them.

Existing and second hand stoves: Existing stoves are not impacted by these rules, nor is the vibrant second hand market for wood stoves. States can regulate existing and uncertified stoves and Washington and Oregon do not allow anyone to install an uncertified stove off the second hand market.  All states allow consumers to purchase and install second hand certified stoves. (How to buy a second-hand EPA certified stove.)

Corn, coal and multi-fuel stoves: Corn and coal stoves are not covered by EPA rules and can continue to be sold without any government emission regulation, so long as they don’t advertise that they can also use wood or pellets. To advertise a multi-fuel stove that can use pellets and corn, the stove has to be certified for pellets and also tested with corn.  There is no threshold for emission with corn, but stove has to also be tested with corn and that data must be submitted to the EPA.  (More on corn stoves.)

Misleading advertising: Most manufacturers have posted unverified and exaggerated efficiency claims on their brochures and websites.  The new rules specify how stove efficiency is to be tested and reported, and companies may start posting verified efficiencies by May 15, 2015. It is unknown if the EPA will crack down on the rampant exaggerated and misleading efficiency claims.  Blaze King and Seraph are only companies that provide verified, accurate efficiency numbers of all their stoves to consumers and the EPA.  Beware of any stove that advertises over 83% efficiency.  

Efficiency: There is no minimum efficiency standard, but the new rule requires efficiency testing and reporting.  To date, most companies have treated verified efficiency as confidential records. Some companies are beginning to voluntarily disclose a few efficiency numbers.

New hangtags: The EPA is getting rid of the old hang tags that consumers were accustomed to on the showroom floor.  Instead, they are issuing special, voluntary hang tags only for those stoves and boilers that already meet the stricter Step 2 standards (2 grams and hour) or that have been designed and tested with cord wood. This will help consumers more easily identify the cleaner stoves and those that are designed to be used with cordwood – the same type of fuel that consumers use.  (Currently, all stoves are tested with 2x4s and 4x4s, which burn very differently than cord wood.)

Carbon monoxide (CO): The new rules do not limit the amount of CO that can be emitted but require that it be tested and reported. As with efficiency, it is still unclear if CO levels from existing stoves will be available before 2020.

Stoves tested with cordwood: The rules set up an alternative, voluntary compliance option for Step 2 emission levels of 2.5 grams an hour for stoves tested with cord wood.  This recognizes leaders in the industry who are optimizing their stoves for using cord wood and encourages other manufacturers to follow their example.

Pellet fuel: All new pellet stoves must be tested and warrantied to use with pellets that are certified by a third party entity – either the Pellet Fuels Institute (PFI), ENplus or CANplus. Consumers will see more and more pellets certified by one of those entities, which means they meet certain quality and consistency standards.



Export stoves: US manufacturers can continue to make and sell their existing stoves that do not meet the new EPA standards in other countries.  Uncertified stoves with no emission controls or testing can be sold in most of the world.  US stove companies are also increasingly exporting to countries that have emission standards, like Japan, Korea, Australia and New Zealand. These stoves have to be labeled as an “export stove. May not be sold or operated within the United States.” 

Masonry Heaters: The EPA did not set emission standards for masonry heaters in this rule, but asked the Masonry Heater Association to further develop a testing standard so that they could be included in the next NSPS, which should be in 2023.

Fireplaces: The new rules do not apply to fireplaces, but there is a voluntary method for cleaner fireplaces to be tested and qualified by the EPA.  This rule does not even refer to the voluntary program, which may mean there is little interest in including fireplaces in the next NSPS.

Owners manuals: Owners manuals will be updated as of May 15, 2015.  Updated manuals will have more detail and must instruct operators how to get optimal performance from the stove or boiler.

Litigation: The deadline to file suit over this rule was May 15, 2015.  The main stove and boiler industry association, the HPBA, has indicated it will be filing suit, probably over the 2020 emission standards.  Air quality groups are joining that suit to defend it from being weakened or delayed. PFI is suing over the authority of the EPA to regulate pellet fuel.  Tulikivi is suing because they want masonry heaters to be a regulated technology.  Several other companies are also challenging the EPA in court.

Role of states: Several states have passed resolutions barring state agencies from enforcing this NSPS but the rule clearly states that it does “not impose any requirements on state and local governments.”   To date, Missouri, Michigan and Virginia have passed laws barring state enforcement, largely a symbolic gesture. A number of other states will be helping to implement and enforce the NSPS to achieve cleaner air in their states and protect consumers.

Boilers & Furnaces

Boilers: Like stoves, boilers must meet Step 1 emission limits by May 15.  Retailers can still sell older, uncertified and unqualified boilers through Dec. 31, 2015.  In 2020, they must meet stricter emission limits.  Due to a schism between domestic boiler manufacturers and those importing more advanced European technology, most test labs are not willing to test use one of EPA approved boiler test methods.  There in still uncertainty about how one boiler test method, EN3030-5, is treated under the new rule.  


Warm air furnaces: Furnaces that heat air, instead of water, got a reprieve from the EPA after intensive advocacy by industry and pressure from Congress.  Small ones have to meet Step 1 emission standards by May 15, 2016 and large ones not until May 15, 2017.

Loophole for unregulated outdoor boilers: Manufacturers of unregulated outdoor wood boilers can continue to make and sell these units for “commercial” applications.  However, one outdoor boiler company has already indicated that as long as the customer assures the dealer that the unit will be used for commercial purposes, its up to the consumer to use it as they please.

Boiler and furnace prices: Unlike stoves, options for consumers will change more, since the boiler furnace industry had not been regulated and many low-cost, low-efficiency units were on the market.  Prices – and efficiencies- are likely to rise significantly but operating costs will be significantly lower.

Moisture meters: Conventional uncertified forced air furnaces and then certified ones must come with a free moisture meter.  (Some advocates had urged all stoves to come with moisture meters.)

Comments? If you think we have omitted important information in the NSPS for consumers, please let us know at  info@forgreenheat.org.

Heated Up!

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

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

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

Heated Up!

New EPA Stove Rules Begin Cleaner Chapter for Wooden Heating

Statement by the Alliance for Green Heat on the Wood Heater NSPS

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Full EPA rule and fact sheets

Wood and pellet stoves

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

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

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

Hydronic heaters

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

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

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

Warm air furnaces

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

Large furnaces: 2 years after publication (2017)

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

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

Heated Up!

Citizen Feedback on EPA’s Stove Rules Trending Favorably

We are now earlier the 50 % way mark for the duration of the ninety-day comment period and, as expected, almost all the responses posted so considerably are by citizen stakeholders.&nbsp Typically, the firms, governmental agencies, and non-profits who have the most skills hold out until finally the previous 7 days, or the final working day to file their remarks.

&nbspCitizen stakeholder feedback can be quite intriguing in that they can mirror the general temper of the population.&nbsp As of Friday, March 28, 571 folks had still left remarks.&nbsp The majority of individuals seem to favor the rules, with 305 producing good remarks and 202 making damaging types.&nbsp Amid these supporting the regulations, numerous merely refer to excessive smoke in their neighborhoods and do not especially point out the restrictions.&nbsp Similarly, a lot of folks who look to oppose the regulations refer to their proper to warmth their property with wooden and the hazards of authorities overstepping its mandate, but do not exclusively mention the laws.
The community remark forum offers the submitter the choice of submitting their title or business they are symbolizing or they can choose to submit an nameless impression. The fantastic greater part of individuals leaving comments did so anonymously. Anonymous responses on equally sides of the discussion tended to be brief, opinionated and everyday.
Among the nameless feedback for the rules two themes were plainly existing. They pointed out the unfairness of wood burners negatively impacting neighborhoods air top quality and their health.&nbsp Secondly, numerous discussed that wood stove appliances that generate so a lot smoke and particulate matter might be realistic in rural places but unjust and pointless in urban areas.
Amongst the anonymous responses from the new regulations, the two major subject areas had been people asserting their appropriate to warmth their homes with wooden heat and that the federal government is unlawfully encroaching into their residences. The next most common argument was the declare that with no wooden heat, their families would freeze in the winter season and throughout electricity outages because other varieties of heating were out of economic achieve.
Between the for a longer time, more knowledgeable responses are copies of several of the testimonies from the Boston general public heating on the regulations on February 26.&nbsp Many of these arrive from the most crucial market and no-earnings players who will also be filing feedback during the final working day or 7 days.&nbsp These comments, linked below, tend be overarching themes and do not have particular suggestions about information of the proposal.&nbsp

The proposed NSPS is nonetheless in the public comment period until May possibly fiveth, 2014 when last responses are because of, at regulations.gov.

Heated Up!

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

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

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

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

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

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

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

Thanks to everybody who lent their voice to this marketing campaign. With your support, we ended up ready to assist the Utah legislature comprehend the disinformation campaign that the invoice was dependent on.
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Utah Adopts Innovative Outside Boiler Rules


Alliance for Environmentally friendly Warmth, February 11, 2013 – A last moment attempt by a producer to derail new outside boiler rules in Utah unsuccessful. The State’s Air Good quality Board handed progressive and well balanced restrictions that permit the installation of EPA experienced outdoor boilers in rural counties but ban them in populated counties that do not satisfy federal air top quality specifications. The laws will just take influence this spring.

This can make Utah the latest in a string of states to control the out of doors wood boiler, the most polluting household wood heating technological innovation on the market place. &nbspUtah went additional than most states, banning their set up in locations that already have very poor air good quality and the place about 2 million out of Utah’s two.eight million populace lives.

Utah is now the only state to undertake an installation ban on out of doors wooden boilers in significantly of the condition, but nonetheless enable their use in rural places. Washington and Oregon have restrictions that effectively banned outside boilers in the whole point out. Other states only regulate exactly where they can be mounted by way of residence line setbacks.

Several states require boilers to be set back again at least 50 feet from the nearest residence line. New York and now Utah demand 100 feet. Maryland and Rhode Island are the only states with laws restricting installs to EPA competent units that have no property line established backs.

An revolutionary attribute of the Utah regulations addresses homes that currently have outside wood boilers and now fall in the area in which they are banned from installation. Those units are grandfathered, but people dwelling in the banned counties can put in another outside boiler in the future as long as it runs on pellets and is EPA certified.

The regulations also call for a one,000 toes setback from a college, working day treatment center or hospital, which may possibly be the strictest this kind of clause in the place. The maps underneath demonstrate the correlation amongst populace density and the non-attainment places in Utah.

Central Boiler fought towards Utah’s new restrictions arguing that the rule “lacks scientific help and would unfairly prohibit Utah people from acquiring and making use of thoroughly clean-burning wooden furnaces.” A main thrust of Central Boilers argument is that Period 2 boilers “are cleaner than EPA qualified wood stoves.” Especially they claim “average emissions for a Period two OHH [out of doors hydraulic heater, an additional name for out of doors wood boiler] are 77% much less than people from EPA-Licensed wood stoves.” The complete submission by Central Boiler can be discovered listed here.

The Alliance for Inexperienced Heat supports laws in all states that only let the set up of Period 2 competent outdoor boilers and, like Utah, have setbacks or other restrictions to avoid their set up in densely inhabited places.

Click on right here for an overview of state outside boiler regulations.&nbsp
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