[Stoves] Alliance for Green Heat statement on new EPA rules

Thu Feb 5 16:01:01 CST 2015

Dear Friends

This most important point to watch in the comments below is that the testing of space heating stoves is done ‘in context’ meaning ‘as people use them’.

The emergence of sets of guidelines and multiple approved burn cycles at different power levels is what underlies the HTP (SeTAR) and CSI testing. Both are connected at the hip but they are implemented in slightly different ways, using the same spreadsheet.

The observation that stoves were being designed to pass the old EPA test, not to burn cleanly in average use, was accepted as a problem and the response has been to do what I term ‘contextual testing’. This means finding out what people do then test the stove with the fuel they typically use and using an operation cycle that is also typical. That is ‘the context’. Lab testing in context predicts performance in the field.

The measurements and rules are mostly about PM per unit of heat from the fire, not as far as I can see, per unit of heat delivered though the organisation sending this newsletter is known to discuss both. As you will already know, emissions per MJNET incorporate the heat transfer efficiency so the emissions are directly related to the effective heating. Because the EPA regulates total emissions, it is expressed in two different ways: mass of PM per unit of heat and total mass no matter what the heating rate or the heat transfer efficiency.

This newsletter contains very interesting news and is a response by the EPA to the manufacturers in particular. Note the reference to EU standards which already exist for cooking, heating, pellet and wood stoves. Some may find them interesting.

Regards

Crispin

From: Alliance for Green Heat [mailto:john at forgreenheat.org] 
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February 5, 2015

New EPA Regulations   <https://files.ctctcdn.com/40708e8b001/9fa0da79-6c2c-49cf-8238-88108ff8f720.jpg> 

Finally Released

EIA Proposes  

Pellet Survey

The EIA is proposing to undertake and ongoing pellet production survey just as it surveys other energy sources. The proposed  survey was published in the Federal Register and is now open to public comment. The FRN can be viewed here. The proposed survey is available  <http://r20.rs6.net/tn.jsp?f=0014x1wOjMw5hYgL-uzKNxxUxhI3tMpq37uDOMN6q00a_JOLQJ6Liby83E54oRRilizgHm98lTafxftCMlCPkRQ4PRVwWqZAhf-ijhu_g7JKO6PDPAMZQXN6ssWF9tUtGdGSgv0l-AtFTqaFMlnBcY_uMcchY5kcjHTe268MIjasPo5VtAAaKtmV2nLKCS1qO3QCZ_aixYLd6jJf2OERSuU3RWvgVIOlYVb_kq7m33hmEIMOlo130uzCo8w2_dr7Dz-crtPbzHOfAExb-NmiNKFX8EgYaoMwid3c_vKsNUNfP3yUL0SNawGS1Cil57PmDIUgZGMsC2AlxLNBXPLPyDZpg==&c=p4i3i9u95LCs69qmCPM0j5_Z1GViuXbeq-rqhbdfGpLwNwmc3gnhCw==&ch=op5vGxnMM7QXzszQ1QM2e_ujg_yU8JYyDyArxuO6xg_dnSQnWdKbIQ==> here.

The Alliance for Green Heat and many others are very supportive of this initiative and we urge you to comment in favor of it. Comments are due to EIA within the 60-day comment period, by March 2, 2015. 

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New Rules Bring Cleaner Chapter to Wood Heating

The Environmental Protection Agency released its new rules for residential wood and pellet heaters February 4th. They are expected to be published in the Federal Register in 1 - 2 weeks and become effective 60 days after that. We put together these initial reactions, which will be followed by a more thorough analysis.

Overall, we think 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. 

Labels and 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 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.

For the full rule and fact sheets, click here.

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)

Rules and compliance deadlines do not apply until after they are published in the Federal Register. These regulations do not affect fireplaces or existing wood or pellet stoves or heaters currently installed in homes.

For information about the rules, see the EPA's website here. 

Please Support Our Work

Thanks
to ...

The Alliance for Green Heat is an independent non-profit organization working to promote cleaner and more efficient biomass heating. Please consider making a generous contribution. The Alliance is a tax exempt 501 (c)(3) organization.

You can make a secure donation online through PayPal here:

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