[Stoves] Woodstove rules in western North Carolina amount to'jumping on the crazy train'

Mon May 30 16:22:12 CDT 2016

Crispin,

It occurs to me that you may be fixating on your created negative here.  Did you notice the high power indoor PM2.5?  At 0.7345 mg/min it is very low, and that is a positive.  Also, all other results are very good.  When your test methods are ready I will be happy to test accordingly.  Until then I can only show the quality of this stove by the current standards.  I am looking forward to also show the quality of this stove by your standards, when available.

All,

This stove or one like it will be at Aprovecho for Stove Camp in August.  You are all welcome to be there to examine and test it.  You will find a good stove, described during testing as "rock solid".

Kirk

----- Original Message ----- 
  From: Crispin Pemberton-Pigott 
  To: Stoves 
  Sent: Monday, May 30, 2016 12:32 PM
  Subject: [Stoves] Woodstove rules in western North Carolina amount to'jumping on the crazy train'

  Dear Wood Stove Friends

  I have a comment on good authority (there really are authorities in this matter) that the 'one death per day avoided' is baseless conjecture. One consultant called the claim 'plain fraud', there being no real basis for making it (the claim). In other words you can claim what you want and no one can prove anything one way or the other because there is no data underlying them.

  This is sort of related to the Pellet Stove competition discussed previously in that the rules the EPA envisages being implemented are being used as performance criteria. Something that has manufacturers up in arms is the test method applied because the test conditions are so different from typical conditions of use. 

  A number of initiatives are on-going with respect to test methods. Some states have their own test methods and performance requirements which complicates things for manufacturers as they have to 'tune the stove' to the test methods, really not provide a low emissions, efficient user experience. 

  We had just experienced on this list Kirk tuning his stove (making it less efficient) in order to 'get a better number' for an invalid metric. In the same manner, manufacturers create stoves that 'test well' by gaming every possible aspect of the test to get the best number they can. At the moment, the main cheat involves sustaining a char-burning phase for as long as possible as the emissions are rated 'per minute'. As a char burning phase has zero PM2.5, the longer the char burn can be sustained, the smaller the resulting number when the total PM mass is divided by time.

  Regards

  Crispin

  http://www.citizen-times.com/story/news/local/2015/04/23/bill-turns-thumbs-wood-stove-rules/26263837/

  Bill turns thumbs down on woodstove rules
   Mark Barrett, mbarrett at citizen-times.com6:05 p.m. EDT April 23, 2015

  Rules on wood stoves are "a point where the EPA has really hopped on the crazy train for us in Western North Carolina," Sen. Ralph Hise, R-Mitchell, told the Senate.
  Buy Photo

  (Photo: Katie Bailey/bkbailey at citizen-times.com)

  RALEIGH - North Carolina would not take part in a federal effort to more tightly regulate emissions from new woodstoves, a common source of heat in Western North Carolina, under a bill that passed the Senate Thursday.

  But, state regulators had not planned to participate anyway, said Tom Mather, a spokesman for the Department of Environment and Natural Resources.

  Sen. Ralph Hise, a Mitchell County Republican who is one of three primary sponsors of the bill, told the Senate the rules are "a point where the EPA has really hopped on the crazy train for us in Western North Carolina."

  The state, he said, cannot "change the federal regulations, but we can not adopt them," he said.

  The U.S. Environmental Protection Agency is implementing restrictions it estimates will reduce fine particle emissions from wood heaters by nearly 70 percent. It says that will mean an average of one fewer premature death per day and yield about $100 in public health benefits for every $1 of additional cost to manufacturers.

  Among WNC counties, the percentage of homes heated by wood ranges from 4 percent in Buncombe County to 17.6 percent in Yancey County, with the rate falling somewhere between 5 and 11 percent in most counties in the region. New Buck Corp. makes the popular Buck Stove brand of wood-burning stoves in Spruce Pine.

  CITIZEN TIMES

  New EPA wood stove rules concern makers, users

  Mather said state regulators "are not involved with wood heaters at all. ... We've never even looked into it. I'm not sure where this came from."

  The state enforces many rules the EPA adopts under an agreement with the federal agency. But Mather said in the case of woodstoves and similar devices, the EPA rules fall directly on makers of new stoves and the state is not involved. The rules do not apply to existing stoves.

  Dan Crawford, director of governmental relations for the N.C. League of Conservation Voters, also said the bill would have a limited impact.

  "A lot of us felt this bill was much ado about nothing," he said.

  Another part of the bill would require that any new rules the state Environmental Management Commission adopts affecting woodstoves be approved by a three-fifths vote of that appointed body. It's unclear whether it might affect other types of emissions as well.

  "No longer is the state going to be on autopilot for putting in the state rules what the EPA is cramming down on us," the bill's lead sponsor, Sen. Chad Barefoot, R-Wake, said during Thursday's floor debate. Sen. Jim Davis, R-Macon, is also a primary sponsor.

  The bill passed 40-9 and will be sent to the House. Sen. Tom Apodaca, R-Henderson, complained on the floor that some senators from urban areas had voted against the bill.

  Instead of visiting the mountains in the winter when people are burning wood to heat their homes, bill opponents "may want to wait until summer," he said.

  Sen. Josh Stein, D-Wake, responded that he voted against the bill because, "We've got a very good rule review process" already to determine whether to adopt rules coming down from the EPA.

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