[Stoves] EPA and heating stoves [Was: Top lit updraft combustors]

[Norbert Senf]

EPA Method 28 (crib fueling protocol) was originally developed by OMNI
Environmental in Oregon, and Oregon was the first state to regulate
woodstove PM, prior to 1988. The Condar portable sampler that we have been
using for in-house masonry heater testing was originally accepted as an
official method in Oregon, OM-41

EPA under Reagan had no interest in regulating wood stoves. It was sued by
Environmental Resources Defense Council, and forced to regulate woodstoves
by a judge in New York State. They basically adopted the existing Oregon
method, in a "reg-neg" process with industry.

In my opinion, if the federal government in the United States had not
regulated, we never would have got modern woodstoves. With woodburning,
every backyard welder seems to be an expert and have a better idea.
However, being forced to measure PM emissions to a known test standard was
a game changer.

There are 30 year long ongoing debates about realistic fueling cycles,
etc., but having an enforced certification standard changed everything.

We've done a lot of in-house work calibrating the Condar sampler against
EPA-M5G as well as measuring repeatability on masonry heaters, and pellet
stoves, and OMNI has done so on a regular EPA certified cordwood stove.
Here's a brief report:
heatkit.com/docs/presentation/Repeatability%20Studies%20with%20the%20Condar.pptx

That's not to claim it would necessarily  be applicable to cookstoves in
the developing world. Only saying that regulation has in and of itself
substantially advanced technology in the North American wood burning
appliance market. Somewhat similar to what happened with automobile
emissions.

Norbert

On Tue, Dec 19, 2017 at 5:47 PM, Nikhil Desai <pienergy2008 at gmail.com>
wrote:

> Ron says,
>
> "For the WBT under discussion for stoves, I think we are probably about
> +/- 5% (example:   such as Tier 4 re cooking efficiency at 40% +/- 2%).."
>
>
> I doubt there is empirical verification of this claim. Besides, % valid
> for efficiency may not translate in similar confidence intervals for PM2.5
> hourly emission rate, the metric that WHO and EPA are using to undermine
> the prospects of "clean enough" solid biomass stoves (even though WHO's
> rationale for hourly average emission rate to achieve certain levels of
> exposures is baseless.)
>
> Besides, what does it matter if 100 testing rounds are done with an unreal
> fuel (what is not locally accessible) and unreal cooking cycle?
>
> In any case, from what I can tell, EPA has NOT been using any version of
> WBT for regulatory approval of heating stoves. The WBT has no lawful basis
> in the US.
>
> Just what the stove industry thinks of EPA NSPS for heating stoves can be
> found at a May 2017 editorial Straight Talk in the Home and Hearth magazine
> - http://www.hearthandhome.com/magazine/2017-04-25/straight_talk.html.
>
> Mr. Houck begins, "It's time to face the truth about EPA's Standard of
> Performance for New Residential Wood Heaters. It's time to take the gloves
> off, stop being a gentleman, and tell it like what it is, The NSPS
> promulgated in 2015 is a bureaucratic nightmare conceived without good
> science. It has the potential to cripple the hearth industry and not do a
> very good job of improving air quality in the process. "
>
> Who is to say that EPA's monkeying around with cookstoves standards and
> rating systems for the world's poor would definitely not lead to the same
> outcome, after nearly 30 years to boot (as was the case with US NSPS for
> heating stoves)?
>
> EPA often does not know what it is talking about; but it is kept in check
> by public scrutiny, specific legislative authority, and occasionally the
> judiciary .
>
> In its interference - via GACC, ANSI and perhaps even WHO (I would like to
> know all the MOUs between EPA and WHO, and follow the money) - with
> cookstoves, EPA has no science, no legislative authority, and entertains no
> public scrutiny.
>
> John Mitchell, when I asked him at a recent webinar bout this secrecy with
> respect to its fancies in TC-285, responded that the ISO procedures
> demanded secrecy.
>
> What disingenuity. EPA went the IWA and GACC route precisely because it
> could not do such work in public.
>
> Anyway, going back to US residential wood heaters, I discovered some of my
> research (below); I would like Ron and Crispin to rationalize EPA's
> engagement in the cookstoves business; I can see nothing good coming out of
> it and TC-285 may become a millstone around the stove community's neck.
>
> According to Green Heat in 2015,
>
> "*In the late 1980s, hundreds of wood stove makers went out of business
> because they could not afford to adopt the technologies that would produce
> cleaner stoves. Some companies will also go out of business in 2015,* but
> unlike in 1988, an overwhelming majority of companies will be able to
> remain in business and many of them may thrive under these new regulations.
> " http://www.forgreenheat.org/policy/epa_policy.html, emphasis added
>
>
> And in May 2017,
>
> In the May issue of Hearth & Home magazine, James Houck wrote a lengthy
> criticism of the 1988 and 2015 NSPS,  Straight Talk
> <http://www.hearthandhome.com/magazine/2017-04-25/straight_talk.html>”,
> in which he took the “gloves off ... to tell it like it is.” It is
> essential reading for anyone who wants to better understand *the science
> and politics of regulating wood stoves*.
>
> But let’s take this a bit further and examine some of things that Jim
> Houck did not mention that also have implications for the future of wood
> heating in America. Houck states his premise is right up front:
>
> *“The 1988 NSPS was bad.  The 2015 NSPS is bad.  They are bad technically
> and they are bad for the hearth industry.  Certainly they have and will
> provide some environmental and health benefits, but they are poorly
> written, they have loopholes, they have cost the hearth industry dearly
> [and] they have allowed gamesmanship. [...] The blame cannot be put on
> regulators alone: those in the hearth industry also share some of it.”*
>
>
> Jim goes on to explain why we are going down the wrong path.  The 2015
> NSPS essentially adopts the same test method as the 1988 one: *a method
> based on grams per unit of time, not grams per unit of fuel, or better yet,
> grams per unit of heat.  He also very clearly shows how both the EPA and
> industry have ignored basic science by, for example, claiming that
> certified stoves reduce pollution far more than the data shows.  The best
> data shows an average decline in PM of nearly 50%, yet the EPA often claims
> its 75% and industry 90%*.
>
> The key question is, can manufacturers make genuinely cleaner stoves
> regardless of the EPA regulations?  Put another way, do manufacturers have
> the expertise and innovation necessary to take stoves to the next level
> despite poor regulations,* or does the NSPS retard innovation and require
> that stoves continue to be designed according to faulty parameters*?  There
> are good arguments on both sides of this debate.
>
> Houck says that the 1988 NSPS was bad and notes that hundreds of companies
> went out of business because of it.  But it did result in a new generation
> of cleaner stoves that appear to be about 50% cleaner.  Houck recalled that *we
> are now saddled with the legacy of the 1988 test method thanks to one
> stubborn regulator who strongly advocated it and subsequent bureaucratic
> inertia.*  Making radical changes to the NSPS is difficult for the EPA,
> due in part to its lack of resources—a condition which is likely to get
> worse under the current administration.  In fact, the lack of resources at
> the EPA could hobble the stove industry even more than the new
> regulations.  As it is now, *there is only one official who does
> enforcement, which includes approving lab certifications.  If that person’s
> time were to be cut back even more, it could pose serious economic
> consequences for manufacturers trying to get stoves to market for the
> heating season." *(emphasis added).
>
>
> Mr. Houck further says,
>
> "The NSPS promulgated in 2015 is a bureaucratic nightmare conceived
> without good science. It has the potential to cripple the hearth industry
> and not do a very good job of improving air quality in the process.
>
>
> All of this is germane to our debates here because there are parallels.
>
> See for example, in Houck's article, "Garbage In, Garbage Out" via
> propagation of errors.
>
> I  urge everybody to read this real life example of what mess EPA can
> create. A rogue employee with not enough resources may hire a cover, but
> ultimately all that is burnt is money and time.
>
> I am goingo to steal Frank's words "But I will be VERY happy to be proven
> wrong.
>
> To begin with, I would like you, Ron, to respond to Houck's piece. Who can
> and should trust EPA (except when being paid or paid off by it)?
>
> Nikhil
>

(snip)



-- 
Norbert Senf
Masonry Stove Builders
25 Brouse Road, RR 5
Shawville Québec J0X 2Y0
819.647.5092
www.heatkit.com
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