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

Tue Dec 19 16:47:58 CST 2017

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

On Fri, Dec 15, 2017 at 7:08 PM, Ronal W. Larson <rongretlarson at comcast.net>
wrote:

> List, cc Andrew and Norbert
>
> 1.  Thanks to you both.  So we are all on the same page, the message the
> Andrew received at 15:36 PM was received at 9:38 AM Denver time.  That was
> a much longer message than below, but I don’t see anything to add.  All
> looked good,as Norbert was responding to my question on how to be sure that
> we were “harmonizing between two very different biomass thermal
> applications.
>
> 2.  But re my on-going dialog with Xavier (hugely longer today) on this
> same topic,  I need to point out that Norbert said:  “*When you get into
> the weeds of “what is the repeatability of your laboratory method”, the
> answer is “we don’t know”, and the next best answer is “plus or minus 40%,
> based on limited data”.*
>
> 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’m
> happy enough with 5% repeatability and see in the standard deviations
> numbers much smaller at any single laboratory.  I gather Xavier thinks that
> is not good enough, but I still have to read through his many articles
> provided today to understand his concerns.
>
> two more inserts below.
>
>
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