The Alliance for Green Heat believes that a minimum efficiency standard is needed, no question. The only question is where the bar should be set and when. Minimum efficiency requirements are becoming standard for major appliances and we believe wood and pellet stoves are better served by being part of the energy efficiency mainstream, not fighting to be outside of it.
A 70% minimum is likely the best minimum efficiency to include in this NSPS and the debate should center on how long manufacturers have to meet that minimum. One option is to say stoves must be 65% efficient a year or two after promulgation and 70% within several years after that.
Then, we think it’s vital that our industry have an Energy Star program that recognizes the most efficient and cleanest stoves. This will help consumers and our industry gain greater support from policy makers, regulators, the environmental community and the general public.
One reason minimum efficiency standards are needed is that the cheap price tag on inefficient products in Asia often is greater selling point than its efficiency label. Are the high quality domestic stoves producers really willing to compete with cheap, inefficient stoves for the next 10 or 20 years? This would be a great disservice to an industry that is still dominated by high quality domestic manufacturers.
Minimum energy efficiency standards have reduced energy costs for consumers by billions of dollars each year. To date, every federal dollar spent has resulted in an average of $650 in net savings, and has also helped spur product innovation: http://www1.eere.energy.gov/buildings/appliance_standards/. Minimum standards of energy efficiency for major appliances are firmly established by the U.S. Congress in Part B of Title III of the Energy Policy and Conservation Act (EPCA): http://www1.eere.energy.gov/buildings/appliance_standards/laws_regs.html
According to one authoritative study by the Consumer Federation of America, nearly all Americans (95%) think it is beneficial for appliances to become more energy efficient and most (78%) think it’s very beneficial. Nearly all Americans (96%) think energy efficiency is important for personal financial reasons and almost all (92%) think it’s important for the environment as well. Substantial majorities of consumer even favor increased efficiency when it increases the purchase price of the items. And, about two thirds of Americans know that the government requires most appliances to meet minimum energy efficiency standards: http://www.consumerfed.org/pdfs/CFA-Appliance-Efficiency-Report-3-11.pdf
The EPA has been far too slow and timid in establishing the regulations that will help propel this industry forward. The first NSPS was a lifeline for this industry and this NSPS can be just as beneficial. This NSPS could help propel wood and pellet stoves into the mainstream of the renewable energy movement. Look at the example of Europe. Efficiency standards have gone hand in hand with soaring sales of more efficient wood and pellet equipment.
There are pellet stoves on the market today that are under 50% efficient and even below 40%. Imagine those families who keep pouring 40 pound bags of pellets into an appliance that is half the efficiency of what it could and should be. Wood and pellet stoves appeal to Americans because they save them money. It’s all about efficiency. Does the industry really want to publicly fight against a minimum efficiency standard that will save consumers millions of dollars?