Tuesday, March 22, 2011
[Update: The proposal was not published in the Federal Register until 2014, and public comment period ended in May 2014.)
Monday, March 21, 2011
The Alliance for Green Heat (AGH) ran a round-table discussion/workshop on incentive programs at the 2011 HPBA Expo. The Alliance presented on the different types of incentive programs, the possible rational and goals behind many incentive programs and an example of the legislative process in Maryland. There were twenty-five people total in attendance and participants ranged from appliance manufacturers, retailers, fuel producers and suppliers to EPA officials and non-profits. The appliance industries represented included outdoor wood boilers, pellet stoves, masonry stoves, catalytic and non-cat wood stoves. While this group was only a small percentage of the industry, many of the participants represented large companies and/or had great depth of policy experience. The discussion provided excellent feedback for AGH’s incentive project and helped focus some of the key issues that need to be investigated.
Efficiency: The EPA will require reporting of actual efficiency numbers in the NSPS and there was a debate about whether there should be a minimum efficiency threshold required by EPA. A Task Force member spoke out strongly against focusing on how high efficiency numbers could go because in wood stoves, extremely high efficiency numbers means lots of problems with draft, condensation and creosote formation – issues that go to heart of safety and effective functioning of the stove. A lively debate ensued about whether wood stove owners care about efficiency and whether we should. Most participants seemed to think some focus on efficiency was important, but not as a way to incentivize the best stoves.
Change-outs (and rental units): A task force member emphasized that the public dollar is best spent on change-out programs, particularly focusing on low-income households. He praised the Idaho tax deduction program for requiring an older stove to be recycled for the deduction. He also suggested that incentive programs should focus on renters more often as they are a huge source of residential wood stove home heating (often using an un-certified stove due to financial constraints).
LIHEAP Benefits: A task force member explained that wood stoves for home heat actually help low-income families stay off of government assistance programs such as LIHEAP, which allows the LIHEAP dollars to stretch further.
Lower Emission Limits for Incentive Programs: One of the liveliest discussions was around the pending Maryland biomass stove incentive bill that sets emissions standard for wood stoves at 3g/hr and pellet stoves at 1.5 g/hr. Participants cited the new Rick Kurkeet study showing the margin of error for EPA studies could range from 2.5g/h - 6.5g/hr, so putting the requirements lower than the EPA standard is arbitrary and will not necessarily incentivize cleaner stoves. A counter point is that stricter standards are inherent in virtually all incentive programs and often form the core rationale for them, and that popularizing the idea that wood stove emission tests are unreliable may be counterproductive with incentive program managers.
Wood vs. Pellets
Wood stoves should always be an option for people in incentive programs. The fact is people won’t want the expense and trouble of pellet stoves and will instead prefer to stick to their old and possibly dirty stoves rather than use the incentive to buy a pellet stove. However, pellets, not cordwood, are likely to be the future of biomass heat in this country. Many people are too lazy to stick with cordwood. Ideally in the future pellet heat will be as easy as oil. Wood stoves equal operator error, and no matter how clean they are regulated to be, people will always be able to burn them dirty. Are there other creative ways that incentive programs can address this?
Replacement on sale of Home
The Oregon law requiring old stoves to be replaced upon sale of property is a great law and bundles the cost of replacing an old stove into the purchase price of the home. This should be a federal program. The NSPS cannot accomplish this, and Congress unlikely to do it, so it may be left to states. Some in Washington State are considering it. Oregon achieved it by having local jurisdictions do it first, creating an incentive for consistency state-wide.
Since old stoves in the market are the main source of our air quality issues, perhaps regulations could focus on eliminating the market for parts for non-compliant stoves, so when old stoves break, they are forced out of use. Europe places a ‘born on’ date on all of their wood stoves, this makes it easy to phase out/in stoves when they are outdated or too polluting. France had an excellent change-out program.
· 25c was not that effective since people used it to replace broken things they were already planning on replacing and did not spur people to buy energy efficiency things they weren’t already considering. There were few water heater change-outs, for example.
· Some incentive programs, like that in Montana, had a hard time giving away new stoves since people only wanted to keep their old stove. “If it ain’t broke, why fix it?”
· One way to sell incentive programs in the future to consumers might be to highlight savings in time and money, rather than health and abstract efficiency concepts.