Alliance for Green Heat, Jan. 6, 2012 - The
long awaited proposed New Source Performance Standards (NSPS) for residential
wood heaters is being delayed yet again. EPA claims that it will be out this
summer for the 90-day public comment period, and noted in a PowerPoint presentation that
since this NSPS is not court ordered, such delays are possible.
The Alliance for Green Heat
believes the multiple delays in this proposed NSPS, which now add up to several
years, have allowed tens of thousands of polluting outdoor wood boilers to be
installed. It has also deprived consumers of being able to select more
efficient, money saving wood and pellet stoves. Until real efficiency numbers
are published, the consumer is left without one of the most important pieces of
information in their purchase.
“Even before the recent
belt-tightening at the EPA, the agency has not provided the resources that
would allow it to efficiently carry out this NSPS,” said John Ackerly,
President of the Alliance. “Given the
millions of low and middle-income families that rely on wood heaters, wood
heaters should have more priority within the EPA.”
The EPA has publicly released a
draft summary of the new NSPS, which will establish mandatory and stricter
emissions thresholds for almost all wood heating appliances. (Fireplaces, pizza
ovens, chimneys, etc. are still exempt.)
The new non-cat wood stove
standards are one of the mildest, going from 7.5 to 4.5 grams an hour, a standard
the EPA acknowledges is already met by 85% of wood stoves. However, in addition
to particulates, a minimum 70% efficiency standard is being added (high heat
value) to
reduce carbon monoxide (CO). Real efficiency numbers will be disclosed for each
stove for the first time.
Catalytic stoves are being held to a
tighter standard (2.5 grams an hour), potentially giving them the reputation of
being the cleanest stoves on the market. EPA noted that the catalytic hearth
coalition is arguing that all wood stoves be held to the same standard. In the
EPA’s PowerPoint presentation, the EPA said they are requesting “comments and
data to support other options for promulgation, e.g., establishing one limit of
2.5 g/hr for both non-catalytic and catalytic stoves.”
In the boiler arena, there is a similar discrepancy as there is
for wood stoves: indoor boilers are being held to a less strict standard than
outdoor boilers, and the EPA is likely working to make the case that they
should be. Boilers will have to meet one threshold in 2014/2015 and a stricter,
Level 2 threshold in 2017. In this arena, the EPA is requesting “comments and
data to support additional options for promulgation, such as co-proposal of
Level 2 immediately”.
For pellet stoves, the EPA has set an
emission level far above what most pellet stoves produce – 4.5 grams an hour,
the same as wood stoves. If this occurs, the United States would be the only
developed country that does not hold pellet stoves to a stricter standard than
wood stoves. It may also undermine the ability of consumers to use pellet
stoves on bad air quality days, when wood stoves can’t be used. The Alliance
believes the pellet stove industry should be positioning itself as a cleaner
alternative to wood stoves and suitable for densely inhabited areas. The EPA
may be willing to lower that standard and says they are requesting “data and
comments to support additional options for promulgation, e.g., tighten the
level in “2015” to 2.5 g/hr.”
The EPA’s draft recommendation for
single-burn-rate stoves is 3 grams an hour, and also a minimum of 70% efficiency,
and they are requesting “comments and data to support additional options for
promulgation, e.g., 2.5 g/hr.” The EPA also notes that single-burn-rate stoves
have been the “largest exemption for wood stoves in existing NSPS in terms of
number of units sold (>40,000 units/year).”
The EPA’s request for “comments
and data” on all these appliances classes is laudable but there appear to be
few data sets that the EPA doesn’t already have that are professional and
substantial enough to make a difference. EPA has had to rely on industry to
fund and produce various studies because EPA does not have the resources. This
has put a financial strain on industry, which is essentially made up of a few
dozen small manufacturers, but also given industry a more powerful position in
the process.
Partly because of lack of resources, EPA
was not able to undertake a number of initiatives that it considered in this
NSPS. Also, as EPA noted in the PowerPoint, “Some states are disappointed that
we are not proposing carbon monoxide (CO) emission limits, visible emission
limits, and requirements for energy audits, proper sizing, heat storage, and
certified installers.”
