Monday, April 1, 2013

EPA Changes Strategy Again; Will Now Phase in Stricter Standards for Biomass Stoves and Boilers

Alliance for Green Heat, April 1, 2013 - The EPA released information about the New Source Performance Standards (NSPS) this month after making many changes to accommodate state demands for cleaner stoves and boilers. The new draft NSPS will do little to make most wood and pellet stoves cleaner until 2017 or 2019 but will have immediate impact on biomass boilers. All classes of heaters will have to meet stricter “best systems” emissions standards in 2017 or 2019, depending on whether EPA uses a two or three-step approach.

The draft NSPS appears to treat all biomass stoves, pellet or wood, catalytic or non-catalytic, the same and require that they emit no more than 4.5 grams of fine particulate emissions (PM2.5) per hour, a standard that has been in place in Washington State since 1995. The average pellet stove today emits about 2 grams per hour, already less than half of the proposed standards.

Hydronic heaters, commonly known as outdoor wood boilers, would also be held to existing standards that were developed about 5 years ago. However, the new NSPS would regulate sales and installations of these appliances across the entire country, instead of just the approximately 10 states that have adopted the voluntary EPA standard. 

While the new NSPS may reflect the status quo in many states in the near future, it could become far stricter for both stoves and boilers. In 2019, the test method for measuring stove emissions could change, for example, from averaging four burn rates to using only the highest or lowest burn rate (depending on which one the stove has the hardest time passing). Some in the industry think this standard will be a death-blow for stove manufacturers. Other experts say it will be achievable, but the stoves that will be made may not be as appealing to consumers.

The written document EPA released this month did not contain any numerical limits that industry would have to meet in the future, but Gil Wood, EPA’s lead official on this NSPS verbally shared numbers with roomful of stove and boiler manufacturers who had gathered in Orlando Florida for the annual HBPA Expo. The Alliance for Green Heat requested a copy to make available to the public, which the EPA provided.

The EPA has backed off of creating a required minimum efficiency standard, which all other HVAC technology has, in favor of testing and publicly reporting efficiency to the consumer. The industry position is that reporting efficiency is sufficient and enables the consumer to decide if they want the equivalent of a gas guzzler or a gas miser as their home heating appliance.

There is much speculation about how the new EPA Administrator, Gina McCarthy, will impact the NSPS.  Administrator McCarthy had been head of the air quality division at EPA and has a good working knowledge of solid fuel appliances. And, McCarthy has already reportedly asked tough questions about why fireplaces are not covered in this NSPS. 

Many in industry are simply tired of an agency that appears to keep changing its mind about how strictly wood heating appliances should be regulated. As of last fall, EPA appeared to have something close to a final draft of the new NSPS that was more acceptable to industry but considered far too weak by many states. 

States now appear to have strengthened their hand. By adopting a stepped approach, the new NSPS may do little to make stoves or boilers any cleaner before 2019 in the Northeast and Northwest, where states have already adopted standards that are as strict as or even stricter than what the EPA is proposing. 

The most immediate impact upon promulgation, which could be in 2014, is that unregulated outdoor wood boilers would go off the market in all states. But there is a growing movement that feels even Test Method 28 WHH and standards for EPA qualified outdoor boilers still are deeply flawed, even after Method 28 OHH was improved to Method 28 WHH. It is still unclear how boilers will be tested for 2014 compliance and how existing voluntary tests will be validated. 

Brookhaven National Laboratory recently completed a study that resulted in a new test method being created for both outdoor wood boilers and indoor boilers that have partial thermal storage. Funded mainly by NYSERDA with some support from EPA, this method draws upon the ASTM method and Method 28 WHH. It can be used instead of Method 28 WHH for any boiler with partial thermal storage. New York State has already accepted the test method which will help open up the state up to European and American boilers with thermal storage. 

The Brookhaven Method is also similar to the ASTM Method 2618 and could replace that method as well, but has it has not yet been introduced into the ASTM process. The test method is more stringent than Method 28 and the European EN 303-5 but it may be a quicker and cheaper test for manufacturers to undertake.  It is still unclear if the Brookhaven method could be part of this NSPS or not. That will likely depend on how much the states push for it and whether industry pushes back. 

The EPA’s latest timetable suggests it will have a final draft of the new NSPS ready for internal review in April and the agency will publish the standard in the Federal Register this summer. Industry, states, non-profits and the public will then have 90 days within which to submit comments. The final rule would be promulgated and go into effect in the summer of 2014.
The EPA has yet to meet any of their timetables for this NSPS. There is always the chance that someone will sue the EPA simply to get a court-ordered timetable that it would have to adhere to. And, lawsuits based on substantive regulations are also possible, if not likely, from a variety of fronts, if acceptable compromises cannot be reached.


  1. Gina McCarthy and Janet McCabe seem open for discussion about an NSPS for wood burning fireplaces. They have received letters requesting an NSPS from the American Lung Association, ECOS, NACAA, Westar, Nescaum and several major fireplace manufacturers.

  2. Why don't the government worry about more important things. There are way bigger issues than wood burning stoves that have been around for ever.

  3. Completely ridiculous what’s next regulating fireplaces in our houses?

  4. As usual EPA is still in bed w/industry. Gil Woods meets w/them and then does NSPS light. The regulations for wood boilers is a clear example of how EPA is not one bit concerned about the public's health when it comes to wood smoke. Why would boilers not be held to same standards as stoves? Same carcinogens as cigarettes, people's houses engulfed in smoke, exposure to VOCs, PM 2.5, and PAHs and Mr. Woods is busy showing off his NSPS light to the HPBA in Florida at their conference. People's lives have been ruined and people have suffered heart attacks, cancer, and asthma attacks and Mr. Woods is still glad handing the industry. No big surprise that industry was successful in getting Voluntary Program to be the proposed sanctioned. 95 g/hr vs. 4 g/hr in emissions. Corrupt. Mr. Woods is corrupt and cares not a bit about public health. Wood Boilers are inefficient and subject their owners and neighborhoods to horrendous pollution. Here's hoping Mr. Woods gets a dose of it some day since he obviously does not get it. Industry doing own testing. NYSERDA study showing EPA data 90% missing or incomplete for Voluntary Program on boilers. Bad data and now Mr. Woods wants to make this the regulation level. Corrupt is the only word for Mr. Woods. He should be fired and his pension taken away. Junket to Florida indeed. Disgusting.

    1. How can you even allow this ridiculous post to be approved by your site? Allowing someone to post completely false and defamatory information about an EPA official is scandalous! EPA - by law - is required to work with people/companies within the industries they are regulating and this EPA official delivers an EPA message to the industry and gets lambasted with false statement and information from some anti-wood burning activist and you post it. What a joke!

    2. I totally agree, where is the balance, as it is the latest round of mandates will kill many manufactures who don't have the ability to meet the standard, Only a few companies will survive. Clean air is good for everyone, but so are American jobs.

    3. Many Outdoor Boiler manufacturers will not be able to meet the latest round of EPA Regulations in 2014, they will be out of business just like hundreds of companies that went under after the EPA regulated woodstoves way back when. Today we have some very clean burning woodstoves and have made progress in cleaning them up. Other boiler manufactures like Econoburn and Woodmaster have worked very hard to meet them. Unfortunately the first two round of testing requirements was not fair as boilers and woodstoves are two different animals so the testing was flawed. There needs to be a better standard and the EPA has had a hard time figuring out what this is. They have a mandate to work together with manufactures to give them time to accomplish the EPAs goals, as well they should, it is only fair as jobs are at stake here. We all want cleaner burning products, however we need a standard testing procedures that yields the same results regardless if the boiler is tested at Omini, Interlake, or Brookhaven labs. NYSERDA has taken the lead on this and done a good job at sorting this mess out, hopefully we can soon have a standard we can all live by. Slandering Mr. Woods who has been handed a can of worms, or the EPA for that matter is childish in my humble opinion. How come no one here has the Kahunas to reveal themselves but prefers to remain "Anonymous" ? Maybe that gives them the right to spew forth garbage....I don't think so. Industries are at stake here as well as livelihoods, I applaud the EPA trying to work with these manufacturers, to come up with a workable standard, unfortunately it has not gone as planned. Manufactures have no control over clowns who think that burning tires in their OWBs is OK. Once again it is a few fools who make it tough on everyone else. Burning Biomass and wood is a renewable energy and good for the environment and the economy, lets not forget the facts for the sake of arguments.

  5. I was at the meeting in Florida when Mr. Woods presented the NSPS update. Sorry Mr. Anonymous, Mr. Woods did not get a "Junket to Florida", he addressed the audience by conference call from his office at the EPA.

  6. The proposed limit to outdoor wood fired hydronic heaters is measured in pounds per million BTU. EPA has indicated a limit of 0.32 lbs./Million BTU for phase 1. The limit of 95 grams an hour posted above is incorrect and I would like to know where that number came from. The difference between units that are not qualified Vs. units that are is night and day. Many qualified units, when run properly by the users, emit less emissions than some wood stoves.