On May 9, 2013, the Alliance for Green Heat and the Biomass Thermal Energy Council (BTEC) co-hosted a webinar with the EPA on how the new wood heater New Source Performance Standards (NSPS), which may be promulgated as early as 2014, may encourage or discourage innovation in wood and pellet stoves and boilers. The EPA's Gil Wood, Project Lead of the NSPS, provided an explanation of the new wood heater NSPS and answered attendee questions that had been requested in advance.
This webinar was held in the lead up to the Wood Stove Design
Challenge, a national competition to promote extremely clean, efficient,
innovative and affordable cordwood technology. The complete recording is below and the slides are available for viewing here.
Introduction: 0:00 - 7:54.
Presentation by Gil Wood: 7:54 - 46:33.
Q&A Session: 46:33 - 1:33:00.
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John,
ReplyDeleteI want to thank you and BETC for the webinar "How can the EPA encourage innovative new technologies?". However, the only good things I can see in the EPA review of the regulation is the intention to switch eventually to realistic cord wood instead of cribs for testing and to focus on the worst case burning situation. There is no mention of the owner's manual being recognized in respect to basic fueling protocol, i.e. coal bed and chunk size. If an innovator wants to design around cord wood, he has to pay for crib testing as well until it is abandoned. In discussing the webinar with a friend who attended the webinar and is much more knowledgeable than I about the industry, we both agree that the proposed regulation will kill the wood burning industry.
The biggest impact of the regulation over the past 25 years has been to discourage woodburning in general. This may be good for air quality in one sense, but it does not seem to be favored by environmentalists, the DOE or the US Forest Service. The increased cost of certified units has increased the value of old dirty devices. True innovation in terms of performance, cost and esthetic value has been discouraged. The EPA is concerned about its data base, but it involves an unrealistic testing protocol based on the best available technology 30 years ago. Rather than encouraging innovation, the EPA is in many ways dictating design. I believe it is time to start all over again.
Efficiency should be the focus of new regulation. The EPA intends to require its measurement but has not set any target. Its required hang tag for fireplaces and retrofit devices in its partnering program requires particulate numbers in grams per kilogram of fuel burned but does not say anything about efficiency. Would not consumers be more inclined to upgrade if the new appliance promised to double the efficiency---the same amount of heat and viewing pleasure with half the wood? Would this not be good for the environment?
The EPA intends to use the Canadian standard B415.1 to measure efficiency. It references a 1987 US DOE report and imposes a very complicated procedure on top of the unrealistic EPA fueling protocol. There has been a lot of innovation in ways to measure efficiency in the past 25 years. The EPA should stimulate (not dictate or fund) the development of portable test equipment for certification purposes as the Europeans have done. One big advantage of portable equipment would be its use in the innovation process. It could also be used by states and local authorities to bless or shut down existing wood burning facilities such as dirty outside boilers. This equipment could also include opacity measurement which should approximate the EPA's current particulate measurement. Innovators could incorporate the technology involved in low cost alarms to warn owners they are burning dirty or automatically adjust the burn. The certified laboratories could get back to what they really love---R&D.
In closing, I feel there is something basically wrong with our regulatory process. This review of a 25 year old regulation has been going on for a couple of years and is attempting to set passing grades seven years in the future. In an innovative environment, the industry and the consumers will assure progress. The regulators should be able to tighten the passing grade as indicated by current events without a big hassle. Whether this is due to the clean air act itself or the EPA, it should be simplified to reduce costs and encourage innovation. We also do not want to discourage world wide innovation and withhold its benefits from our consumers. Perhaps strict record keeping and a harsh penalty are needed for anyone importing units that have not been certified and quality controlled.
-- John G. Meeker, DBA Woodkiln
340 Kent-Cornwall Road
Kent, Connecticut 06757
860-927-3185 jgmeeker@charter.net