Wednesday, April 30, 2014

Summary of NSPS Comments from the Alliance for Green Heat

The Alliance for Green Heat is sharing its draft summary comments with all stakeholders to promote transparency and conversation and to solicit input on how we can improve our comments.  We also urge stakeholders to consider incorporating the points that you agree with, into your comments.  Please feel free to leave input or suggestions for the Alliance on this blog or if you want them to remain private, send to  Comments must be sent to the EPA by Monday, May 5.  Our final comments are now available here.

Alliance for Green Heat

Comments on
EPA’s Proposed Standards of Performance for New Residential Wood Heaters, New Residential Hydronic Heaters and Forced-Air Furnaces, and New Residential Masonry Heaters
Docket ID No. EPA-HQ-OAR-2009-0734

April 30, 2014 


The Alliance for Green Heat (Alliance), appreciates the opportunity to comment on EPA’s proposed New Source Performance Standards (NSPS) for wood heating devices.[1]  The Alliance is an independent non-profit organization that works with environmental and forestry organizations, air quality experts, the wood and pellet stove industry, and others in the wood burning community to promote high-efficiency wood combustion as a low-carbon, sustainable, local and affordable heating solution.  The Clean Air Act requires EPA to review and revise, if appropriate, the NSPS at least every eight years.  The Alliance strongly supports EPA’s decision to update the standards for wood stoves and to require a number of previously unregulated wood heating devices to reduce their emissions.  We also believe that the new standards, which reflect significant improvements in wood heating technology, are both appropriate and long-overdue. 

We have several suggestions for improving the proposed NSPS, which we outline below.
In our comments on the NSPS, we make the following points:
        First, it is important to recognize that wood heating is renewable heating and should be acknowledged as such by the EPA.

·         Second, the Alliance strongly supports EPA’s decision to issue revised performance standards for wood stoves and other wood and pellet heating appliances.
o   The Alliance supports EPA’s decision to close existing loopholes and to include all major categories of wood-fired heating devices in the new performance standards.  Previously exempted devices and devices above Step One emission limits should not be “grandfathered.”  
o   The Alliance supports a nine-month sell through for certified stoves that emit higher than Step One emission standards and a 2-year sell through for boilers or furnaces that are EN303-5 certified or EPA qualified.
o   In the next NSPS, the Alliance urges the EPA to regulate uncertified, pre-1988 stoves as new sources if they are installed in a new location.  Doing so will help to hasten the removal of the oldest, most polluting stoves from our airsheds.
o   In the next NSPS, the Alliance also urges EPA to regulate fireplaces.

·         Third, the Alliance believes that the proposed emission limits, though reasonable, could be more stringent for certain devices:
o   Data from currently certified stoves appear to justify a more technology-forcing, lower Step One performance standard for wood stoves.
o   Pellet stoves are clearly capable of meeting a lower limit for Step One.  The majority of pellet stoves certified by EPA are already emitting less than 2.5 grams per hour (g/hr).
o   Forced air furnaces could achieve a Step One emission limit of .48 pounds per million BTUs (lbs/MMBTU), instead of the proposed .93 lbs/MMBTU. A .48 standard corresponds to the pounds/MMBTU of a typical Washington approved wood stove.
o   In addition, although we believe a .06 lbs/MMBTU Step Two standard for pellet boilers is justifiable, this limit may not be appropriate for cord wood boilers, depending on the test method.   

·         Fourth, the Alliance strongly supports a shorter, five-year implementation period for the NSPS.  This deadline is both achievable and reasonable given the state of wood heating technology today.

·         Fifth, the Alliance believes that credible testing and enforcement are essential components of any New Source Performance Standard under the Clean Air Act (CAA).
o   The Alliance supports the proposed transition to cord wood testing, and calls on EPA to expand its cord wood testing program to obtain additional information on the performance of existing wood stove models using cord wood prior to promulgation of the final rule.  Alternatively, we urge the EPA to commit to re-examining the achievability of the Step Two standards for stoves that must be certified on cord wood before those standards become effective.
o   The Alliance urges EPA to establish a clearer path to certification for advanced technologies like automated stoves.  The Alliance is also encouraged by ClearStak’s comments and urges EPA to consider some of the forward-thinking ideas put forth in those comments.
o   The Alliance supports EPA’s proposal to delegate some oversight and enforcement authority to the states, and urges EPA to improve the capacity of the Office of Enforcement and Compliance Assurance (OECA) to help ensure that state enforcement programs are effective and that manufacturers and retailers comply with the NSPS.

·         Sixth and finally, the Alliance believes that mandatory efficiency standards are needed. Greater efficiency is particularly import to low-income wood stove users because it can lower their heating bills by requiring less fuel to heat their homes.  Nevertheless, the Alliance supports EPA’s decision to gather more data on wood stove efficiency, with the understanding that future NSPS would set mandatory efficiency standards.
o   The Alliance strongly supports a requirement to post B415.1 HHV efficiency numbers on all wood heating appliances on the market within six months of the rule’s promulgation.  Models that are EN 303-5 certified or qualified by an EPA voluntary program should be allowed to use HHV numbers until they become EPA certified.
o   The Alliance opposes the elimination of the hangtag requirement and urges EPA to consider additional consumer information resources such as a Green Label and state incentives for changing out old stoves and installing the most efficient new stoves.
o   The Alliance agrees that both particulate matter (PM) and carbon monoxide (CO) emissions data, as well as efficiency data, should not be considered Confidential Business Information (CBI), and urges EPA to make emissions and efficiency data about all four burn rates public on its website.
o   The Alliance urges EPA to immediately begin requiring manufacturers and labs to scan and electronically submit all paper data submissions, even as the agency works to develop a more streamlined Electronic Reporting Tool (ERT). 
o   Finally, to avoid misleading consumers further, EPA should also remove the “default” emission factor column from its posted list of certified wood stoves, and require manufacturers and retailers to stop using these default factors in their advertising materials.

 We appreciate your attention to our comments and look forward to working with EPA to successfully   implement this important rule.  The full text of our comments is below.

[1] Standards of Performance for New Residential Wood Heaters, New Residential Hydronic Heaters and Forced-Air Furnaces, and New Residential Masonry Heaters, 79 Fed. Reg. 6,329 (Feb. 3, 2014) [hereinafter “Proposed Rule”].


  1. Testing has shown that poor maintenance can degrade a good stove's efficiency. Poor stove operation also can contribute, especially if the stove is run too cool. The same can be said for burning poorly seasoned wood. Perhaps another requirement should be adequate documentation of annual maintenance procedures, running temperature, thermometer location, and wood moisture measurement to all stove manuals.

    1. Begreen,
      Thanks for those suggestions. We have some detail along those lines in our comments already, but we will beef them up. I expect the EPA will be very receptive to that, as would manufacturers. We understand some states are including comments like that as well.

  2. I don't see anything that reverses exemption of gas and coal burners and I would like to know who is going to pay for all of this. In light of the fact that at least one manufacturer has closed their doors (Thelin Hearth Products) and some retailers as well I am not supportive of this nor do I believe is the HPBA. Obviously our stoves are already beating the proposed 1.3 gramps per hour as a non cat stove but my biggest fear is that this will close more businesses. I believe the best thig we an do to help the environment is stop creating more people living in the poverty zone as by nature poor people are hard on the environment

  3. Your concerns about jobs and businesses are on everyone's minds and very important. We think this could have a positive impact on jobs in the hearth industry, but some businesses will lose jobs and others will gain them. To your last point, I think there is lots of research showing richer people tend to have a much larger carbon footprint because they tend to have bigger homes, take more flights, buy more stuff and generally use more energy. That is certainly true with household energy consumption. Would be very interested to see any other trends.

  4. Efficiency must be specified as "thermal" otherwise hydronic heater manufactuers will continue to deceive consumers saying that their devices have 100% combustion efficiency. Most people don't know the difference. And EPA has to ensure that efficiency is defined as "thermal" not "combustion."