New EPA Stove Regulations Begin Cleaner Chapter for Wood Heating

Statement by the Alliance for Green Heat on the Wood Heater NSPS

Key EPA architects of this NSPS include
Greg Green, left, and Gil Wood,  right  and
Amanda Simcox. Gil retired on February 3. 

Overall, the EPA did a good job and released a fair rule that includes many compromises between industry and air quality agencies.  We think these rules are good for consumers and will not drive prices up substantially for most product categories, but will result in cleaner and more efficient appliances that will ultimately save consumers time and money. This is our initial reaction to the rule, which we will be followed by a more thorough analysis.

High performance stoves: The EPA took some key steps to address the lack of recognition for high performing appliances. Notably, stoves that test with cordwood in the next 5 years can use a special EPA label that will alert consumers that the device is designed and tested for use like the consumer will use it. This shift is possibly as important than just lowering emission standards for wood stoves. Along these lines, the EPA is also allowing stoves that already meet the 2020 standards, to use a special label so consumers can more easily recognize these higher performing stoves. We are, however, very disappointed that the EPA removed the long-standing requirement that all stoves have a consumer hang-tag that helps consumers better appreciate the basic differences between all stoves on the showroom floor.

Boiler testing: Another positive step forward is EPA’s recognition of the European test method EN303-5 to certify European style indoor pellet boilers that have been accepted by Renewable Heat New York (RHNY). Also boilers certified by the New York State Department of Environmental Conservation (NYSDEC) will be automatically deemed EPA certified. This is another step to recognizing higher performance equipment. NYSERDA deserves credit for the R&D, test method and other funding that EPA and DOE should have been doing to develop higher performance equipment. These parts of the new EPA rule will help give consumers more options to buy cleaner and more efficient devices.

Stove emission standards: As expected, the EPA is staying with the de facto status quo for the next 5 years, at 4.5 grams an hour (g/hr). The 2 g/hr standard for stoves as of 2020 is fair and reasonable. As the EPA explained in the rule “nearly 90 percent of current catalytic/hybrid stoves and over 18 percent of current non-catalytic stoves” already meet the Step 2 emission limit of 2 g/hr. We hope that those manufacturers who have to redesign stoves use the opportunity to redesign to use cordwood and to reduce start-up and fugitive emissions. The optional Step 2 certification test for cordwood at 2.5 g/hr represents a very creative and positive approach by the EPA to move towards required cord wood testing.

Some independent stove and boiler companies played a vital role in broadening the debate and sharing key data sets that enabled the EPA to show that some stoves can already meet the Step 2 standards of 2 g/hr with cordwood. We are pleased that companies who participated in the 2013 Wood Stove Design Challenge helped the EPA and OMB understand that smallest manufacturers can undertake the R&D to make very clean and affordable stoves that operate well on cordwood.

Key issues not addressed: Some of the most important issues with wood stoves are difficult to address in regulations, such as indoor air quality from fugitive smoke and the ability for homeowners to reduce air-flow so much that the stove smolders for hours on end, which is often a nightly occurrence. Ultimately, we believe that some types of automation are needed to prevent the widespread consumer misuse of wood stoves. The attempt by the EPA to set a maximum emission level while the stove is on its lowest burn rate was a good start. We had urged the EPA to more formally address alternative tests for automated stoves that hold tremendous promise to reduce widespread poor operation by consumers.

Warm air furnaces: Delaying the standards for all warm air furnaces for 1 - 2 years was a mistake because some companies have little ability or intention of meeting the Step 1 standards. An interim measure after 6 months to distinguish between companies on their way towards meeting standards and those who aren’t would have been far better.

Exempt wood stoves: We are very pleased to see that the era of exempt wood stoves is over. About 1 out of every 3 or 4 new wood stoves sold in America has been exempt in recent years and EPA had considered a weaker standard for them, but is now holding them to same standard as all other stoves.

Masonry heaters: The EPA was not able to set standards for masonry heaters but we are glad to see that the EPA has charted a path forward to work with the Masonry Heater Association so that masonry heaters become a certified appliance category

Sell-through period: The sell-through period, set at 8 months through December 31st is fair for certified wood stoves, pellet stoves and qualified or EN303-5 approved boilers, but too long for exempt wood stoves and traditional outdoor boilers which should have come off the market sooner.

Electronic reporting: We were very glad to see that the EPA will begin electronic reporting for stove certification tests and provide more transparency for the public and access more data that is not Confidential Business Information (CBI) about stove tests.

Efficiency: Achievable efficiency standards are important in the near future and we are pleased that the EPA will finally require the manufacturers to test for, and report actual efficiency numbers not only to the EPA, but also on their websites. In practice however, many existing stoves many not have to retest for 3-5 years and it is unclear if they will have to disclose efficiency before then, unless they do it voluntarily. This is particularly important for boilers and pellet stoves that have a very wide range of efficiencies.

Renewable energy: We are very disappointed that the EPA did not mention the term “renewable” in this rule. The EPA Office of Air and Radiation should take into consideration that this sector has potential not just to make cleaner energy, but to use a renewable energy source and displace fossil fuels. Governor Cuomo’s Renewable Heat New York is investing tens of millions into the sector and integrates the goal of driving down emissions, driving up efficiency while replacing fossil fuels and offering homeowners an affordable, renewable heating source. In addition to setting minimum emission standards for lab testing, the EPA should adopt a more integrated approach to this technology that is being increasingly adopted not just by New York, but by other states as well.

In conclusion, the EPA crafted a fair and balanced rule overall and took some important steps towards testing with cordwood and recognizing those companies who take steps to build stoves based on how consumers operates them. In the long run, this new rule will result in cleaner appliances and a better foundation for renewable wood and pellet heating.

Full EPA rule and fact sheets

Wood and pellet stoves

Step	New PM emissions limit	Compliance deadlines
Step 1: All uncertified wood and pellet stoves (cat and non-cat)	4.5 grams per hour for crib wood test method If tested with cordwood, emissions test method must be approved, and stoves must meet crib wood limit	60 days after publication in the Federal Register
Step 2: All wood and pellet stoves (cat and non-cat)	2.0 grams per hour, or 2.5 grams per hour if tested with cordwood (test method must be approved)	5 years after publication in the Federal Register (2020)

Hydronic heaters

Step	New PM emissions limit	Compliance deadlines
Step 1	0.32 pounds per million Btu heat output (weighted average), with a cap of 18 grams per hour for individual test runs (crib wood test method) If tested with cordwood, emissions test method must be approved, and stoves must meet crib wood limit	60 days after publication in the Federal Register
Step 2	0.10 pounds per million Btu heat output for each burn rate, or 0.15 pounds per million Btu heat output for each burn rate. If tested with cordwood; method must be approved	5 years after publication in the Federal Register (2020)

Warm air furnaces

Step	Standard	Compliance deadlines
Step 1	Operational/work practice standards	60 days after publication in the Federal Register
Step 2	Emissions limit of 0.93 pounds of PM per million Btu heat output, weighted average. Cordwood testing is required for forced air furnaces	Small furnaces: 1 year after publication in the Federal Register (2016) Large furnaces: 2 years after publication (2017)
Step 3	Emissions limit of 0.15 pounds of PM per million Btu heat output for each individual burn rate. Cordwood testing required	All furnaces: 5 years after publication in the Federal Register (2020)

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