Tuesday, June 23, 2015

Technology Design Challenge to Promote Top Performing Pellet Stoves

A yearlong project to test and assess pellet stoves is entering its first phase this summer.  This first phase focuses on the most popular pellet stoves in North America and aims to help consumers identify the most efficient stoves and how best to operate them.

(The Pellet Stove Design Challenge is now accepting applications for innovative pellet stoves and individual participants at the April 2016 Workshop.)

The initiative is being led by the Alliance for Green Heat with a wide group of partner organizations and stove experts.  Pellet stoves are increasingly popular in North America and Europe, are far cleaner than wood stoves and have enormous potential to replace fossil heating fuel. 

2013 Design Challenge
in Wash. DC
The second phase of the project will feature an international stove technology competition to spotlight innovative and high performing pellet stoves and prototypes.  The project will culminate in an international gathering at Brookhaven National Lab in New York, where pellet stoves will be tested and the top performers will receive awards.  The focus will not just be on low emissions and high efficiency in a test lab setting, but also in the hands of consumers.  The application to submit pellet stoves and stove prototypes for the competition will be available later this summer.  The competition and workshop is scheduled for the week of April 4, 2016.

Ben Myren, Tom Butcher and others
in a lab at Brookhaven at the 2014
Wood Stove Design Challenge
This pellet stove challenge marks the third Stove Design Challenge, and the second to take place at Brookhaven. Previous challenges, including the inaugural Wood Stove Design Challenge on the National Mall in 2013, focused on promoting technological innovations that would help ensure wood stoves burn cleaner in the hands of consumers.  All the Stove Design Challenges involve stakeholder engagement in testing and assessing stoves, the opportunity to see and understand how testing works, and workshops and roundtables that bring together industry, regulators, air quality groups, non-profits and the media.

Phase one: Testing of Popular Pellet Stoves

There are approximately one million pellet stoves in North America.  Unlike the wood stove market, which has many manufacturers, most pellet stoves are made by just a handful of companies.  The Alliance will independently test some of the most popular models made in North America and Europe for emissions and efficiency.  The first round of tests will follow EPA lab testing protocols, while the second round will approximate how some consumers might use the stoves to better understand the range in efficiency when stoves are burned clean as well as dirty.  We will also test the stoves for noise level and ease of cleaning and repair. We may also test heat output and efficiency differences using high and low quality pellets.

Prior to both rounds of testing, the Alliance will explain what test methods and procedures are to be   used and seek input from industry and other stakeholders.  Testing will begin in an EPA accredited test lab and then move to Brookhaven National Lab.  The project expects to produce some data about the variability and reproducibility of emissions and efficiency in pellet stove testing. 

Planning meeting for the 2013 Design
Challenge. Pictured (left to right) Ray
Albrecht, Rod Tinnemore, Mark Knaebe,
John Ackerly, Melissa Bollman, David
Agrell, Norbert Senf, Ellen Burkhard  &
Tom Butcher. Photo: by Norbert Senf

To get better baseline data on some popular stoves, the Alliance for Green Heat submitted a Freedom of Information Act (FOIA) request to the EPA asking for emission and efficiency data for each of the four tested burn rates.  The Alliance also asked for moisture and ash content of the pellets used in the certification tests.  The EPA provided some of the data but issued a partial denial for efficiency values, pending a process to see whether the stove manufacturers will challenge the release of that information.

Funding for the ongoing Wood Stove Design Challenge initiative has been provided by the New York State Energy and Research Development Authority (NYSERDA), Osprey Foundation, the US Forest Service and the Alliance for Green Heat.

More information about this yearlong project will be posted on our website, blog, Facebook page and monthly newsletter.

Friday, June 12, 2015

Hearth industry lists grounds for lawsuit against EPA

David Chung is a
lead attorney for HPBA
Updated: June 17, 2015
The US Court of Appeals has consolidated four lawsuits against the EPA’s wood heater rules together into one lawsuit.  The four parties are the Hearth, Patio & Barbecue Association (HPBA), the Pellet Fuels Institute, Tulikivi and Richard Burns & co..

Consolidation means that the four parties opposing parts of the rule will likely have to write and share one brief (while sticking to the typical 14,000 word limit), unless they can convince the court that separate briefs are appropriate or that they should be granted more space. This usually means that the four parties need to pick only their best arguments and discard some smaller or less appealing arguments.  In practice, this means that the challengers won’t be able to throw “everything but the kitchen sink” at EPA.

HPBA filed its list of issues (PDF link) as required by the court, giving the EPA and broader hearth community a detailed look into exactly what HPBA will be challenging and what they hope to change in the NSPS.  Their three main areas are:

* The 2020 particulate matter emission standards for wood heaters, residential hydronic heaters and residential forced-air furnaces are arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.

* The “failure to include adjustments for test method precision” is in the compliance audit testing is arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.

* The ability of the EPA to use test methods and other provisions that are not developed through a consensus standard-making process.

HPBA’s challenge on stricter emissions standards in 2020 has been widely anticipated, but their challenge on EPA recognition of non-consensus test methods indicates that industry may be seeking more control over how indoor and outdoor boilers are accredited by the EPA.  At issue is the long simmering division between domestic outdoor wood boiler manufacturers and those companies importing and manufacturing European style boilers. 

The development of test methods for stoves and boilers have traditionally been dominated by the domestic stove and boiler industry through the EPA and/or ASTM.  The consensus driven ASTM process is open to anyone who wants to participate, but is dominated by HPBA insiders, experts and manufacturers. In recent years, New York State bucked that system by funding the development of an alternative test method outside the ASTM process that “is a major modification of EPA Method 28 WHH, intended to provide a method to evaluate a specific type of advanced wood heating boilers. 

The NSPS says that boilers certified by New York State or qualified under the New York’s Renewable Heat New York (RHNY) program are to be automatically deemed EPA certified to meet the Step 1 emission limits.  If HPBA is successful in its challenge, it is unclear if all of those units could lose their certification, giving HPBA member companies a big edge over companies who participated in the New York program, which are mainly non-HPBA members.

Despite the lawsuit by HPBA, a number of their member stove manufacturers are already reassuring their distributors and retailers that they will be able to meet the 2020 emission standards.  And, many, if not most companies are starting R&D efforts to meet the stricter standards because there is no guarantee that the suit will be successful and they cannot afford to do nothing for several years.  Even those HPBA member companies who do not agree with the lawsuit have to help pay for it.  The suit is funded by assessments on all member manufacturers.

Rick Curkeet
HPBA is also challenging the EPA’s “failure” to take test method imprecision into account.   Rick Curkeet, one of the key figures involved in the study that shows wide testing imprecision, recently explained the issue in a public paper. 

“Unfortunately the EPA has chosen to ignore the reality that the test process does not appear to be able to reliably distinguish emissions performance differences of several grams per hour. Indeed, it will take some very good luck in addition to high quality testing to obtain acceptable results. A possible means of reducing this risk is for designers to focus R&D efforts on getting repeatable results and not simply a low number.”
Tom Morrissey

Tom Morrissey, the owner of Woodstock Soapstone Stoves, a non-HPBA member, says Curkeet’s study is riddled with flaws and should not be relied upon by policymakers or regulators.

The Pellet Fuel Institute (PFI), headed by Jennifer Hedrick is challenging the authority of the EPA to regulate pellet fuel and to include ENplus and CANplus, since the EPA did not offer an opportunity to comment on their inclusion in the rule.  (PFI court filing, PDF)  It is unlikely that PFI would want the EPA to remove references to certified pellet fuel, as PFI has worked diligently for many years to establish the certification standard, with EPA involvement.  PFI may just want the EPA to recognize their third party standard, but not get involved in what ingredients and characteristics should be allowed.  Most PFI members who manufacturer pellets have not agreed to become part of the PFI pellet certification program and some of them use ingredients in their pellets which are not allowed by the NSPS.
Jennifer Hedrick

For example, one of the other litigants, Richard Burns & Co, is a PFI member, a pellet producer and also a recycler of construction and demolition debris, and retailer of #2 wood chips.  The NSPS does not allow plywood, construction and demolition debris, paper and cardboard and many other items to be used to make pellets. The court filings from PFI and Richard Burns & Co should be available soon.

Tulikivi, the dominant leader of factory built masonry heaters, is suing the EPA because the NSPS did not include them as a regulated technology.  Since nearly all categories of wood heaters are now required to be certified by the EPA, lack of certification for masonry heaters will become a market barrier.  (Tulikivi court filing, PDF.)

The U.S. Court of Appeals will likely to soon be studying both sides of this argument.  Several air quality non-profit groups have also intervened to help the EPA defend the rule and will likely be arguing that that Step 2 emission standards are realistic and achievable, and if anything, are too lax.

Thursday, June 11, 2015

US to begin mandatory survey of wood pellet varieties, volumes and ingredients

Rosalie Bianco founded Boulder-based
New Earth Pellets using bark beetle-damaged
trees to make the pellets.  Her company, like
others, will  have to start filling out this
survey in 2016. 
Dec. 2016 update - The EIA released its first data set showing production of wood pellets by state, region and capacity. Reports will be issued monthly.

June 2015 - The US government is poised to begin a monthly survey of pellet producers, much like it conducts similar surveys for coal, oil, gas, and other renewable technologies like solar panels.  The Alliance for Green Heat has been part of a coalition urging the government to include thermal biomass in reports, policies and data collection initiatives.

Some pellet manufacturers may say, “be careful what you wish for, lest it may come true.”  Efforts by the Pellet Fuels Institute and others to gather information about how many pellets are being produced each year have been met with resistance by many manufacturers. 

In contrast, response rates to surveys by the Energy Information Agency (EIA) are often 100% according to EIA staff because response to the EIA energy surveys is mandatory pursuant to Section 13(b) of the Federal Energy Administration Act of 1974.  Failure to respond to EIA surveys is punishable by significant fines.

The EIA-63C "Densified Biomass Fuel Report” will require any company that produces more than 10,000 tons (the EIA expects there to be about 150) to fill out the survey monthly, which the EIA estimates will take one hour to complete.  The EIA aggregates the survey responses and does not release any company specific data, a strict rule that follows with all energy surveys.

The EIA is an independent information agency within the Department of Energy.  Its long hallways are filled with wonky number crunchers who produce some of the most important data that industry and government rely on to understand energy markets.  Thermal biomass being selected at long last to join the club of major energy producers shows recognition of its contributions to heat homes and institutions across America is growing.

The EIA wants to know how much PFI certified and non-certified pellets manufacturers are making for both the bulk and bagged market.  For the PFI certified pellets, the EIA wants to know whether they are premium grade, standard or utility grade.

The survey also asks if pellets are being sold domestically or to foreign markets and even why plants may not be operating at full capacity.  The survey asks if extrusion machinery was not fully utilized, was it a shortage of raw materials, drying capacity, grinding capacity, or lack of a market for them?

As pellet exports for European electric plants have become more controversial, one relevant part of the survey covers the origin of wood fiber.  The survey lists 10 possible sources of fiber: from pulp wood quality roundwood to wood chips to logging residues to sawdust.  Then, it asks if this fiber is from a natural private forest, a planted private forest, or public land.  See more in chart below:

In addition to pellets, the survey includes other densified biomass such as wood bricks, wood logs and briquettes.  The results will likely show a rapidly expanding wood brick/log sector, which has the potential to produce far cleaner fuels than cordwood in residential wood stoves.  However, there is no quality certification process for these types of densified biomass in place yet, as there is for pellets.  As this market matures and supply begins to meet demand in upcoming years, there is likely to be more focus on the ingredients used in the fuel, just as there is now with pellets.

“This survey is a sign that the US government is taking thermal biomass more seriously,” said John Ackerly, President of the Alliance for Green Heat.  “Pellets can provide a clean and efficient alternative to fossil fuels to heat our homes and buildings.  We applaud the EIA for agreeing to undertake this survey so that all stakeholders can have a level of detail and transparency,” Ackerly added.

The survey has already been through one public comment period, where major stakeholders, including the Alliance for Green Heat, provided feedback and suggestions to the EIA.  It is now being sent out for a second 30-day public comment period.