Friday, July 19, 2019

EPA finds lapses in cord wood certification test reports

A Regency stove being tested at RFS labs
for 2020 compliance using the Alternative
ASTM E3053 cordwood method.
The EPA recently sent a memo to wood heater test labs and third party certifies about significant lapses in documenting certification tests using the cord wood test method and potentially significant lapses in cord wood testing.  We reproduce the memo below.  The memo does not specify which labs and which manufacturers are involved and the EPA is not making that public as of now.  The manufacturers involved are being contacted to have labs submit paperwork to the EPA, via third party certifies, who also could have caught the lapses before forwarding documentation to the EPA.  Some stoves may have to do the cord wood emissions tests again.
A Kuma stove using the ASTM
test method at Omni labs
AGH supports a transition to cordwood testing under the assumption that stoves tested with cordwood are more likely to burn more cleanly in the hands of consumers. But cordwood testing of stoves in the United States is still in its infancy and so far there is only the ASTM E3053 test method.  There are still many, many questions about whether the ASTM method can help achieve the emergence of a class of wood stoves that truly operate better in peoples' homes.
AGH asked the EPA to provide us with the memo to test labs when we heard about it.  The EPA promptly sent it to AGH but more often than not, we do not know about memos that go to labs, HPBA and manufactures.  EPA rarely shares many
A Travis stove using the ASTM cordwood
method at Omni lab.
such memos with the wider stakeholder community, that also includes stove retailers, state air quality agencies and others.  We believe documents such as this should be made routinely available by EPA without anyone having to file a freedom on information act request.   
Documentation from test labs to show stoves meet certification requirements go to Rafael Sanchez at the EPA Office of Enforcement and Compliance at EPA's headquarters in Washington DC.  This memo came from a review done by Steffan Johnson, based in Research Triangle in North Carolina.  Mr. Johnson is the Group Leader for the Measurement Technology Group at EPA's Office of Air Quality Planning and Standards,  the Measurement Technology Group provides national leadership in furthering the science of characterizing and measuring air pollutant emissions from industrial sources and is the EPA's focal point for producing validated emissions test methodology.  The Group also provides expert technical assistance for EPA, State, and local enforcement officials and industrial representatives involved in emissions testing.
From: "Johnson, Steffan", EPA
Date: 6/13/19 4:18 pm
To: all EPA Approved Wood Heater Test Laboratories and Third Party Certifiers,

In reviewing some recent test reports that have been submitted to EPA with the intent to certify a wood heater to the Subpart AAA cordwood emissions standard, there are some discrepancies and concerns that we are observing, and we will be asking some manufacturers to revise and resubmit a corrected compliance test report.  At least one of these concerns (noted below) is critical and may require re-testing.  All of these items are important enough to request a corrected report, and we wanted to let all of you know just why you may be contacted by your client(s) with such a request.

  1. We have seen a number of test reports using the Alternate Test Method and ASTM E-3025 that do not identify the species of cordwood used for the com pliance testing.  While it is true that the ASTM method allows selection from a wide list of wood species, the test report must identify the species of fuel used.  This is specified not in the test method but in the General Provisions to EPA 40, Part 60.8 (f)(2) which governs content that must be included in the test report. Paragraph (iii) of this section reads:  “(iii) Description of the emission unit tested including fuel burned, control devices, and vent characteristics; the appropriate source classification code (SCC); the permitted maximum process rate (where applicable); and the sampling location.”

We are asking that test reports that did not identify the wood fuel species burned during a compliance test submit an amended test report to this Agency.  If you are a third party reviewer and have certified such a test report, we request that you include this item, along with other items listed in the General Provisions, in your review checklist. 

  1. We have seen some test reports that reference “manufacturer’s instructions” for conducting the certification test, yet those instructions were not included in the test report.  The requirement to submit this information is to comply with the General Provisions of 60.8(b) and (c).  The guiding principle here is that ONLY the EPA Administrator has the ability to modify a test method for any reason, and these manufacturers instructions do NOT supersede the test method.  Also, the National Stack Test Guidance Document (available here: clearly states that the emissions test report “must demonstrate all information from the test lab such that it is a stand-alone document capable of reproducing the entirety of the test results”.  As such, all information pertinent to the operation of the appliance during the testing must be included in the test report (per 40 CFR 60.534). Also, as such instructions are relevant to how the testing was conducted, this documentation is not Confidential Business Information (CBI). 

We are asking manufacturers that have issued test reports where the manufacturers provided instructions to the test lab regarding appliance operation during the test, and that documentation was NOT included in the emissions test report available to the public, to take corrective action and submit an amended test report to this Agency.  If you are a third party reviewer and have certified such a test report, we request that you now include this item, along with other items listed in the General Provisions, in your review checklist.

  1. We have seen some test reports that contain manufacturer’s instructions that may run contrary to the test method and rule requirements.  Specifically, we have seen instances where manufacturers have directed laboratories to conduct low load testing with air inlet damper settings at “specified distances from fully closed”, meaning that the unit may not be getting tested at the lowest operating rate that a homeowner will have access to during the course of normal daily operation.  Testing at the lowest setting a consumer will be able to operate the appliance in their home is specifically required in 40 CFR 60.534.

Test labs and third party certifiers who are conducting /observing testing where manufacturers provided such instructions AND where you have knowledge that such devices are capable of combustion with air inlet dampers more fully closed than those setpoints specified by the manufacturer review the rule requirements with their client(s) and either select the lowest available setpoint or modify that stove model to fix the lowest available air inflow setting at that specified point, to remain fixed thereafter.  Furthermore, we insist that laboratories and third party certifiers add the requirement(s) of 60.534 to their checklists and take necessary steps to not look past this requirement in the future.  Appliance models found to have been tested in this manner and subsequently certified, will need to be reviewed by EPA on a case-by-case basis.  As a reminder, third-party certification is an attestation that all testing was conducted as specified in the regulation; certification of testing that does not meet the regulatory requirements may result in loss of EPA Approval status.  

  1. We have seen some test reports where cordwood fuel is used to demonstrate compliance, and the dimensions of the “cordwood” very closely match the dimensions of crib fuel.  While we recognize that it may happen that occasionally a wood splitter would produce a piece where the minor cross section is nearly equal to the major cross section of the fuel piece, we expect that this happens infrequently and is not normal for every piece in a fuel load. 

We ask that labs and third party certifiers use pieces that approximate hand-split fuel and not something that seems to be far more selective.  While fuel pieces are ‘selected’ for the test based on size and weight and, to some extent, dimension, we expect to see fuel loads that are more random (in terms of piece-to-piece comparisons) than not.

As always, thank you for continuing to support the EPA Wood Burning Appliance Certification Program.  Please do not hesitate to reach out to us and ask questions, any time, with respect to any certification testing you are undertaking; we are happy to offer our technical direction to help you, and your clients, meet the subpart AAA and QQQQ regulatory requirements.

My best regards,

Stef Johnson

Steffan M Johnson | Leader – Measurement Technology Group | US EPA Office of Air Quality Planning and Standards | Air Quality Assessment Division | 109 T.W. Alexander Drive, RTP, NC  27710 | Mail Drop: E-143-02 | Phone: (919) 541-4790  | Cell: (919) 698-5096


Thursday, June 20, 2019

Danish stove industry looks to compete, grow in America

This award winning Aduro stove accepts
wood and/or pellets and can switch
between them automatically.
Companies must navigate and anticipate shifting regulations on multiple continents

The Danish stove industry is known for sleek, vertical, expensive stoves. There is a joke that they are made to look like high end furniture that happens to hold a fire. But amidst this new wave of modern design is an industry that embraces innovation, competes worldwide to heat homes and has many budget line models.  

Danish stove makers tend to be skeptical of catalysts, very comfortable testing with cordwood, committed to quality and adaptable to the preferences and requirements of different countries. Danish stove manufacturers also have their own EPA-approved test lab at the Danish Technological Institute, one of three European labs that are now approved for EPA certification testing.    

John Ackerly, AGH President
with Jes Sig Andersen and Anne-
Mette Frey of DTI. AGH photo
One of the most exciting new Danish stoves burns both wood and pellets. It can run off pellets, just like an ordinary pellet stove, but then you can load the firebox with cordwood, drastically reducing start-up emissions. When the wood fire dies down, it will automatically revert to pellets. The stove is made by Aduro, a major European manufacturer that has not yet entered the US market but will likely do so.

Danes do not appear as intimidated by sensors and smart control systems as their American counterparts. They may appear on the market quietly, with little fanfare, and possibly without the consumer even knowing what’s under the hood. Since they require very little power, they may just have a couple batteries and don’t have to be plugged into an outlet. The trick is to get those sensors past the 2020 emissions standards with or without using a single burn rate test.

Aarhus – the stove capitol of Europe

No city in Europe is surrounded by as many stove manufacturers as Aarhus, the second largest city in Denmark. It is located on the mainland, just a few hours north of the German border. Brands well-known to North Americans include Hwam, Rais, Morsø
Aarhus is on the Jutland Peninsula, the 
Danish mainland, an academic center 
and Denmark's the second largest city.

 and Scan, but the city is also home to others that are as big or much bigger, including Aduro, Heta and Termatech. All these brands are present in many if not all European countries.  

Aarhus is centrally located with wind turbines and biomass district heating plants dotting the surrounding countryside. The hundreds of small biomass district heating plants pipe hot water underground to virtually all homes in cities, towns and suburbs. The extensive network of district heating is one of the main reasons that Danish stoves tend to be small.  Most homes already have affordable and renewable heat. Rural homes that are not on the district heating grid usually have pellet boilers, made by one of the many Danish pellet boilers companies. Danes also have innovative boilers for farms that use hay bales, another novel technology that could have a market on America’s farms.

EPA’s 2020 emission standards and foreign stoves

Danes have always tested their stoves with cordwood (only Norwegians test with cribs). The ASTM cordwood standard that allows up to 2.5 grams an hour appears to be achievable, according to Danish manufacturers. EPA certification has always been considered the gold standard in Europe and is universally accepted as the hardest test a European stove can pass.  
Jes Sig Andersen of DTI lab in Aarhus,
 left, with a technician at the Rais lab. AGH photo

The 2020 standards make it even harder for manufacturers. Danish stoves “can’t be tweaked, they need to be redesigned,” says Jes Sig Andersen, a senior specialist at the stove test lab at the Danish Technological Institute (DTI). The entire system that delivers primary and secondary air has to be reengineered and optimized to ensure maximum combustion of particulates through primary oxidation, secondary pyrolysis and often tertiary combustion. Getting that just right is a challenge even for seasoned combustion engineers, who have spent their professional lives designing stoves for the laxer protocols required in Europe.  

At a seminar hosted by DTI on stove and boiler testing, AGH President John Ackerly presented a powerpoint (PDF) on the current state of EPA regulations, potential changes, and other cordwood test methods that are in development.

Danish attitudes toward wood heating
The Danish landscape is dotted with
small biomass district heating systems,
which often use chips or hay bales.

There is an ambivalence toward wood heating in Denmark that is similar in many respects to attitudes in the US and in many European countries. Wood heating is often viewed as too polluting, a result of too many old stoves and poorly operated new ones. Pellet stoves comprise an even smaller part of the market here but pellet boilers are far more commonplace. In the capital city of Copenhagen, the mayor, like the mayor of London, is cracking down on cordwood stoves and plans to ban their future installation in part of the city. One of the largest crackdowns in Europe is in the Po River valley in Northern Italy where regular inversions trap wintertime pollution.  

The Danish government has had national change out or scrapping programs that provide a US $300 grant to simply remove an old stove, or replace it with a newer certified stove (it does not have to carry the Nordic Swan eco-label).

Vertical, clean lines and small fireboxes
dominate the Danish domestic market.
Because Denmark has a culture that looks down on overnight burns, extremely few models produced here have large enough fireboxes to do that. Some local jurisdictions banned overnight burning as it is almost synonymous with smoldering. Danes tend to want smaller stoves anyway, not as a primary or even a secondary heater as much as for the ambience. Younger Danes are more likely to install a gas stove or just a heat pump for space heating.

Danish automated stoves
The Hwam smart controller allows
the user to load and leave, and uses
sensors to adjust the air.

Aarhus stove maker Hwam was one of the first to design a fully automated stove, with an Intelligent Heat System (IHS) which competed in the first Wood Stove Design Challenge in 2013 in Washington DC. That stove helped revolutionize the concept of what a wood stove can be, and how it can be assured of operating cleanly in the hands of consumers.  Other Danish manufacturers have also used sensors and controllers that will be coming out in future models. The Hwan IHS has held its own in the marketplace, but price conscious consumers still prefer more basic, cheaper stoves.

The Aduro hybrid that burns both pellets and cordwood uses automation by necessity, so that it knows when the operator has loaded cordwood and when the stove needs to switch back to pellets.  

Henrik Norgaard, CEO of Rais
explaining their upcoming automated
stove that gives consumers confidence
in clean during technology. AGH photo

Rais has an automated stove in development that pairs Maxitrol controls with smart phone connectivity to allow users to monitor and adjust it. Basic automation can also prevent overfiring on one extreme and extended smoldering on the other, a key safety features that may catch on in the marketplace. 

A German company, Thermoelect, is marketing their automated stove in Denmark, looking for buyers who desire heat, domestic hot water and reliable electricity from a very clean burning system. That stove won first place at the 2018 Wood Stove Design Challenge in Washington DC based on its efficiency, emissions, electric output and innovative design. 

A key question is whether local and national governments will support the advancement of automated stove technologies that help stoves operate better in the hands of consumers. Automation should be
Horst Erichson holds the trophy his
automated stove won at the 2018 Wood
Stove Design Challenge. Rene Bindig
from the German Biomass Research Centre
consulted on the firebox design. AGH photo
able to help stoves pass stricter emission standards such as the EPA’s 2020 standards. Otherwise, there may not be sufficient incentives for stove manufacturers to build stoves that do much more than operate well in the test lab.  

European Union 2022 Emission Directives result in weaker emission limits in northern Europe

A weakness of European wide emission standards for wood stoves is that they are the product of a
negotiation between countries with stricter standards, and countries that have no standards at all.  One of the key purposes of the Union is to harmonize standards so that goods can flow freely between all EU countries, which means that countries cannot maintain stricter standards than others. For countries like Denmark and Germany, this can result in having to weaken emission standards. The 2020 EU Eco-Design Regulation calls for a maximum of 40 mg/cubic meter for wood stoves and 20 for pellet stoves. Denmark already requires a max of 30 and most stoves are in the 10 – 20 range. Denmark may be able to negotiate keeping their stricter standards which would also result in keeping some stoves made in other countries out of their market. But the more powerful European stove industry associations may block a country’s attempt to keep stronger standards so that they can build stoves to the laxer standards. 

One reason that European stove testing protocols are laxer is that they typically only have to test at a nominal heat output rate. They do not have to test at their lowest air setting or heat output rate. They also allow fueling to be based on manufacturers’ instructions and do not require the stoves to be filled with nearly as large loads as EPA protocols. However, there are national variations and the Norwegian national protocols required testing at 4 burn rates and with crib wood.

beReal and IDC testing protocols
Round robin testing of the same stove in different labs and
settings shows emissions are often double or triple in the real
world compared to lab testing. 

Danish stoves for export to the US are much more likely to be tested with the ASTM cordwood method, which should make them somewhat cleaner in the hands of consumers. But using cordwood and including start-up emissions is just the beginning of innovation needed in test protocols. Stricter PM limits only result in cleaner stoves if there is a level of integrity in the test method that does not exist in Europe or North America. On both continents, industry has played a big role in writing the test methods and labs in both continents have a financial stake in making sure their clients pass the test.  

The need for more real-life test methods is just as obvious to Europeans as it has become for Americans. Even before NESCAUM began developing Integrating Duty Cycle test methods, European began beReal, a very similar process to understand the weaknesses of existing lab testing and move towards a method that would result in stoves being designed for consumers, not for test labs.
An early overview of the IDC protocol
under development by NESCAUM.  The
protocol had early input from HPBA but
 they have since dropped out of the process.

A ground-breaking 2018 report, “Advanced Test Methods for Firewood Stoves” by Christoph Schmidl and Gabriel Reichert, concluded that “Real-life oriented test concepts (e.g. beReal) are capable to reflect the real-life performance of the appliances better compared to existing EN standards. An implementation of a real-life oriented test protocol as a quality label or standard should be considered as an instrument to push technological development towards optimized real-life operation and to enable a better differentiation of good and poor products for the end customer.” 

Marius Wohler, manager of the beReal
initiative speaking at the 2016 Pellet
Stove Design Challenge at Brookhaven
Nartional Lab. AGH photo
The authors suggest that establishing a voluntary test method that could be used as the basis for an eco-label could justify the costs of developing the method and provide an incentive for stove manufacturers to test to it. Wood stove eco-labels, while common in Europe, are not supported by the wood stove industry in the US, which has never had any eco-label for stoves.

The adoption of more realistic and effective test methods based on the European beReal initiative or the American Integrated Duty Cycle approach will face headwinds. Regulators may not have the time, expertise or motivation to engage in a major test method shift, and industry may resist leaving charted waters that they know how to navigate for seas that may pose tougher challenges. But both continents have persistent stakeholders and face air quality and renewable energy targets that require technologies to operate cleaner in the field, not just the lab.

Compliance audit testing or "market surveillance"

Regulators on both continents also realizing the need for compliance audits, called “market surveillance” in European parlance. Without effective oversight of test lab results, a culture of artful, possibly legal, manipulation of test protocols can grow in labs.  Once the culture exists in one lab, other labs need to follow to keep their clients from going to labs who can help stoves pass more easily.  The Alliance for Green Heat wrote about this danger in 2015 in the wake of the Volkswagen testing scandal. That scandal involved a emission testing defeat device, but it also uncovered an old boys network that stayed quiet about a culture in labs that is driven more by client pressure and expectations than government-approved test protocols.

Under the U.S. Clean Air Act, the EPA has authority to conduct compliance audit testing of stoves
A page from a 2017 Belgian list
of stoves whose sale was banned
after audit testing was performed.

and revoke a certification if the particulate matter exceeds the original lab test by 50% or more.  That provision is under litigation by HPBA and other stakeholders agree that if the PM is below 1 gram per hour, 50% is too strict given the variability of solid fuel testing.  European countries have similar compliance laws, and Belgium has begun to conduct audit testing and cracking down on stoves that it believes may have exaggerated test numbers.  They issued a seven-page document, "List of devices tested in the laboratory" (pdf) that banned the sale of nine mostly Spanish Panadero stoves in Belgium based on discrepancies in PM or CO between the certification lab and the audit lab.  

Panadero is a family run, mass market value stove manufacturer that like many other companies
The Panadero website shows the eco-
labels that some of its stoves carry.
claims to have met the 2022 standards for all its stove in 2018.  In addition, some Panadero stoves carry the French Flamme Vert and British HETAS and other eco-labels.  They apparently do not qualify for the Nordic Swan or Blue Angel.  Most of the stoves found to have a large PM and/or CO variation in 2017 Belgian audit compliance tests appear to be out of production as of 2019. One that is still in production, the Luis, does not claim to meet any European eco-labels.

Can Danish stoves gain traction in the US market?

Vertical, stylish European stoves led by Danish companies have been slow to catch on in the US market. But the entry of Danish value stove makers could change that. They already make more horizontal style stoves with larger fireboxes for the British and other markets. Danes could have a real advantage with sensor-equipped stoves that have sensors that take some or all of the “idiot factor” away from the operator. If tests can better show the value of these stoves, then it will be up to federal, state and local jurisdictions to find ways to help pave the way for them to proliferate. The recent funding opportunity from the US DOE is clearly looking for R&D in automation, and that may be a tipping point for automated stoves. Danish companies are not eligible for that, but they are well-positioned to benefit from any trend in that direction. 

European stoves may also be a beneficiary if the trade war between the US and China escalates.  
Many Danish export stoves are
more horizontal and have larger fireboxes
for Eastern European and British markets
Tariffs on steel and parts such as fans could impact American manufacturers far more than European ones, which could benefit Italian pellet stove manufacturers, for example.  

Regardless of their share of the US market, Danish stoves represent an enduring aesthetic. They are also expanding into Eastern Europe, where some of them are manufactured, and where cleaner, more efficient stoves are needed far more than North America and Western Europe. It is difficult to know how regulations, innovation and energy demands will impact wood stoves, but Danish stove makers are likely to be on the forefront of those changes.

Friday, May 17, 2019

EPA releases long-awaited searchable wood heater database

A screen shot of part of the
navigation of different fuel types
in the new EPA database
Consumer friendly site is cause of worry for some

Updated May 30 - This week, the EPA released its long-awaited searchable stove and central heater database, overhauling a decades-old practice of using basic excel sheet lists.

The EPA said the new database was designed to“improve accessibility and usefulness” by allowing users to search for the cleanest stoves, the most efficient stoves, those designed to burn cordwood and other attributes.

A wide range of stakeholders, from industry to states to non-profits, had been urging the EPA to switch to a modern searchable format for nearly a decade. The painfully slow development of the database at times seemed to epitomize the government's reputation to move at a snail’s pace. The list is maintained by the EPA’s Office of Enforcement, which like much of the EPA has been hit with repeated budget cuts and loss of staff in recent years.

The sleek new functionality of the list, allowing users to focus on one parameter or another, is also worrying to many in the stove industry. Traditionally, this list of certified wood heaters has not been a primary information source for consumers. But with this new functionality, consumers may start relying on it more and more, leading to some unintended results, such as worse buying decisions or ones that favor some manufacturers over others.  One feature that the old excel spreadsheets had that will be particularly missed by many was the clear designation of which stoves were newly added to the list each time it was updated.

One fear is that consumers will put too much reliance on higher BTU output if they can easily search and cross reference by these values. Right-sizing a stove is already problematic, and the BTU values on the list are overinflated due to loose parameters that allow labs to show high BTU output. Another fear, expressed by some manufacturers at the recent HPBA Expo in Nashville, is that consumers will favor “Cord Wood” stoves over “Crib Wood” stoves because they are not familiar with the lexicon of stove testing and the legacy of crib wood. This could lead to a surge in the sales – and reputation – of the 10 models that have been designed for and tested with cord wood. Other stakeholders welcome the feature, hoping that the companies who were among the first to invest in cord wood testing will benefit.

The EPA chose to include a box that helps consumers identify the cleanest and most efficient stoves,
and some say that this puts unwarranted attention to values that won’t necessarily translate from the lab to the home. This “Quick Searches” box will likely be used by consumers who don’t understand pellet stoves work similarly in the home as they do in the lab, but wood stoves can only achieve the optimal lab numbers with a large bed of coals, dry wood and careful operation.
This “certified fuel type” feature also sheds light on one the biggest problems with the new searchable data – accuracy. Six wood stoves are listed as using wood chips as a fuel, an apparent mistake according to one of the manufacturers of those stoves. This could hurt sales of those units if consumers are relying on the database to narrow down the stoves they may purchase. EPA staff are quick to say that this is a work in progress and it is incumbent on manufacturers to vet the list and provide the EPA with corrections. In 2017, the HPBA warned the EPA that many inaccuracies – such as stoves being listed as wood chip stoves – existed in the database. Many of the same errors are still listed two years later.

The Alliance for Green Heat welcomes the new database and had the opportunity to provide input on several occasions as other stakeholders did. Some of our suggestions and wording was adopted and some was not. AGH believes that the new database will help consumers become more educated about the working of stoves and the terminology, but it will take time and effort by the wood heating community.

The release of the database was coordinated with the update of some key pages on the EPA's Burn Wise website. The EPA finally changed their page on hydronic heaters which previously defined and pictured them just as outdoor boilers, a change that AGH had urged them to make for years. They also made major changes to their efficiency page which had not been updated since the EPA began requiring testing and reporting of efficiency of stoves.

Features and functions

·      Pellet stoves
A simple search that used to take hours, now takes seconds.  For instance, with 5 clicks, the database shows that 40 of the 70 pellet stove models that are 2020 compliant emit one gram an hour or less – an impressive feat considering pellet stove lab values are relatively consistently with how they perform in homes. 

·      Catalytic Stoves
The database shows that 27 of the 68 wood stoves that are 2020 compliant are catalytic, underlining the surge in catalytic models that resulted from stricter emission limits.  

·      Hybrid Stoves
Wood stoves are divided into three
subtypes - cat, non-cat and hybrid - but
hybrid stoves are not yet listed
Hybrid stoves, which almost all use both catalysts and air tubes for secondary combustion, are listed as a subtype, but no stoves turn up in a search for that term.  It is unclear if the EPA intends to populate that subtype. AGH is urging the EPA to also add “automated stoves” as a subtype in the future. Both hybrid and automated stoves offer great promise to help consumers run stoves more cleanly and should be identified in the database.

·      BTU Output
With tighter homes and a new breed of tiny homes, it is now easy to search for stoves with the lowest BTU output. Forty stoves, 20 wood and 20 pellet, were tested at less than 25,000 BTU. AGH believes that many units still have erroneously high BTU values based on loose parameters in lab testing and reporting, and these values should be used with great caution.  For wood stove, firebox size is probably a more accurate indicator of BTU output.

·      Efficiency
The EPA has chosen to use the term “overall efficiency” instead of simply “efficiency.” Some manufactures use “optimal efficiency” or “maximum efficiency” instead of publishing the EPA tested efficiency, which is lower. The database quickly shows, for example, that 37 of the 70 pellet stoves that are 2020 compliant are 75% efficiency (HHV) or higher – another great improvement compared to the performance of pellet stoves just 5 years ago.

·      Carbon monoxide
Nearly 150 stoves that are 2020 compliant have CO values showing a huge range from 0.0 to 6.1. Of the 23 stoves tested at less than 0.1 gram of CO per minute, all but 3 were pellet stoves. The carbon monoxide listing raised concern from some who worry that consumers may use it instead of PM as a primary indicator of cleanliness, or that consumers may think it’s an indication of amounts of CO emitted into the room.

·      In and out of production
The database shows 565 models in production, a number that will likely drop significantly as of June 2020. And it has nearly 700 stoves that emit less than 4.5 grams but are out of production.

·      Previously certified
The database also shows the 205 stoves that were previously EPA certified at 4.6 grams or higher, a feature that could be very helpful for change out program managers who want to target older certified stoves, many of which need replacement.

·      Key terms and definitions
The EPA provides a new page with definitions of key terms such as adjustable burn rate vs. single burn rate heaters, fireplace insert, wood pellets, etc.

·      Central Heaters
The database is separated into two: “Room Heaters” and “Central Heaters” and you have to select one or the other or your search may turn up empty. There are only 12 central heaters that are 2020 compliant, and eleven of those use cord wood. While central heaters have had a harder time meeting the Step 2 requirements, many more have either been approved by labs or are in the pipeline to be 2020 compliant.  Efficiencies of pellet boilers are more complex because those that get listed with European test data are likely to show higher efficiencies, even though they are converted to HHV. 
Not included in the new database

Some stakeholders have urged the EPA to include more search attributes, such as the test method, lab, and a link to the detailed lab report that manufacturers are required to post on their websites. The list also does not say whether PFI certified pellets were used during certification testing and are thus technically required to be used by the consumer.  Up until 2007, list used to include the deadline that the five year certification certificate expired.  Up until the summer of 2015, the list included the outmoded estimated default efficiencies, which listed all non-cats at 63%, cats at 72% and pellet stoves at 78%.  The default efficiencies were set based on testing in the mid and late 1980s, resulting in relative accurate estimates for wood stoves, but helping to develop the enduring myth that pellet stoves had such high average efficiencies.

Contact Rafael Sanchez at the EPA's Office of Enforcement to address errors or omissions in the database, ( at (202) 564-7028.