Excerpts of EPA's Final Rule on the 2020 wood heater regulations

On March 11 2020, the EPA finalized wood heater regulations, ruling that no "sell-through" period was warranted based on data supplied by industry.  
EPA rulings can be long and technical so we excerpted the key points in the EPA's final ruling on changes to the New Source Performance Standards for wood heaters.  While you may know that the EPA did not agree to a sell-through period for Step 1 heaters, you may not know that the EPA ruled that pellet manufacturers can use old pallets as fiber, or exactly why the EPA kept to its original timeline.  After the initial summary, the first half is about changes in pellet composition and the second half is about why they are not changing the timeline for appliance sales.  The other important document for those who are interested in more details is the EPA's Response to Comments from stakeholders and the public.  The document shows the EPA's findings and analysis on scores of contested issues from all sides. (May 5, 2020 update: due to the Coronavirus pandemic, EPA is trying to reverse course and allow a limited sell-through on a tight timeline.)

Key Excerpts of 

ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 60, RIN 2060-AU00 

Standards of Performance for New Residential Wood Heaters, New Residential Hydronic Heaters and Forced-Air Furnaces

AGENCY: Environmental Protection Agency (EPA). 

ACTION: Final rule. 

SUMMARY: In this final action, the U.S. Environmental Protection Agency (EPA) is amending the 2015 New Source Performance Standards (NSPS) for New Residential Wood Heaters, New Residential Hydronic Heaters and Forced-Air Furnaces. This final action removes certain requirements from the rule for pellet fuel to meet certain specifications regarding density, size, and content, while retaining a provision in the rule that requires EPA-approved third-party organizations to specify minimum requirements as part of the pellet fuel certification process. Also, in this final action, the EPA is deciding not to make changes that it had proposed that would have allowed a sell-through period for Step 1-certified residential wood heating devices that are manufactured before the May 2020 compliance date to be sold at retail after that date. Finally, this preamble provides a 

FOR FURTHER INFORMATION CONTACT: For questions about this final action, contact Rochelle Boyd, Sector Policies and Programs Division, telephone number: (919) 541-1390; and email address: boyd.rochelle@epa.gov. For information about the applicability of the NSPS to a particular entity, contact Rafael Sanchez, Office of Enforcement and Compliance Assurance, telephone number: (202) 564-7028; and email address: sanchez.rafael@epa.gov.

II. Background 

On February 3, 2014, the EPA proposed revisions to the NSPS and promulgated revisions on March 16, 2015. The final 2015 RWH NSPS updated the 1988 RWH NSPS emission limits, eliminated exemptions over a broad suite of wood heating devices, and updated test methods and the certification process. The market share for each of the categories considered in this final rule are as follows: wood and pellet stoves were 96 percent, hydronic heaters were less than 1 percent and forced air furnaces were 3 percent of the total.

The EPA took a two-step compliance approach, in which certain Step 1 standards became effective in May 2015 and more stringent Step 2 standards would become effective 5 years later, in May 2020. 

As the May 15, 2020, Step 2 compliance date approached, representatives from the manufacturing and retail industry expressed concern that a substantial number of retailers have either limited or stopped their purchases of Step 1-certified wood heating devices from the manufacturers due to concerns they may not be able to sell these devices before the May 2020 Step 2 compliance date and would, therefore, be left with unsalable inventory. Manufacturers also expressed concern that these reductions in sales would result in reduced earnings needed to develop Step 2-compliant model lines. 

On November 30, 2018, the EPA proposed a "sell-through" provision to give retailers additional time after the May 2020 effective date of the Step 2 standard to sell Step 1-compliant hydronic heaters and forced-air furnaces remaining in their inventory. The EPA also took comment on whether to amend subpart AAA for wood heaters and pellet fuel heaters to provide a similar sell-through period. In addition, the EPA took comment on whether the minimum pellet fuel requirements in the 2015 RWH NSPS should be retained or revised.

III. Public Comments 

Public comments on the 2018 proposed rule and the EPA’s responses to these comments are addressed in a separate Response to Comment document, available in the docket for this action at Docket ID No. EPA-HQ-OAR-2018-0195.

IV. What is included in the final rule?

A. Pellet Fuel Minimum Requirements 

The pellet fuel requirements, in addition to ensuring consistency with certification testing, were intended to safeguard against emissions hazardous to human health and the environment when the pellets are burned in pellet fuel heaters operated in the home by consumers. 

Since publication of the 2015 RWH NSPS, interested parties have raised issues concerning the pellet fuel requirements. First, these parties have questioned the EPA’s authority to promulgate the pellet fuel requirements. The EPA has considered these comments and concluded that the Agency has the authority to set pellet fuel requirements for the reasons discussed in the RTC. 

Second, interested parties have questioned the need for the pellet fuel requirements and commented that the specific minimum fuel requirements will inhibit innovations that may improve pellet fuel heater operation and decrease emissions. 

After reviewing public comments on these issues, the EPA [will] delete the following seven pellet fuel minimum requirements:

1. density: consistent hardness and energy content with a minimum density of 38 pounds/cubic foot;

2. dimensions: maximum length of 1.5 inches and diameter between 0.230 and 0.285 inches;
3. inorganic fines: less than or equal to 1 percent;
4. chlorides: less than or equal to 300 parts per million by weight; 5. ash content: no more than 2 percent;
6. contains no demolition or construction waste; and
7. trace metals: less than 100 milligrams per kilogram. 

The EPA is retaining the prohibition that was stated in the eighth pellet fuel minimum requirement that stated pellet fuel must not contain any of the prohibited fuels:

1.     residential or commercial garbage;
2. lawn clippings or yard waste;
3. materials containing rubber, including tires;
4. materials containing plastic;
5. waste petroleum products, paints or paint thinners, or asphalt products;
6. materials containing asbestos;
7. construction or demolition debris;
8. paper products, cardboard, plywood, or particleboard.
9. railroad ties, pressure-treated wood or pallets (40 CFR 60.532(f)(9)) and railroad ties or pressure-treated lumber (40 CFR 60.5474(f)(9));
10. manure or animal remains;
11. salt water driftwood or other previously salt water saturated materials;
12. unseasoned wood;
13. any materials that are not included in the warranty and owner’s manual for the subject wood heater; or
14. any materials that were not included in the certification tests for the subject wood heater.

Retaining this provision assures that these specified materials will be not be used as a source of fuel and prevents the burning of trash, plastics, yard waste, and other unsuitable materials. For most of the items on the prohibited fuels list, it is widely-recognized and widely-accepted that the burning of such material increases emissions regardless of the type of wood heating device. 

Interested persons have asked questions about how the prohibitions against “unseasoned wood” applies to pellet fuel. The EPA is clarifying that the determination of moisture content is made at the end of the manufacturing process, and the prohibition on unseasoned wood does not prohibit the use of unseasoned wood earlier in the pellet fuel manufacturing process

3. Clarification Concerning the Burning of Pallets and the Use of Pallets in Manufacturing Pellet Fuel

Interested parties have asked the EPA to clarify the scope of the prohibition on “pallets.” The prohibition on “pallets” bans only the use of pressure- treated pallets, because “pallets” is part of the phrase “pressure-treated wood or pallets” and the term “pressure-treated” is intended to apply both to “wood” and to “pallets.” 

B. Decision Regarding Promulgating New Sell-Through Provisions 

To justify a sell-through, the Agency first requires sufficient data from manufacturers and retailers demonstrating why a sell-through is needed. Insufficient data were provided by manufacturers and retailers to justify a sell-through, especially in light of the fact that in every residential wood heating device category, there are model lines certified to meet the Step 2 standards that are already available, and have been available for considerable time, which supports the conclusion that the Step 2 standards were achievable. For example, the record shows that, as of March 2018 (over 2 years before the May 2020 Step 2 deadline), there were Step 2-certified model lines available for each category of wood heating device (83 FR 61578). 

By contrast, manufacturers did not provide the Agency with information showing that any manufacturers have tried but failed to develop Step 2 model lines. Thus, there is no support in the record showing that manufacturers could not develop Step 2 models in time to: (1) have Step 2 models for sale as retailers reduced or discontinued their purchase of Step 1 models; and (2) allow for manufacturers and retailers to replace their inventories of Step 1 models with Step 2 models in advance of the May 2020 deadline. In short, the record shows that some manufacturers have tried and succeeded in developing Step 2 model lines but contains no adequately supported examples of manufacturers that have tried and failed to develop Step 2 model lines. 

Finally, it is important to note that manufacturers have had since May 2015 to develop Step 2-compliant wood heating devices, and that retailers have had since May 2015 to manage their inventory of Step 1-compliant wood heating devices and replace them with Step 2- compliant wood heating devices ahead of the May 2020 deadline. The record shows that Step 2- compliant model lines have been available to retailers for a considerable amount of time. For example, there were wood heater, pellet fuel heater, hydronic heater, and forced-air furnace models that were Step 2-certified starting in 20179 and, as of March 20, 2018, more than 2 years before the May 2020 compliance deadline, there were 78 wood heater model lines (44 pellet fuel heaters and 34 wood heaters), nine hydronic heater model lines and one forced-air furnace model line certified to Step 2 (83 FR 61578). Further, some model lines have emissions significantly below the Step 2 standard, showing not only that it is possible to achieve the Step 2 standard but also that manufacturers can develop models well below the Step 2 standard.10 Based on this record, the Agency has insufficient grounds to conclude that a sell-through period is needed and to change the established NSPS and allow a sell-through. 

Regarding the data necessary to justify a sell-through, the EPA solicited this information in the notice of proposed rulemaking (NPRM) by posing multiple questions to stakeholders while requesting comment on the proposed 2-year sell-through, including, but not limited to, the following queries: 

• whether retailers are currently declining to purchase Step 1-compliant wood heating devices and how widespread is this reduction in purchases; 
• the cost or other impacts that retailers could have on manufacturers if they decline to purchase Step 1-compliant wood heating devices; 
• the typical period of time between when a retailer purchases a wood heating device and when the device is sold to the consumer; 
• what period of time would be sufficient for retailers to sell their inventory of Step 1- compliant heaters; 
• the number of Step 1-compliant wood heating devices that are currently in production and the number that are being designed for Step 2 compliance that have not yet been EPA-certified; 

• the number of Step 2 wood heating devices that are currently Step 2-certified; and 
• how far in advance of the current May 2020 Step 2 compliance date manufacturers will need to submit their EPA certification applications to meet the standard as well as manufacture, market, and distribute their products without disruption to their business. 

While manufacturers and retailers made qualitative statements asserting economic harm from stranded inventory if a retail sell-through was not allowed, these statements were not supported by contextual data. In fact, commenters did not submit sufficient data to the Agency in response to the NPRM’s solicitations, and in particular, provided insufficient data showing a percentage decrease in sales approaching 2020 relative to previous years and/or the percentage of Step 1 inventory that would be stranded without a sell-through since the promulgation of the 2015 RWH NSPS. 

V. Summary of Cost, Environmental, and Economic Impacts 

The EPA believes that this action does not have disproportionately high and adverse human health or environmental effects on minority populations, low-income populations, or indigenous peoples. Because this final action does not have air quality impacts relative to the 2015 RWH NSPS, it will not alter the EPA’s prior findings that, on a nationwide basis, cancer risks due to residential wood smoke emissions among disadvantaged population groups generally are lower than the risks for the general population due to residential wood smoke emissions.

Andrew R. Wheeler, 

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Administrator

Coronavirus & the wood heating community: agencies, industry and consumers brace for impacts

The coronavirus tidal wave has begun to break, and consumers, industry and agencies will all be impacted. An economic shock in March/April --- one of the least active seasons for stove and fuel sales and installs --- would be the best possible timing for the wood stove industry most years. But this year, the pandemic hit virtually during the same week that oil prices fell off a cliff and the EPA made a final ruling that industry had not made a sufficient case for a sell-through for Step 1 heaters. 

 

In eight states, wood heating soared by more than 100%
as a result of a recession --- and a spike in oil prices.

The recession of 2008/09 provides some valuable lessons. Like that recession, the one hitting now will make consumers drastically cut back on spending. We don’t yet know how much this will impact the fall sales season but we can expect stove sales will be reduced.  In the 2008/09 recession, wood heating increased by up to 50% in many states – and so did wood smoke problems – but that was when oil prices were at an all-time high.

While wood heating increased drastically back then, wood stove sales stayed flat or declined. Tens of thousands of homes that had relied on other heating fuels now relied on their stoves far more. As the buying power of consumers dwindles, people hang on to their old stoves or even dust-off ones that had not been used much. AGH tracked this trend in a 2013 blog:

 “The surge in wood heating between 2000 and 2010 was partly due to reduced buying power and job loss. New studies show that lower income families have locked in that reduced buying power since the end of the recession … and is also likely contributing to the growth in the sales of less expensive wood stoves such as those sold at big box stores, compared to higher priced specialty hearth stoves.”

The health crisis may be under control by the fall, but the economic fall-out will likely be with us still. Last week, a record 3.2 million Americans filed for unemployment.  Thousands of those worked in the home energy sector.  Savings and retirement accounts ravaged by the stock market’s implosion will lead consumers to put off larger purchases, like stoves.  

 

As wood heating soared after 2008, sales of new stoves
drastically declined, with pellet stoves and boilers
more susceptible in changes to oil prices.

Pellet stoves sales will likely be hit even harder, as economic recessions favor wood stoves, where fuel is cheaper or free. Some families that have relied on pellet heat may turn back to cordwood if their budgets can’t sustain pellet fuel purchases. Factories making spare parts for pellet stoves, some of which are in Wuhan Province where the Coronavirus originated, are resuming operations after a 2-month shut down.

Most manufacturers and retailers are diversified. Gas stoves have taken over market share from wood stoves, and pellet grills have taken over market share from pellet stoves.  

Covid-19 poses a massive threat to the wood heating industry because it coincided with a historic free fall in the price of oil, not seen since 1991. With little prospect for oil prices to rise in the near future, the renewable heat sector faces the prospect of going through the winter of 2020/21 at a huge disadvantage. 

Coronavirus and the EPA Final Rule

The timing of the coronavirus outbreak also coincided with the EPA’s final announcement  that it was would not extend compliance deadlines. The EPA found that industry did not present any data to show "manufacturers could not develop Step 2 models in time" and "provided insufficient data showing a percentage decrease in sales approaching 2020." 

Inside EPA, an insider, subcription only publication noted this in its analysis: “The Trump administration is taking the rare step of rejecting an industry call to ease EPA emissions standards … [which is ] … notable for appearing to be at odds with the administration’s overall deregulatory agenda that has included softening many other agency air, water and other rules.” 

 

Gas appliances increasingly dominate the market for both
manufacturers and retails but they too will be hit by the
Covid-19 fallout. Source: Hearth & Home, April 2017.

Time had been working against industry, as manufacturers kept proving the Step 2 emission limits were reasonable by certifying stoves under 2 – 2.5 grams and boilers under 10 – 15 lb/mmBtu.  The same cannot be said of warm air furnaces, as only two models have been certified in the last 4 years. But no one could have foreseen the perfect storm that would unleash a pandemic virtually the same week that EPA issued its ruling. 

The EPA’s ruling and the intervening years of certifications to Step 2 standards has also likely dealt a major blow to the industry’s lawsuit, which is still pending. The coronavirus storm comes after manufacturers made most of their investments to retest their stoves, but before they could recoup those costs. Now, test labs may have to close, throwing yet another wrench into the timeline to get remaining stoves certified before May 15, 2020.

(May 5, 2020 update: The EPA reversed course, due to the Coronavirus pandemic and is trying to arrange for a sell-through period, but how and when it will occur is still up in the air.)

The role of the federal government

The federal government is rolling out a series of stimulus packages with provisions that may blunt some of the blow for manufacturers, retailers and employees. Again, industry will have to see if it has the connections and goodwill to convince Congress to provide specific relief for wood heating.  Democrats are floating various provisions to help renewable energy sectors, in part to balance the stimulus aid that fossil fuel companies are likely to get. One group urged a $2 trillion “green” stimulus plan that includes everything from $1 billion cash for trading in old energy-wasteful household appliances to an extension of renewable energy and electric-vehicle tax credits.  This could extend or even raise the $300 tax credit for wood and pellet heaters, a small but important incentive for the wood heater community.

The wood and pellet heating industry helps roughly 10 million households reduce fossil heating fuel and plays a vital role in the residential renewable energy fabric of America. With the new emission standards that took effect in 2015 and those scheduled for May 2020, the stock of stoves and boilers in America is slowly becoming cleaner and more modern. The growing pellet heat industry in America is especially vulnerable to low oil prices and needs support.

HBPA sent a letter to congressional leadership on March 20 urging Congress to extend the deadline for selling Step 1 stoves to Dec. 31, 2020.  This would help those retailers who just lost their window to sell-off their stranded inventory. The HPBA letter included testimonies from scores of retailers, relating how sales have dried up, foot traffic in their stores halted and employee layoffs begun. A December deadline would “give retailers time to sell these soon-to-be stranded products. Without this relief, and in combination with impacts all small businesses are facing at this time, numerous stores will close permanently.” (As of March 26, it appears that the proposed language from HPBA did not make it into the stimulus package passed on March 25.  However, talks are already starting for energy and energy efficiency relief in a fourth stimulus bill.)

The 2009 Economic Stimulus legislation signed by President Obama included a 30% tax credit (up to $1,500) for the purchase of a 75%-efficient biomass-burning stove. That tactic could work again and give retailers of wood and pellet stoves and boilers a much needed boost in the summer and fall of 2020 and through 2021. This policy response, being pushed by BTEC, is at the core of the residential parts of the BTU Act that came close to passing in 2019.

An even longer term, badly needed program is a federally-funded change out program which also has some traction in Congress. Subsidizing the swap out of an old stove for a new one targets people who need or want to heat with a renewable energy source. It sustains and creates jobs, helps family affordably heat their homes, and reduces air pollution. This policy mechanism, proposed by Senators Murkowski and Carper, would mainly benefit areas experiencing high wood smoke pollution out West, but would not equally benefit most states and retailers like the BTU Act. 

Additional funding will also be needed for LIHEAP, the federal low-income energy assistance program.  An additional $900 million is reportedly in the latest stimulus package.

Powerful lobbyist groups from big industries like airlines, cruise ships and fossil fuel companies are already lining up at the federal trough, ready to absorb anything and everything they can get. AGH calls on Congress to support small businesses, employees and consumers in the renewable heat sector. 

Implications for state and local agencies

This shows a spike in wood smoke following the 2008
recession in one county due in part to a renewed
 reliance on older stoves.

If this economic downturn lasts through the winter of 2020/21, heating with wood may soar, like it did in 2009, however low oil and gas prices may ameliorate this. When wood heating soars, so does wood smoke. This will put additional strains on air agencies, particularly in Western states that experience far worse weather inversions than Great Lakes and eastern states. Burn bans will be even tougher on families who cannot afford propane and electric heating.  

Bad recessions lead to major rises in the use of coal in much of eastern Europe and Turkey.  In Greece, the economic crisis in 2013 was so bad that people were cutting trees in public parks, burning furniture and fouling cities with wood smoke on an unprecedented scale. All of this taxed various government agencies as they struggled to help households secure affordable heat and combat air pollution.

AGH urges states to maintain funding for programs that replace old stoves with cleaner, renewable heating options and for incentive programs that help households purchase cleaner and more efficient renewable heating technologies, such as advanced wood and pellet heaters. 

The coronavirus has helped bring much cleaner air to countries around the world as industrial activity slows or stops, airlines cancel flights and commuters work from home. One study, featured in a headline said: “Coronavirus Lockdown Likely Saved 77,000 Lives In China Just By Reducing Pollution.”  

What consumers can do

It is still too early to tell if there could be disruptions in the domestic firewood and heating pellet markets. Nonetheless, those who heat with pellets ought to think about buying early and stocking up this spring and summer.

Consumers who heat with cordwood can prepare by making sure they have plenty of firewood split, covered and ready for next winter – which starts in 7-8 months. As unemployment soars this spring, many people should have more time on their hands. And if you purchase your firewood, you can help by supporting the firewood industry during the warm months, before wood is in short supply this coming winter.

Getting your chimney swept by a professional is vital before the next heating season, especially if you plan to use your stove more, and you used at least one cord last year. It’s also a great way to support your local chimney sweep or stove retailer during this downturn.  

For households who use stoves for most of their home heating, it’s important to upgrade to an EPA certified model if they don’t have one already. And this spring is a time when your local retailer may be offering rock bottom prices. It’s even more important for households with old stoves to get a professional chimney sweep as they can tell you how safe your install is and keep you as safe as possible for another winter. If you do need to upgrade but can’t afford a new stove, there are now many decent certified stoves on the second-hand market. There are also some decent brands at big box stores, and your local chimney sweep can likely install those for you to ensure its safe enough for you, your family and your insurance company.   

Implications for the wood heater industry

Like many industries, the economic impact of Covid-19 could be very serious for the wood heater supply chain. Retailers with underlying health conditions are also among the most vulnerable. A slowdown in new construction will mostly likely impact the gas stove and fireplace market and pellet stoves are more vulnerable to cheap oil and gas than wood stoves.

The wood and pellet stove industry has moved past much of the impacts of the new EPA regulations, but this economic downturn could cause a prolonged problems on many fronts. Warm winters, low gas and oil prices, high unemployment and a host of other factors all also point to an extremely tough year or even two.  

The immediate impacts are being felt by stove retailers, many of whom are required to shutter their shops. HPBA laid out the impacts to this sector extensively in their letter to Congressional leadership. Chimney sweeps are more likely to be considered essential and may weather this storm better than the equipment sales and installation side.  

European stove production lines are already shut down and many, if not most, US stove factories will likely be shut down soon.  

Today is Tuesday, March 24. This post will quickly become out of date as things are moving fast. Stay tuned. 

HPBA 2020 Expo showcases all new stoves to smaller audience

Jack Goldman, right, opens the 2020
Expo in New Orleans.

Updated, April 9, 2020: The hearth industry’s annual marketplace for manufacturers and retailers concluded on March 14^th, a half a day early in New Orleans amidst a dwindling crowd and growing concern about the spread of Covid-19. This was the first hearth industry gathering since the late 1980s in which virtually all the stoves and boilers on the floor were newly redesigned and tested to meet stricter emission standards.  

Some manufacturers were clearly proud of what they felt were genuinely cleaner stoves while others were unconvinced or cynical of the new standard’s impact in the real world. 

Mark Shmorhun of the DOE's
Biotechnology office
attended the Expo to talk to
manufacturers about R&D
funding needs.

Due to Coronavirus concerns, Travis and Jotul, two large manufacturers, pulled out at the last minute, leading to a notably smaller Expo. U.S. Stove, having dropped their HPBA membership, decided not to attend this year, presumably because their inability to meet the 2020 emission standards on most of their appliances weakened their position in the hearth industry.  US Stove has 18 stove models that are 2020 compliant but no 2020 compliant furnaces yet, an area it had once domoniated.  US Stove responded to this blog, saying they are well positioned to move forward with a broad range of new and exciting products.

From the perspective of the Alliance for Green Heat, the 2020 Expo showcased several notable trends, some encouraging and others troubling.  

Vesta gives Best in Show award to an automated wood stove

Possibly the biggest highlight for AGH was seeing automated stoves take more of a foothold in the marketplace. Napoleon’s Eco Smart wood stove won Best in Show at the Vesta Awards, marking the first time that an automated stove won a Vesta Award.  The stove has an optical sensor that monitors particulate matter and can continually adjust air settings to produce a cleaner burn. According to Napoleon, the automation will only add $300 to the price and they expect the complete system with stove to retail for about $2,500. The stove also connects to the Napoleon cloud via the user's smart phone so they can monitor combustion conditions. The user can also allow the company to log data from the stove, providing a valuable record of how the stove runs. The stove is not yet EPA certified, but should be within months. 

The Charnwood Skye 2700, expected to
retail for about $3,300, several hundred
more than its non-automated cousin.

Charnwood, a British manufacturer, also was a finalist in the Vesta award, with their Skye E2700, also an automated stove that does much of what the Napoleon does, but with different technology.  Charnwood will be entering the US market for the first time later this year with this stove. Hugh Wells, head of the Britsh company told AGH, "We are very excited about this product because it does revolutionise how we burn wood by taking out user error." CFS-Teco did the certication testing in Portland and it achieved 78% efficiency, the highest of any non-cat. 

SBI should also have an automated stove on the market within a year, and MF Fire had their automated Catalyst on display at the Expo and have another one in development.  Maxitrol also exhibited a prototype of an automated stove and says that they are taking off in Germany.  Napoleon also won a second Vesta award for their novel "Heat & Cool Electric Fireplace," a mini-split heat pump housed in an electric fireplace.  

2020 stove trends

The 2020 NSPS has resulted in many more catalytic and hybrid stove models. AGH is particularly

Larry Brockman from the EPA's
voluntary Burn Wise program
talks the MF Fire staff about their
automated stove.

happy to see more hybrid models as they help reduce start-up smoke and provide back-up secondary combustion if the operator does not engage the catalyst. A more unnoticed trend is the rapid adoption of the ASTM E3503 cordwood test method. Data from the EPA list of stoves shows the average grams per hour for cordwood tested stoves is 1.6 grams – the exact same average for crib tested stoves. About 45% of all 2020 certified wood stoves were tested with the ASTM cordwood method, which reportedly has more flexibility in its parameters making it easier for manufacturers to pass the certification test. Nearly all of the smaller non-cat stoves were tested with cordwood. Quite a few very affordable stoves that sell primarily in big box and hardware stores are passing the 2020 standards, and some stoves barely had to undergo any redesign.  

A sophisticated, lower priced electronic precipitator

ESPs for wood stoves, considered
far-fetched just a few years ago, are
improving rapidly and popular in
Germany and Switzerland. 

Danish manufacturer Enervex brought a self-cleaning electronic precipitator, known as an ESP. They are commonly used by factories and restaurants, but now small and affordable enough for residential applications. ESPs are a type of scrubber that uses static electricity to remove particulate matter from exhaust fumes before the particulates exit the smokestack. Enervex’s innovation is to design a residential ESP that is self-cleaning, often a big problem, and to bring the price down. They expect theirs will sell for $1,200- $1,600 when it comes on the US market. There is a quickly growing market for them in Germany, now that they are recognized by the country's eco-label, Blue Swan, and some cities may require them. OekoSolve, a Swiss company, made the ESP being tested in Fairbanks.

HPBA recruits Appalachia Service Project to take 2015 stoves in May

To address the fate of potentially hundreds of wood stoves that are 2015 certified but not allowed to be sold after May 15, 2020, HPBA negotiated with the EPA to allow retailers to donate stoves to a non-profit who can them install them. HPBA is teaming up with the Christian ministry Appalachia Service Project, based in Tennessee, who repairs homes in Central Appalachia, making them warmer,

AGH President John Ackerly with
Adam Bean of the Appalachia
Service Project

safer, and drier. At the Expo, AGH met with Adam Bean, Home Repair Coordinator for the group, who is quickly learning about wood stove installations and trying to estimate how many stoves his group has the capacity to install, which will partly depend on securing donated NFI installing and training.

Pellet stoves out of the limelight

Even though pellet stoves were relatively easy to redesign and test at 2 grams an hour or lower, the market for pellet stoves has not been particularly good and there were not many on the Expo floor. There were no pellet stove finalists in the Vesta Awards, which may indicate a pause in innovation in the North American market.

EPA announces final NSPS rule during Expo

On the first day of the conference, the EPA formally announced that they would not allow a retailer sell-through. The EPA had said on October 15, 2019 that entities should follow the compliance dates but some felt that there was still a chance for a sell-through. HPBA expressed its disappointment in a written statement while the Pellet Fuel Institute claimed a victory because the EPA removed minimum requirements from pellet fuel while retaining the prohibition that pellet fuel must not contain any of the prohibited fuels listed in the 2015 NSPS. There remains considerable debate about whether the 5-year timeline would have been enough if manufacturers had started redesigning and testing to the 2020 standards early in the process. Key excerpts of the EPA ruling provide detailed insight into why the EPA did not allow a sell-through. Some did start early and began offering 2020 compliant models to their retailers as soon as 2018, while most did not start releasing 2020 models until 2019 or even this year.  The issue was far more complicated because manufacturers had large inventories of 2015 stoves and some needed the cooperation of retailers to buy their 2015 inventory well into 2019. An HPBA mailer to retailers in 2019 said: “retailers and distributors should NOT immediately stop buying anything that doesn’t meet Step 2” in part because there wasn’t enough variety and in part because manufacturers still needed revenue from sales of their 2015 inventory.

EPA holds 3-day wood smoke workshop

One of the main reasons AGH attends the annual HPBA Expo is to participate in workshops

The wood smoke workshop brought
scores of experts from across the US
to share new knowledge, tactics and
success stories.

organized by the EPA on wood smoke reduction strategies. This year the workshop was coordinated and supported by EPA's Burn Wise, the Western States Air Resources Council (WESTAR), the Northeast States for Coordinated Air Use Management (NESCAUM) and National Tribal Air Association (NTAA) and was going to be the largest one ever, with nearly 100 federal, state, local and tribal participants registered.  But some states like Washington banned their employees from travel and many other participants cancelled, leaving a group of about 60. The workshop mainly consisted of a series of talks and powerpoints about change out programs, cord wood test methods, the impact of the NSPS, DOE funding opportunities for stove R&D, retrofits and ESPs, low cost consumer air quality sensors, indoor air quality issues, addressing wood smoke complaints, etc. Most of the powerpoints can be dowloaded here. AGH also hosted a gumbo and etouffee networking reception on Frenchman Street for all the participants. 

The 2021 HPBA Expo is scheduled for March 4-6 in Nashville, Tennessee.