Some states may disallow sell-through, but selling-through has already begun
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| Rep. Peterson (D-MN) seen here with constituent Dennis Brazier of Central Boiler, was the strongest advocate for a sell-through in Congress. |
The sell-through was expected to be at least for 2 months, most likely October and November but as of the end of October, the EPA had still not announced whether it would approve a sell-through and it may not be likely that any announcement will be before mid or late November, leaving barely a month before the end of the year.
While many European countries are moving forward with incentives for pellet stoves and boilers as part of a broader policy to reduce fossil fuels, the US wood heating community is embroiled in fights about whether the dirtiest cordwood appliances should get a new lease on life. The main wood heat industry association, the Hearth, Patio and Barbecue Association (HBPA) also represents gas appliances, so it is not making the case that these wood and pellet heaters are a low-carbon, renewable technology.
The stakes are not as high as they were in 2017 when Congress nearly passed a 3-year extension to stove and boiler emission deadlines, or in 2018 when the EPA proposed a full two-year sell-through. But the way this sell-through proposal finally emerged is opening old wounds, not only between industry and states, but also within industry. It led to the two highest volume stove manufacturers leaving HPBA and left the association without a meaningful victory during Trump’s presidency.
The EPA has opened the public comment period on whether to allow a window in the fall to sell now out-of-production higher emitting Step 1 stoves that were scheduled to be illegal to sell after May 15. The EPA will also host a virtual public hearing on June 8 to solicit input. Most experts believe some fall sell-through period is extremely likely but its length and potentially some smaller details still hang in the balance. In the meantime, hundreds or possibly thousands of non-compliant new wood stoves and boilers continue to be openly advertised and sold across America two weeks after the stricter EPA standards took effect.
While many retailers and manufacturers took the May 15 deadlines seriously, some continue to advertise and/or sell Step 1 heaters on their websites, showroom floors, or through Craigslist, eBay and other sites. EPA has made enforcement a low priority which does not preclude letters and visits by EPA enfrcement. HPBA has also been consistently educating retailers about how to comply with the new regulations. In addition, HPBA has been reminding both manufacturers and retailers that even though the EPA may not very active at higher level enforcement, state and local authorities can still be active.
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| HPBA has continually updated its education effort for retailers. |
Industry highlights mom and pop hearth stores in their advocacy efforts to get a sell-through, but the needs and goals of manufacturers is the crux of the problem. Mom and pop stores still have Step 1 stoves as a result of the many different relationships that they have with manufacturers, some of whom pressured them to keep buying Step 1 stoves, some of whom didn’t even have Step 2 stoves until recently – and some who were ahead of the curve and started selling Step 2 stoves in 2018.
Some manufacturers still really need the sell-through because they have unsold inventory of Step 1 stoves, boilers, and furnaces and may have to buy back many thousands of Step 1 appliances. Five years lead time could have been enough, but there was a widespread belief that the 2020 deadline would not stick under a Trump administration. As late as the winter of 2020, some manufacturers were still in disbelief that their industry association didn’t get any significant results in the courts, Congress, or with the administration.
Conversely, the good news for the progressive pellet and wood heating community is that the Obama-era regulations are still intact, 5 years after they came into force. Pellet stoves and boilers are
significantly cleaner and more efficient not just in test labs, but in the homes of more than a million families, many of whom want them not just to save money, but to stop paying a heating bill to multinational oil companies.
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| 2020 compliant pellet stoves show a strong correlation between lower PM, lower CO and higher efficiency. |
The stakes are not as high for some New England states like Vermont that have been giving hefty incentives to mostly European designed, clean burning pellet boilers and don’t experience severe weather inversions that trap wintertime pollution close to the ground. (Vermont and other other New England states do experience regular, more localized inversions in valleys.) But a potential sell-through of dirtier cordwood appliances represents a greater threat for West Coast communities struggling with excessive wood smoke from California’s central valley to the Canadian border.
Nowhere is the sell-through more controversial than in the warm air furnace sector, where two small companies with Step 2 compliant units would be significantly harmed by an initiative enabling a larger manufacturer to sell their older, higher polluting units.
The stakes may the highest for upper mid-west states like Minnesota where outdoor wood boilers are
as popular as they are controversial, having subjected hundreds of towns and neighborhoods to excessive smoke. A sell-through could result in hundreds of additional Step 1 boiler installations that will continue to emit heightened levels of smoke for a decade or more. Warm air furnaces are also higher sellers in Mid-Western states, as they experience some of the coldest weather in the country.
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| On per capita basis, wood smoke concentrations are highest in states with more outdoor wood boiler installations like Wiconsin and Michigan. |
Minnesota is home to Lamppa Manufacturing, a small Step 2 warm air furnace manufacturer that is vehemently against any sell-through, as their company would suffer if Step 1 furnaces were allowed to come back on the market. Lammpa Manufacturing is not a HPBA member because it and other manufacturers like Woodstock Soapstone oppose HPBA’s history of advocating for more lax standards for outdoor wood boilers and stoves.
EPA adds to confusion
On May 20, EPA Administrator Wheeler defended the proposed sell-through at a Senate hearing, adding to the confusion and myths about wood heaters. The Administrator mistakenly said that the EPA is only proposing to allow stoves to be sold that we allowed by the 2015 standards and “we’re not talking about standards that are 20 or 30 years old.” But 90% of stoves met the 4.5 gr/hr. standard when Washington State adopted that standard in 1995. The EPA adoption of it in 2015 barely moved the needle at all and allowed stoves tested as far back as 1990 to remain on the market.
The Administrator also incorrectly told the Senate Committee that most retailers sell off their
inventory in the spring. In actuality, the spring is the slowest sales period of the year and the Coronavirus shutdown disrupted sales (though far less than industry claims). Administrator Wheeler further added to the confusion by implying that it was the manufactures who were most imperiled because they had to buy back unsold stoves from retailers.
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| Administrator Wheeler's performance at a recent Senate Hearing showed limited understanding of sell-through details. |
Meanwhile, the EPA’s Office of Enforcement, OECA, has not designating Step 1 heaters as “Out of Production” but says that they are in the process of changing their database. The Alliance for Green Heat (AGH) believes that all out-of-production stoves should be consistently designated, and the EPA should not be operating under the assumption that there will be a sell-through until one is formally approved. (The EPA made this change to their list 2 months after this blog was initially posted.)
The EPA database of certified stoves is also riddled with errors and omissions but it remains a vital resource for states, air agencies manufacturers, retailers, consumers. Many of the errors are minor and its important to note that the EPA maintains this database as a public service, not because it is legally required to do so. If the certification of a unit, or other details are in doubt, the most authoritative document is the certication test report that manufacturers are required to post on their websites. Moreoever, some stoves may be fully certified but not appear on the EPA's database. It may take up to 40 days for the EPA to post an appliance on their database after it is certified because manufacturers are required to email the EPA showing the link where they have posted their test dart on their website before the EPA adds them to the database. This helps ensure that manufacturers comply with the requirement to be transparent about their testing, which manufacturers used to keep confidential prior to 2015.
Dispute over $75 million change-out fund and one-year sell-through offer
During the May 20th Senate hearing, both Administrator Wheeler and Senator Capito (R-WV) took
aim at Senator Carper (D-DE), noting that he had previously supported a sell-through but now opposed it. The day before the hearing, Jack Goldman of HPBA sent a letter highlighting this supposed contradiction, and the main reporter following this issue, Sean Reilly, called it a “flip-flop” by Senator Carper. But the attempt to embarrass Carper may have backfired as it brought back a controversial chapter in this saga into the limelight.
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| Senator Carper (D-DE) has become the leading voice in the Senate for stricter wood heater emission standards. |
Senator Carper introduced a bill in 2018 that would have established a $75 federal change out fund and provided a one-year sell-through. Although the bill was historic opportunity to get both a sell-through and a significant fund to subsidize the sale of wood stoves and boilers. HPBA refused to support it at the time because it would have also codified Step 2 emissions limits as of May 2020, and the association still thought they could roll back much of the 2015 New Source Performance Standards (NSPS), or at least delay by three years. Only in retrospect can the wood heater industry appreciate what an opportunity Carper’s amendment was, and how little industry ended up securing in subsequent years. HPBA’s decision to try for a three-year extension instead of a one-year sell-through and a $75 million change-out fund may have exposed differences between central heater manufacturers who really needed a three-year delay, stove manufacturers who were already meeting Step 2 emission standards, and retailers who would have been a main beneficiary of a large change-out fund.
This moment may have represented industry’s high point in influence in Washington but the moment was squandered and such an opportunity has never come back.
AGH asked HPBA how decisions about wood heater policy are made within the organization. Jack Goldman, CEO of HPBA responded in writing that, “All policies of HPBA go through the appropriate internal approval process that includes staff, committees, sections, and leadership.” HPBA members interviewed for this story say that policy is normally set by the Solid Fuel Hearth Appliance Section and that central heater companies do not have any inordinate influence but HPBA must represent all its members, even if that means working for “the lowest common denominator.” One HPBA member who was distressed by HPBA’s lack of support for Carper’s amendment said they did not recall any vote on that policy decision, and that there was a lot of inconsistency on what matters were voted on, and what was decided by HPBA government affairs staff.
In hindsight, industry would have benefited far more from Senator Carper’s amendment. At the time, however, industry felt that, between Congress, the courts and the Administration, they still had lots of cards to play, according to industry members interviewed for this blog. Industry had the opportunity to promptly litigate the legality of the 2015 NSPS but instead chose to delay litigation and take their grievances to Congress and the Administration. Briefs for the court challenge are due in August but it is unclear if there is anything meaningful left to litigate other than some technical issues that don’t implicate timelines and emission standards. It’s also unclear how much appetite manufacturers have for litigation if it needs to be funded with assessments in addition to normal membership dues.
States and programs that may not allow the sell-through
A number of states, such as Minnesota, may have incorporated the 2015 NSPS and its 2020 timetable into their state laws even before they anticipated a sell-through and thus cannot allow a sell through per state law. New York has publicly said that a sell-through may violate state laws, leaving open the question whether retailers can safely sell Step 1 appliances in the Empire state. Most change out programs and incentive programs that account for potentially up to 15% of annual stove sales only make Step 2 units eligible. Some of those programs operate with funds tied to the EPA that could not be redirected toward Step 1 stoves.
In addition, it’s unclear if the sell-through will be allowed in parts of Canada that have expressly adopted the 2015 NSPS. The provinces of Quebec and British Columbia, home to a third of Canada’s modest 37 million population (less than California’s) adopted the 2015 NSPS. It’s also unclear if local jurisdictions, including major urban areas, could disallow a sell-through. Depending on the number of states that reference the 2015 NSPS deadlines, there may emerge a patchwork of regulations disallowing the sell-through. This kind of patchwork is often what all industries try to avoid, as it makes commerce more difficult.
Central heater manufacturers spearhead the fight for relief
Central wood heater companies appear to have played an outsized role in the effort to delay the EPA’s wood heater deadlines, frustrating HPBA members who would rather have leaders of companies with more modern technology be the face of industry. Frank Moore, President of Hardy Manufacturing, a Mississippi based outdoor wood boiler company, represented the wood heater industry at a Senate hearing in 2017. However, Hardy Manufacturing had no intention of making a Step 2 heater and has since gone out of business.
As recently as February of 2020, HPBA said they “invited two HPBA members – Central Boiler and U.S. Stove Company” to a private meeting with officials at the Office of Information and Regulatory Affairs (OIRA), which is part of OMB. These two companies dominate the outdoor boiler and warm air furnace markets. It is unclear why HPBA invited them to the meeting. AGH asked HPBA why they invited those two companies to this meeting, and in a written response, Jack Goldman said, “we do not discuss internal deliberations as to how we make such decisions.”
The appearance that HPBA policy was being driven more by the needs of companies making central boilers caused considerable friction within industry. One HPBA member, who asked that his name not be used, said that some companies did not renew their membership in HPBA in 2020 because the “NSPS assessment fees are not in the interest of the company,” referring to the fees manufacturers paid to fight the EPA’s 2015 NSPS. The initial success of HBPA’s advocacy efforts, which led to a proposed 2-year sell-through for central heaters but not for stoves, was a deep disappointment for some HPBA members that only made stoves.
The February meeting left a paper trail on the record, giving insight into the number of Step 1 central heaters these larger manufacturers have in their own warehouses. John Vorhees, Director of Compliance for US Stove Co., said in a memo to the EPA that, “We, as a manufacturer are also stuck with inventory. We currently have $730,000 of WAF and $670,00 of AAA products.” (WAF stands for warm air furnaces, regulated under Subpart QQQQ of the NSPS, and AAA refers to stoves, which are regulated under Subpart AAA of the NSPS.)
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| "Thank you Congressman Peterson" says a sign held by Central Boilers employees in
2017, after Peterson introduced HR 453
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Central Boiler did not disclose in their memo that they had any Step 1 boilers in their possession but said that 210 of their dealers had 596 Step 1 boilers, or an average of 2.8 boilers apiece. Oddly, the memo does nothing to explain how many Step 2 boilers those dealers have, or when the company stopped selling Step 1 boilers to their dealers and started helping them stock up on Step 2 boilers. As a result, this memo, like scores of other comments submitted to the EPA in support of a sell-through, fails to provide the EPA with the kind of data that demonstrates a sell-through was warranted and that manufacturers acted timely and in good faith to provide Step 2 heaters to retailers.
After industry failed to secure a two-year sell-through that would have allowed them to build up a two-year inventory of Step 1 heaters, US Stove Company laid off 25% of their workforce and also dropped their membership in the HPBA. England Stove Works also dropped their membership but reportedly did not have any such large-scale layoffs. These two companies are by far the largest volume stove manufacturers in the US, as they sell to big and small hardware chain stores and have buy-back agreements.
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| Hardware chains such as Home Depot, Lowes, Menars, Habor Freight Tools, Northern Tools and True Value, sell the majority of stoves in some areas. |
There has long been tension between US Stove Co, England Stove Works and the makers of more expensive stoves that get sold through specialty stove retailers. US Stove Co and England Stove Works have always offered EPA certified stoves for under $1,000 and rarely sell stoves that cost more than $2,000. After the 2008-09 recession, these companies picked up a larger slice of the stove market, putting more pressure on specialty hearth stores whose stoves often start at $2,500 and can go up to nearly $5,000. Brandon Barry of US Stove Company told AGH that "we have tried in all instances to maintain similar price points in the marketplace, even with increased cost on our 2020 models, leaving those stoves as some of the most cost effective for consumers in the market."
The EPA’s low priority enforcement policy
The EPA has adopted a more low priority enforcement approach across a broad range of regulated industries. With wood heaters it has appeared to be somewhat low-priority for many years, far before the Covid-19 pandemic. The EPA is not expected to engage retailers who continue selling Step 1 appliances, but HPBA has still doggedly implored them to abide by the legal timeline and avoid any possibility of infractions.
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| Acme and EZ Boiler do not advertise their units as commercial only |
The EPA’s lack of enforcement may be most pronounced by the continued open sale of uncertified outdoor boilers and furnaces. Several outdoor boiler and warm air furnace companies still brazenly ignore EPA laws and operate with apparent impunity. Companies like Acme Furnace Co based in Missouri, EZ Boiler based in Michigan and Hyprothermboiler based in Arkansas continue to make uncertified residential wood boilers and furnaces. We are not aware of any EPA enforcement activity despite being contacted numerous times in recent years.
Follow the money
HPBA is a small industry association by Washington standards with about a $6 million-dollar budget. HPBA emerged from the Wood Heating Association founded in the 1970s during the wood stove boom years. It later merged with the barbecue industry association, but barbecue manufacturers only pay a fraction of the dues that hearth industry manufacturers pay. Three quarters of HPBA’s revenue comes from its annual Expo and only 22% from membership dues. The loss of membership dues from US Stove Co. and England Stove Works may be less significant than the loss of revenue from them buying booth space at the annual Expo, but since they don’t sell to independent hearth retailers, their motivation to have a booth at the Expo is not as important as other stove manufactures that rely on small retailers.
Retailers are members of regional HPBA affiliates and do not pay dues to the national HPBA, even though affiliates share a small amount of retailers membership dues with the national HPBA. Test labs also pay dues to regional affiliates based on their income, ranging from a high of $1,050 for Omni Test Labs to $350 for Intertek, each year. (AGH is also a member and pays a non-profit rate of $350 per year.) Between membership dues and fees for manufacturers and renting booth spaces at the Expo, HPBA remains mostly a manufacturer-driven industry association.
The Solid Fuel Section of HPBA is the committee that “promotes and protects the interests of HPBA members that produce wood and pellet hearth appliances,” according to the HPBA website. The Section also funds specific legislative, regulatory, and consumer initiatives. If the Section votes to litigate or pursue Congressional legislation, the effort is funded through a special assessment based on the size of each company in the Section, not by barbecue or gas section members. Some companies resisted expensive efforts to undermine or stall the NSPS, but still had to pay the special assessment, and others refused to pay any more special assessments after the EPA’s only proposed a sell-through for central heaters in 2018. The 2019 assessment for additional NSPS advocacy approved by the Solid Fuel Section was reportedly less than $100,000, but previous years may have been much higher.
The March 2020 Expo in New Orleans was nearly cancelled but carried on with smaller attendance. This was the first Expo to showcase all 2020 compliant appliances and was notable that the only two stoves considered for Vesta awards were both automated.
The March 2020 Expo in New Orleans was nearly cancelled but carried on with smaller attendance. This was the first Expo to showcase all 2020 compliant appliances and was notable that the only two stoves considered for Vesta awards were both automated.
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| The annual HPBA Expo is a networking hub not just for industry, but also EPA and air quality experts who attend parallel events. |
The main purpose of the annual Expo is to provide a forum for manufacturers to sell to retailers and that in turns provides HPBA with much of its annual operating expenses. HPBA largest expense by far is putting on the Expo. Its next largest expense is its advocacy and government affairs department, which reportedly spends nearly $1 million a year, mainly in salaries. In addition, regional affiliates, with far smaller budgets, engage in local lobbying and advocacy. By far the biggest issue in recent years for the Government Affairs staff has been trying to extend the 2015 NSPS deadlines and dismantle parts of it. But increasingly HPBA and its regional affiliates are engaged in fighting against restrictions on natural gas and the electrification of heating.
It’s unclear what percentage of membership dues, assessments and booth fees companies like Central Boiler and US Stove Company pay to HPBA. Hearth & Home Technologies, by far the largest higher end stove manufacturer in the US who owns top brands like Harman, Quadrafire and Vermont Castings, already pulled out of HPBA’s annual Expo several years ago, which was an even bigger financial blow to HPBA. It’s unclear if the departure of US Stove Co will help other factions regain more clout and leadership within HPBA.
Companies making and supporting some of the cleanest, most efficient, and most automated wood heating technologies have formed a smaller trade association, Biomass Thermal Energy Council (BTEC), that initially broke off from the Pellet Fuel Institute (PFI) so it could more aggressively fight for modern pellet heating policies in Washington DC. (AGH is also a member of BTEC and its President John Ackerly is on the Board of BTEC.)
Impact of sell-through sales of Step 1 appliances
The proposed sell-through would clearly benefit some companies and reduce the sales of others. Manufacturers that took the deadline seriously would have to compete with those who were counting on an extended timeline and can now offer cheaper or more discounted products. Some retailers who cleared out their Step 1 products also would be unhappy with the sell-through for this reason, but the majority who have some Step 1 stoves left support it. Retailers that have no Step 1 stoves could also buy more from manufacturers who have left-over Stove 1 inventory.
For the states and air agencies opposing the sell-through, the issue has little
to do with issues within the trade association, and everything to do with the additional pollution that will result from the sell-through. Upper Midwestern states where central heaters are popular and Western states that have frequent inversions are struggling to determine how many more Step 1 boilers, furnaces and stoves are left to sell. One data point causing great concern is that a relatively small number of manufactures who sell to “major home center chains, and report that over $10 million worth of product will not sell in time and must be repurchased,” according to a letter from HPBA’s Jack Goldman to EPA Administrator Andrew Wheeler. It is not clear how much was repurchased, or still needs to be repurchased, what percent is furnaces and boilers, and how much of that could back on the market before Nov. 30. Brandon Barry of US Stove told AGH in a written response to questions that “our inventory levels are confidential. I will say that sell through would be beneficial for us at both the manufacturing and retail level. ... Some product came back to our location and could be sold if sell through comes to fruition. Some has already been destroyed." Pellet Stove Parts 4 Less, a Massachusetts company said they bought more than 100 Englander Step 1 pellet stoves in April at bargain prices so they could take them apart and sell the individual parts.
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| A smoke capturing inversion in Fairbanks, Alaska. |
The other controversial area is how much more polluting Step 1 appliances are in the field, compared to Step 2 appliances. HPBA’s position is that Step 1 appliances are “perfectly good” and a sell-through “ultimately has a minimal impact on the environment as the products in this sell-through provision are already clean burning.” In written answers to questions submitted by AGH, Jack Goldman added, “We certainly hope that the Step 2 appliances may be better than Step 1 products in people’s homes … EPA simply has no data confirming that there is a distinction in the field between a 2.0 g/h laboratory number and a 4.5 g/h laboratory number.”
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| Emission standards for lab testing dropped by more than a half for stoves and even more for most boilers and furnaces. |
While pellet stoves are the least concerning, as many Step 1 pellet stoves were already under 2 grams an hour, outdoor and indoor boilers, also known as hydronic heaters, have the widest differences between Step 1 and Step 2 and are likely the appliance type where there is a very appreciable emission difference. Furnaces are even more complex as they didn’t even have a voluntary emission program prior to 2015, so they have had to go from an uncertified class of appliances very quickly. In 2015, their Step 1 standards were ≤ 0.93 lb. of PM/mmBtu heat output but their Step 2 dropped the most drastically, all the way to ≤ 0.15lb/mmBtu heat output. It’s hard for any wood heating combustion expert to expect that such a drastic drop in required lab certification limits would not impact emissions in the real world.
For states and air quality agencies, there is also a much more antagonistic relationship with HPBA than there was decades ago, before this bitter fight over the 2015 NSPS. The apparent leadership of central boiler companies within HPBA has not helped the relationship, and it will likely lead to more robust comments opposing the sell-through and a potential increase in state enforcement activity.
What comes next
US Stove Co and Englander dropped their memberships for different reasons, but the loss of their membership dues and assessments is overshadowed by a far more imminent threat to HPBA’s financial health: whether they can have the next expo in Nashville in March 2021. The association is actively exploring whether to hold a virtual trade show but that may not provide the revenue, even after the far lower expenses, that it relies on. Many trade associations and other groups are facing similar, longer term disruptions to the business models as a result of the Cover-19 pandemic.
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| NESCAUM's Lisa Rector demonstrating the IDC test method to EPA staff at the 2018 Wood Stove Design Challenge on the National Mall. |
Then, there is the next NSPS which could begin as soon as 2023. Many people in industry worry that the 2 grams of PM2.5 per hour standard is just a precursor to 1 gram an hour. But the next NSPS is likely to be far more complex and will focus on adopting an entirely new test method that may abandon measuring pollution in grams per hour, and adopt grams per unit of heat, which is the way boilers are already measured. HPBA members have already paused development of the broadly accepted ASTM E3053 cordwood test method, that was mainly designed by the HPBA manufacturing community. HPBA members developed the underlying data for this ASTM cordwood test, and it has become very popular, with 57 out of the 120 Step 2 wood stove models using the ASTM test.
Now the Northeast States for Coordinated Air Use Management (NESCAUM) is developing the underlying data for a series of Integrated Duty Cycle (IDC) tests, mostly with funding from the New York State Energy and Research Development Authority (NYSERDA). The EPA informed HPBA in January that they plan to use the IDC framework as the basis of the future Federeal Reference Method (FRM), the officially designated certification test method.
The question will likely be about how much data NESCAUM releases and when, and whether HPBA feels that it has been sufficiently included in the process and ultimately whether the EPA has enough data to adopt a FRM. The amount and quality of test data developed for the ASTM will be a reference point. Developing test data for a test method is a lengthy and expensive process and also can become political and controversial based on who can witness testing, how much data is shared, how long it takes to share data, what new instrumentation is required, and what the next set of timelines looks like. The process could lead to another lawsuit – and special assessments from the HPBA’s Solid Fuel Section, if manufacturers feel their ability to certify products is too unpredictable. Alternatively, if the acrimony around this proposed sell-through diminishes, a more cooperative and inclusive process could emerge and result in a genuinely improved test method that will encourage innovation to make stoves burn well in homes, not just in labs.
Now the Northeast States for Coordinated Air Use Management (NESCAUM) is developing the underlying data for a series of Integrated Duty Cycle (IDC) tests, mostly with funding from the New York State Energy and Research Development Authority (NYSERDA). The EPA informed HPBA in January that they plan to use the IDC framework as the basis of the future Federeal Reference Method (FRM), the officially designated certification test method.
The question will likely be about how much data NESCAUM releases and when, and whether HPBA feels that it has been sufficiently included in the process and ultimately whether the EPA has enough data to adopt a FRM. The amount and quality of test data developed for the ASTM will be a reference point. Developing test data for a test method is a lengthy and expensive process and also can become political and controversial based on who can witness testing, how much data is shared, how long it takes to share data, what new instrumentation is required, and what the next set of timelines looks like. The process could lead to another lawsuit – and special assessments from the HPBA’s Solid Fuel Section, if manufacturers feel their ability to certify products is too unpredictable. Alternatively, if the acrimony around this proposed sell-through diminishes, a more cooperative and inclusive process could emerge and result in a genuinely improved test method that will encourage innovation to make stoves burn well in homes, not just in labs.
