Residential Wood Heating New Source Performance Standards Testimony of John AckerlyAlliance for Green Heat
Monday, June 8, 2020
Good morning. My name is John Ackerly and I am the President of the Alliance for Green Heat. We are a 501c3, non-partisan, non-profit organization based in Maryland.
Thank you for holding this hearing. We will add to this testimony in our written remarks.
Let me start by saying that we support a partial, limited sell-through, but not one that will result in more Step 1 units coming from manufacturers into the retail market. That would backfire.
There is a way to do this proposed sell-through in a smarter, more targeted way. And there is a way to do it that will add too much wood smoke into communities and neighborhoods.
One of the roles of AGH is to bring greater transparency to the wood heating community. In the next 2 – 3 minutes, we’d like to talk about details that the EPA may not have considered.
We sympathize with many of the small retailers who still have some Step 1 appliances. Their predicament is partly or in some cases mostly because manufacturers could not or did not get them Step 2 appliances early enough.
Manufacturers had 5 years and that was enough time. Now it’s the retailers turn. We do not think manufacturers should be able to sell or ship Step 1 units during a sell-through period unless the manufacturer is also the only retailer and they do not use any other retailers.
On the EPA’s website, you say that “the proposed amendments, if finalized, would provide retailers more time to sell Step 1-certified residential wood heating devices.” Please stick to your word and only consider a sell-through for retailers, and not use this as a back doorway for manufacturers to keep moving Step 1 units into the market.
Many manufacturers held off producing and selling their certified Step 2 products until 2019, thinking or just hoping that there would be a sell-through. If you happen to be a dealer who sells mostly those lines of stoves, you were put in a bad spot.
HPBA has been a good partner to EPA insofar as they have helped educate retailers about the EPA regulations. But their policies are more driven by manufacturers and in 2019 they were still urging retailers to buy Step 1 products to help out manufacturers. They said, and I quote “Manufacturers need that revenue to complete testing and certification of Step 2 products. Remember, you still have one full selling season between now and the Step 2 deadline.” (unquote)
Hundreds of retailers tried to stop buying Step 1 appliances but some of the manufacturers that they sold for, pressured them to keep buying Step 1 units.
The second way that the EPA can make this a smarter, targeted sell-through is to limit it to stoves and not allow central heaters. Step 1 units central heaters have the potential to be far more polluting than Step 1 stoves. If the EPA is concerned with air quality implications of a sell-through, the best way to allay those concerns is to focus on stoves, not on the appliances that have biggest fireboxes and the biggest potential to cause excessive smoke – and the worst reputation in the industry.
In the upper Midwest and great lake states, hundreds or thousands more Step 1 central heaters could be installed in communities that already have too many cheaper, polluting outdoor boilers and warm air furnaces. Its patently unfair for companies like Lamppa Manufacturing and Fire Chief, who are even smaller than their competitors who did not design a Step 2 unit. They deserve to recoup their investments to design and certify Step 2 furnaces, not to be undercut by the EPA. They followed your rules and your timelines and now you should not penalize them for that and reward the companies that fought your rules and thought they would not have to comply on May 15.
Out west many communities and valley towns that experience severe weather inversion where wintertime wood smoke get trapped close to the ground. These are the areas that most needed Step 2 appliances and that don’t need cheaper, more polluting Step 1 stoves to be competing in the marketplace for yet one more heating season. In anticipation of this likely sell-through, we urge those communities, starting with Fairbanks Alaska to adopt rules, if they haven’t already, that do not allow more Step 1 sales or installs.
AGH also calls on the EPA to publicly recognize states and local jurisdictions that may not allow the sell-through.
The third way to make this a smarter, more targeted sell-through is to limit the time period to as little as 4 weeks, but no more than 8 weeks. Retailers lost 2 very slow months due to Covid – 19 and the EPA is proposing to replace that with months during the peak of the selling season.
Currently, an informal sell-through is already happening as hundreds of retailers use different methods to offload Step 1 stoves. If anyone wants to go to eBay today or tomorrow, you will find hundreds of new stoves listed. (You need to double check the model numbers to see which ones are Step 1, which can be confusing.) Craigslist is another outlet used by retailers, some of whom are still listing 4 or 6 new Step 1 units. You can also find new, completely uncertified stoves online.
Some may ask, why does the EPA need to propose a sell-through, when EPA enforcement is not tangible enough to stem this informal and illegal sell-through that has been occurring since May 15. Will there be another informal sell-through after Nov. 31? If EPA is going to allow a sell-through, it needs to do a much better job at showing that it can and it is willing to do certain types of enforcement. Otherwise, we will just have a much longer period where some player comply and others are in continual, open non-compliance.
In closing, we want to say that because of EPA testing regulations, America probably makes the best wood stoves in world. We lag behind in wood boiler technology and we are not the only leaders in pellet stove technology. But with wood stoves, we probably have the strictest testing standards. For the next NSPS, we should not be looking at reducing PM levels below 2 grams an hour without first getting a federal test method that requires cord wood fuel and is based on real world burning habits. Thankfully, we now may be on track to undertake that, now that the 2020 deadline has basically remained intact, despite this likely sell-through window.
We also urge the Office of Air & Radiation to recognize the carbon benefits of small high efficiency wood and pellet heating. The Achilles heel of biomass to electricity is the low efficiency leads to more carbon emissions per unit of energy. The Achilles heal of residential biomass is the particulate matter, not the carbon. So if we can get better test methods that will lead to redesigned and genuinely cleaner stoves, we will be world leaders in residential wood stove technology.
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