|Bryce Ward, Mayor of Fairbanks |
North Star Borough.
Alaska is undertaking this unprecedented review in an effort to find the stoves that they can be assured are the cleanest and meet all the requirements in EPA regulations under the Clean Air Act. AGH first covered this in a October 22 blog. In addition to checking that stoves meet the extremely detailed level of documentation based on emission testing, Alaska has imposed even stricter emission requirements, which do not apply anywhere other than Fairbanks. The primary stricter standard is that stoves cannot emit more than 6 grams an hour of particulates during the first hour of a multi hour test. Ultimately, when averaging the PM of the entire test, stoves must emit no more than 2 grams an hour to meet the Fairbanks standard, even though the federal standard allows up to 2.5 grams of PM if a stove is tested with cordwood.
|Part of ADECs summary sheet showing|
the preliminary and initial final
determination and the reasons.
One reason why so many stove models are flagged with multiple deficiencies is simply because ADEC officials missed data in the test reports or the manufacturer of the model has not yet provided it. Of the 130 stoves with major problems, many will likely meet Alaska’s review in the coming months. Manufacturers who have requested an extension from the State have until April 1 to work with Alaska to provide details, and only after that can the model not be sold in the Fairbanks non-attainment area. In the meantime, the review appears to shpow that only one wood stove model – MF Fire’s Nova tested by ClearStak lab – could be on the market. The data sheets on all stove models can be found here and will be updated at least monthly.
|A Step 1 Jotul stove being tested by|
Dirigo labs, taken over by PFS-Teco.
ADEC has not yet determined which missing items on test lab reports disqualify a stove. Some of the issues ADEC is flagging have to do more with paperwork requirements than the potential cleanliness of the stove. They are engaging in a series of meetings with EPA personnel from both enforcement (OECA) and air quality (OAQPS) offices to determine what is actually required by the NSPS, what isn’t required, and what should be considered significant. One long time technician at an EPA approved lab said that “based upon ADEC’s interpretation of the language in parts of the Federal Register, they have come up with several new requirements” which never existed before.
|A 2019 pie chart made by AGH|
showing an approximate percent
of stoves tested by each lab based
on one data set.
The scrutiny of certification paperwork by labs by Alaska also comes on the heels of years of effort by the stove industry to prevent stricter emission standards and the possibility of stricter audits. States have become increasingly frustrated that the EPA is not enforcing their regulations governing wood stoves and boilers. While enforcement was explicitly curtailed under the Trump administration, under Obama and previous administrations, enforcement has been regarded as lax or sporadic. In particular, the EPA has never initiated an audit of a wood stove or boiler to determine if it can achieve the emission levels that it got on its initial certification test. There is also no documentation of the EPA denying certification of a stove or boiler based on inadequate lab reports. In addition, there are only a handful of documented cases when a stove or boiler has failed emission tests in a lab even though industry cites very high rates of variability in emissions during testing.
Some of these issues emerged in 2019 when the EPA released hundreds of documents that NESCAUM had requested in a Freedom of Information Act request. But very little has ever been written about the many complex and opaque issues in test labs other than a blog AGH posted in August 2019: Records reveal successes and challenges in laboratory wood heater testing. That article explored issues of conflicts of interest, compliance with testing regulations and suspension of certification tests, all of which are receiving are receiving more scrutiny by ADEC officials and their partner agencies.
|An ASTM 3053 test at Omni lab in|
May 2020 on a GHP Group stove. GHP
is a company that has not
requested that ADEC review its stoves.
ADEC’s initiative is also intertwined with concerns about the ASTM E3053 cordwood method and lab tests that showed the method was lax and may have helped some stoves to achieve certification to the EPA’s stricter 2020 standards with few or no modifications to their design. A meeting between EPA and state officials and industry representatives in January of 2020 explored these concerns and ADEC presented their strategy at that time.
ADECs efforts to improve air quality in the Fairbanks non-attainment area go back at least 10 years, starting with traditional stove and boiler change-out programs and a variety of restrictions. But the tenacity of excessive wood smoke in America’s coldest city has frustrated residents and officials alike, leading to this latest effort to understand which stoves are actually cleaner than others. Fairbanks is also spearheading solutions for the other most obvious culprit: unseasoned wood. As of October 1, 2021, only seasoned firewood can be sold in the non-attainment area.
|Registration for firewood retailers is|
compulsory in Fairbanks and voluntary
in the rest of the state.
It is still too early to tell how much this latest initiative will lead to cleaner air in Fairbanks. There is little doubt that it will bring a new level of scrutiny and integrity to test reports submitted to the EPA, and help the EPA and state agencies better understand how to craft a federal reference method for testing stoves with cordwood.