Thursday, March 18, 2021

Initial response from AGH on the NESCAUM report

 A scathing report, "Assessment of EPA’s Residential Wood Heater Certification Program," raises many important points but overstates its case and fails to acknowledge the advances in stove technology in recent decades. The report never acknowledges that pellet stoves operate more consistently in homes as they did in the lab, compared to wood stoves, for example. Moreover, the policies and interests of the northeast states represented by the report's author, NESCAUM, are undermined by a report that never acknowledges the important role that modern, automated wood and pellet heating have to reduce fossil fuel use and help combat climate change. The Alliance for Green Heat (AGH) is preparing a response to the NESCAUM report.

The report alleges that the EPA certification process is "dysfunctional," and its tone and content easily digestible by the media.  The process needs significant improvements but we need to also recognize what works and what has been achieved. It rightly points out the deficiencies of the so called "independent" third-party reviewers, lack of sufficient enforcement by the EPA, and certification paperwork that often lacks required detail. AGH urges the EPA to take the report seriously, and calls on the Biden Administration to provide more resources to enforcement, the Burn Wise program, and the development of a federal cordwood test method that integrates IDC concepts.  Many of the problems cited by the report are the result of budget cuts in an agency tasked with scores of vital air quality programs.

AGH urges states and the media to take this report with a grain of salt.  This report provides an opportunity to further educate state and local experts but the report should not undermine the important steps states have taken to incentivize modern, automated wood and pellet heating.  The process to certify pellet stoves and boilers in particular is a functional one and can be even more so with improvements.  

The complexity of writing test methods that hold up over time is also evident in some of the missteps by the very authors of the report.  Test labs that used a flawed IDC test method developed by NESCAUM resulted in mysteriously low efficiency numbers.  The lab now has to explain to EPA why they should be allowed to adjust their efficiency numbers.  Our point is that regulators and experts all over the country - including the authors of this report - are going through an important learning curve to better understand how to improve test methods and the certification process.  We urge all stakeholders in this community to approach this highly complex process with humility - and urgency - so that lasting improvements can be made.


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