Confidence in wood stove testing program shaken in wake of Alaska and NESCAUM exposé
 |
| Richard Wayland leads the nation’s technical air quality management programs |
On Tuesday, April 5, the EPA published letters that they sent to wood stove testing labs, announcing they were embarking on a historic review of certification paperwork, similar to the examination that the state of Alaska is conducting.
The publication of the letters may have been prompted by a freedom of information request from a reporter, who got access to the letters hours before the EPA published them.
The overhaul could end up costing stove manufacturers large sums of money and the revocation of some models' certification. This is sending reverberations throughout the manufacturing community of wood and pellet heating appliances, which has never faced such scrutiny and oversight since wood stoves were first required to be certified in 1988.
The EPA announcement is also derailing, at least temporarily, a move by members of Congress to refile legislation that would establish a national wood stove change out program heralded by industry as the best way to combat excessive wood smoke. The EPA emphasized that local and state change out programs rely on EPA certification documents to help determine which stoves can achieve the best emission reductions.
The immediate actions by the EPA include using a template similar to the one used by the state of Alaska to see if their review of deficiencies in paperwork matches the the state's review. This indicates, as early reports confirm, that the EPA may not agree with some of the categories of deficiencies Alaska thought were significant.
The EPA is also announcing that starting immediately, they will be conducting far more intensive reviews of new certifications. This is believed to also include the routine retesting waivers. Under the current system, once a stove gets certified, it receives a 5-year certificate that can be renewed, without any additional testing, over and over. While this benefits manufacturers who, prior to 2015, were still marketing stoves certified in the 1990s, it did not incentivize making even small improvements in the cleanliness or efficiency of the unit every 5 years.
The letters to the EPA approved stove testing labs also put the labs under notice that they could lose their approved status if they do not improve their standard operating procedures. It is unclear why half of EPA approved labs and third-party certifiers appear to have expired approvals. The newest third-party certifier, Guardian Fire Testing Laboratories, is based in New York, the state that has been providing most of the funding to NESCAUM through its energy department, NYSERDA.
 |
| List of EPA approved labs and 3rd party certifiers who received letters |
Although the letters the EPA sent to wood stove test labs dealt mostly with enforcement issues, they did not come from the EPA's Office of Enforcement, but rather from Richard Wayland, the Director of the Air Quality Assessment Division, which typically does not handle such measures. Wayland’s Division is now under a new high profile political appointee, Joseph Goffman, who was one of Biden's top advisors during the presidential transition. Under Goffman is Tomas Carbonell, the Deputy Assistant Administrator for Stationary Sources, another political appointee who worked on the 2015 wood heater NSPS during his tenure at the Environmental Defense Fund. This may indicate a shifting and larger role for senior leadership at the Office of Air and Radiation, a potential sign that the Biden Administration is taking the NESCAUM report very seriously.
The EPA stopped short of implementing some of the recommendations in the NESCAUM report. For instance, they have not yet indicated any interest in revoking an ASTM cordwood test method that NESCAUM and Alaska found to be flawed. However, the agency did emphasize that the recently approved IDC cordwood test method could be used by any manufacturer and updated their approval of the method, possibly to correct an error found by veteran stove tester Ben Myren. That error, which the Alliance for Green Heat highlighted in a recent blog, dealt with the amount of bark that must be left on logs during certification testing, and highlights the precarious role of the EPA in approving test methods where the underlying data has not been publicly released for experts to review. It is unclear if EPA even had access to the IDC test method's underlying data which is owned by NYSERDA. If the agency does have the data, it could make it available or it may have to disclose it through freedom of information requests.
The EPA's announcement of this major overhaul comes just days after many top stove manufacturers and the main industry association, the Hearth, Patio & Barbecue Association, filed comments vigorously opposing the results of the Alaska stove certification review. If the EPA does not approve Alaska's scheme of culling out stoves with too many deficiencies in their paperwork and which emit more than 6 grams an out during test runs, Alaska may be forced to only allow the new installation of pellet appliances in the Fairbanks area, that is fighting federal non-attainment status.
For many years, experts have known of the mounting complexities and loopholes in testing wood stoves. Then, by 2020, it became apparent that many stoves that were tested above 2 grams an hour were somehow able to test to below 2 grams an hour without being altered, calling into question whether the regulations led to a cleaner generation of wood stoves. Pellet stoves and boilers however have genuinely become cleaner and more efficient from the tighter 2020 emission standards because of their automated functions and consistent fuel qualities.
Related stories
EPA's cordwood test protocol moves forward (July 2021)
EPA and states vigorously defend stove audits (Sept. 2020)
Opinions of top stove industry insiders on controversial topics (Aug. 2017)
Study shows environmental advantages of pellet stoves and exaggerations by manufacturers (Oct. 2015)
No comments:
Post a Comment