Tuesday, October 24, 2023

How to make the EPA stove database more useful

The EPA's wood heater database, also known as the EPA list of certified stoves, is the official site where the EPA publicly registers certified wood heaters after they have been tested by third party labs.  The list has EPA sanctioned data including the emissions, efficiency, firebox size and Btu per hour range of all certified stoves, and previously certified stove information is also available.

As such it is the go-to site for consumers, manufacturers, retailers and air quality agencies. The EPA has updated it many times, most notably in May of 2019 when they switched from a static to a searchable database. 

But the site remains clunky, not consumer friendly and also not sufficient for many stakeholders such as some states and air quality agencies who want far more data included.  The Alliance for Green Heat has often sent recommendations for improvements and corrections since our founding in 2009 and we have generally had a good and productive relationship with the managers of the site, who have appreciated our input.  

Recently, AGH sent a lengthy memo to the EPA with a long list of suggestions to overhaul the site again, as they did in 2019.  To follow along with our comments, you may want to go to the site and follow along as we move through its features and terminology. 

1. Overall suggestions: make the database more consumer facing, while also retaining information and data that is valuable to states, air quality agencies, industry etc. To make it more consumer oriented, we suggest:

    A. Include many links to EPA Burn Wise, so that consumers can easily access relevant information such as how to size a stove, differences between cat and non-cat, etc. These should be prominent links on the home page of the room heater and central heater list. Integrating this list with Burn Wise info will help expand on the details that you provide to consumers so they can better understand the terminology you use.  If you want consumers to use this list and learn for it, include vital information that they want and should have.

    B. One of the main functions consumers like, and even expect, is the ability to choose 3 or 4 stoves and have them come up together on a page so they can easily compare them. A “compare my stoves” option allows anyone to see exactly which stoves they want to compare, whether you are a consumer or a state/air quality organization.

    C. When the page loads, you should see a list, and can easily start sorting. Currently, that first step of getting to the actual list seems clunky.

    D. We also suggest you have an introductory paragraph in big font, giving basic information about how to use the list, and how not to use the list. Knowing that seasoned wood is almost always more important that the lab emission and efficiency number, and maybe something like “This list does not include many vital details about stoves, such as distances to combustibles, type of floor protection required, etc.”

    E. Add a button: send reports of inaccuracies or possible violation of these regulations.

    F. You should consider having half a dozen of the most important columns appear right away on a main page, and then give users the option to choose to see other columns. We suspect that this process of updating the database will lead to adding more columns and that will be clunky and crowded unless you somehow hide some of the columns. Thus, test method, date of certification, and other things that specialists want on the list, but are not important for the consumer, or even too confusing for the consumer, should not be initially visible. You could also have an “Advanced search page” where everything is available for whoever wants to go there.

2. Name: The overall name should be EPA Certified Wood Heater Database. Then, we recommend changing “room heater” to “wood and pellet stoves.” The EPA can do far more to give pellet heaters stature and visibility as a cleaner and more modern option. The term “room heater” is not used often. “Space heater” is far more accurate and more in tune with lower income households, where the space to be heated is their smaller home, not a single room. “Room heater” is simply out of touch with how most people use their stoves, which is often in the largest area of the house than it also connected to other rooms. Historically, and to some extent today, stoves are located in the basement, not to heat that room, but to drift up into the house. Conversely “Central heater” is a more commonly used term in the HVAC space. Or, you could say “Central heaters: boilers and furnaces.”

3. Slide bar searches: We urge you to at least only include realistic ranges, thus 0 – 5 cubic feet, not to 10 cubic feet. And emissions should top out at 2.5, not 10. But we question whether the tool is really effective enough to encourage consumers to use, unless they have been somewhat educated about its limits. We think its less of a problem with pellet stoves, who are likely to have real world emissions and efficiency that track lab values far better than wood stoves. The EPA should not be hesitant to say that. If you keep it, you need to stress that seasoned wood and proper stove use (giving the stove sufficient air when needed) is more important than choosing a stove that is 1 vs. 2 grams per hour, or 70 vs, 75% efficiency. And you should not be hesitant to include a link to the IRS tax credit as other EPA pages would when a product gets tax credits. Again, if you want consumers to come to this page and be educated here, vs. manufacturer literature, include the info and the links that consumers want to know about. Lastly, as we describe in more detail below, we think BTU output is less relevant than firebox size to estimate heat output.

4. Columns
    a. On an “Advanced search” page, or an area where you can select other columns, we would add Test Method (denoting which ones got modified or alternative tests), date of certification or recertification (but not any certification expiry date), maybe the test lab and a link to the owner’s manual and non-confidential test report. If you want more people to use this list and come to it, include info that consumers want like the owner’s manual.

    b. Hybrid stoves: Make sure to accurately include all hybrid stoves.  This is a very important, relatively new type of stove that many experts think is an important technology improvement over catalytic stoves. Currently, the database has 22 hybrids, but we think there are far more. Are they being correctly and consistently labeled as hybrid?  Make sure consumers understand what they are and how they benefit from using both cat and non-cat secondary combustion strategies to reduce emissions. 

    c. Single burn rate stoves: We encourage you to designate which stoves are single burn rate stoves. This is also an important type of stove and can be an easier and cleaner for consumers because it has no levers and cannot be put into a smoldering mode. We think they are all no-catalytic, but if not, it could say single burn rate/cat or single burn rate/non-cat.  

    d. Model: You should not need to say that all models meet the 2015 NSPS. If not, how would it be on this list? You seem to confuse the 2015 NSPS with the staggered emission standards within that NSPS.  I would add that if there are multiple models, tell the consumer that the differences between them are either cosmetic or have some different external feature but the firebox is the same.

    e. Manufacturer: In the days of industry consolidation, the manufacturer is often less important than the brand. For this to be useful to consumers, you need to have a column for brand and then the manufacturer could be noted under the brand, and the manufacturer need not have its own column. And, where the manufacturer is something like “Gruppo Piazzetta S.P.A.”, it should be listed alphabetically by the brand “Piazzetta” followed by the manufacturer.

    f. Firebox volume: We think this is as much or a better indicator of heat output than the “Heat Output (BTUs)” column and it should be recognized as such. Many retailers know this and sell stoves based on firebox volume. BTU numbers are notoriously unreliable and we've got a number of different explanations from test labs and industry experts. We also recommend defining Firebox Volume not as its used for test fuel, but as its used by consumers, and why it matters. Small fireboxes can’t take 18-inch logs. Large fireboxes do not perform well in small spaces, etc. etc.

    g. Heat output (BTUs): As mentioned above, we question the consistency and accuracy of BTU numbers from test labs and as such they are not very useful for consumers. At the very least, we suggest saying something to the effect that sizing your stove to the space you can heat with it is really important and while BTU output can be one data point, the firebox size of the stove is another important one.

    h. Emission rate: The “annual avg” is confusing. If anything, consumers want to know the grams/hour, not average grams per year. We realize this is not an average per year, but it could sound like that to consumers. It should emphasis that this is a lab number and consumers need to use seasoned wood and give the stove enough air for this number to mean anything. Or, maybe say something to the effect that if seasoned wood and sufficient air it not supplied, emissions can be many times higher than the lab number.
    i. Efficiency: Efficiency terms need to be better standardized so that manufacturers report the same type of efficiency in their materials as the EPA lists in its database. Perhaps the way to get to this is to only ask labs to report “overall efficiency” and “combustion efficiency” in the next NSPS and drop “Heat transfer efficiency.” As you know, Overall Efficiency tracks closely with Heat Transfer Efficiency, but the often 1-point difference between them can make a stove eligible for the IRS tax credit which is based on a minimum 75% “thermal efficiency,” a term not technically used by test labs but most often associated with Heat Transfer Efficiency. The term “weighted” should not be used in the EPA database as that just makes things more confusing.

    f. Type: On the room heater page, there are two Types are wood and pellet stoves, so it may not be necessary to talk about central heaters. It may be an opportunity to briefly distinguish between wood and pellet stoves, noting that pellet stoves are typically cleaner and more efficient because the fuel has a standardized, low moisture content and a more consistent combustion conditions.
    j. Subtype: First, you should list and define the subtypes before talking about one of them. I don’t think saying that any type of heater can be equipped with a catalyst is a point worth making. The main point here is that consumers have choices between three types. Non-cats are most common and typically the simplest. Cats are typically more efficient, and hybrids have the added benefit of two distinct forms of emissions reductions and are sometimes even more efficient as a result.

    k. Fuel type: This is unnecessarily confusing. First, you should delete all the fuels if there are no stoves that can be certified with them, such as coal, wood chips and biomass. Only include the fuels that you list in that column. Can corn be a “certified” fuel or just a fuel that is allowed to be advertised with the certified fuel: pellets. Second, you need to explain “crib wood.” Then, in the description below, room heaters are always designed for either wood or a pellet fuel. Why even mention wood chips if there are no room heaters certified with wood chips? As far as I know, there are no certified multi-fuel stoves on the market and the EPA continues to fail in their enforcement of non-certified multi-fuel stoves that list pellets as a fuel. You could say as of the date the new database is released that there are currently no certified multi-fuel stoves anymore and no non-certified multi-fuel stove can be sold if it advertises pellets as a fuel.

    l. CO: This is very confusing because it brings up the image of a gas stove, where CO is being released directly into the living space. The amount of CO released by a stove is more relevant as an indication of clean combustion, not because a higher CO stove is more of a health risk for consumers. CO from a wood stove is rarely a health risk but can happen when flue gases reverse and come back into the room, which is most likely (though rare) in the tail when there is little heat, but a lot of CO. It can also be dangerous when you put live coals in a bucket and leave the bucket indoors. Stoves in tiny spaces like boats are riskier if flue gases reverse and come back into the living space. We also recommend putting this column in an Advanced Search page, or an optional column that you can choose to see but is not initially served up on the main page.

    m. “NSPS Compliance 2020” should only be an advanced search page if currently certified stoves are mixed with uncertified ones. Otherwise, its confusing for the consumer, who should rightly assume that these stoves are certified and legal to make and sell.

“Quick Searches”

Remove “Previously EPA Certified” from this box. That option can be in a much less prominent
place, not in such valuable real estate. Then, you can also remove “Currently EPA Certified” because the list should only be currently certified units, unless you specifically want to see old ones, which only specialists want to see. You may not even need the “Quick search” box, as it may give lab numbers of emissions and efficiency too much emphasis, when we need more emphasis on fuel and operator skill.

I would suggest using that box for headings and links about the role of seasoned wood and giving the stove enough air, and how that is as or more important than lab tested emissions and efficiency numbers, except in pellet stoves. Again, the EPA can use its voice to say that lab numbers are likely to be more realistic for pellet stoves than they are for wood stoves. Don’t write caption info that inadvertently applies to wood stoves without noting the differences for pellet stoves.

I find this para, below, extremely confusing. Is there really a “2020 Rule”? Both the 1988 and 2015 rules had staggered compliance dates but this detail does not need to be here. Then, the line starting “If you question whether you can keep or operate …” I also may cut as its pretty rare that you can’t keep or operate the stove in your home, and if so, it’s not a federal rule.

Thank you for your consideration of these recommendations and we would be happy to elaborate on any of them, and provide further input as you go through the process of improving this database.

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