Alaska releases deficiency details on wood and pellet stove test reports

Bryce Ward, Mayor of Fairbanks
North Star Borough.

Alaska posted summary review sheets of nearly every certified wood and pellet stove, exposing issues in a certification system that has been running for decades with little oversight. Of the 131 wood stove models, 130 had major problems in their testing report based on the Alaska classification system.

ADEC is pursuing EPA approval of s smoke reduction plan similar to one in Montana. They said, “Missoula City-County Montana regulations allows installation permits only for pellet stoves emitting no more than 1.0 gm/hr.  Alaska embarked on the certification test review and the establishment of a 1-hr filter pull standard as an alternative to a pellet only program for the nonattainment area as DEC feels this approach meets the communities desire for more device options and is at least equal to the Missoula requirement."  Click here for the full email.)

Alaska also sought and received approval from the EPA for an IDC cordwood stove test method to be "broadly applicable" which means any manufacturer can choose to use it in a stove's certification test. It also sets the stage for Alaska to potentially require that test for stoves sold in Fairbanks.

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.

The initiative is being undertaken by the Alaska Department of Environmental Conservation (ADEC). It only impacts which stoves and boilers can be installed in a relatively small area around the city of Fairbanks that currently fails federal air quality limits. That is a very small market for the wood stove industry but the initiative may end up having far reaching implications for the EPA, the stove industry and how stoves are tested in the future.

 

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.

The data on pellet stoves is far better in some respects. Rarely do pellet stoves emit more than 6 grams during the first hour of a test like many wood stoves do. Of the 97 certified pellet stoves, only 3, or about 3%, are disqualified for this reason, compared to 31% of wood stoves. However, like wood stoves, the vast majority of pellet stove test reports had missing data. Only 7 had minor issues. As with wood stoves, over the ensuing months, scores more will likely be approved after missing information is found or provided by the manufacturer. Eleven of the test reports could not be found by ADEC. Sometimes links to these reports are hard to find, sometimes the link is broken, and sometimes the report doesn’t appear to be posted.

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.

For manufacturers, a key distinction is also data that was collected and exists, but was never calculated or reported properly, compared to data that was mistakenly not collected and could only be obtained by retesting the unit. It’s unclear if any of the test reports are so deficient that the EPA would ever considering revoking a certificate.

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.

Postscript: In March 2021, NESCAUM released a report that was largely based off of the reviews of certification reports done jointly by ADEC and NESCAUM.  The scathing report concluded that the EPA process of certifying stoves is "dysfunctional" and recommended a series of aggressive measures.  AGH's initial response that report can be found here.

Related stories

Veteran lab technician challenges Alaska's wood stove criteria (March 2021)

Alaska building list of cleaner, properly certified wood and pellet stoves (Oct. 2020)

DOE request input about wood heater R&D needs

The Bioenergy Technologies Office of the US Department of Energy has begun to provide R&D funding

to the wood heater manufacturing community.  To date, it has had two rounds of funding, with $10 million available.  The DOE provides R&D funding to many different renewable energy technologies to "enable sustainable ... energy security, reliability and resilience while creating economic opportunities across the country."  The Bioenergy Technologies Office "selects research and development projects through open and competitive procurements called Funding Opportunity Announcements (FOA) and encourages collaborative partnerships among:

• Industry
• Universities
• National laboratories
• Federal, state, and local governments, and
• Non-government agencies.

Now, the DOE is asking for input from the extended wood heater community about what the community needs to build cleaner and more efficient stoves.  This likely indicates that they may change the focus of their funding next year.  In the past, they provided funding for 

• Novel and innovative residential wood heater designs to improve combustion chamber geometry, combustion air flow distribution, mixing of combustion air with gasification products, stove baffling designs, etc. 
• Improvements in automation of stoves to optimize combustion control. 
• Wood heater power generation via thermoelectric module integration 
• Improvements in catalyst technologies for emissions reduction

Input should be sent to FY21MultiTopic@ee.doe.gov and is due by 5:00 PM September 21, 2020.  We have reproduced the details of the Request for Information below (except we omitted language about a parallel ROI on biofuels). For the full text, click here.

FY 2021 Bioenergy Technologies Office Multi-Topic RFI (DE-FOA-0002386)

DATE:           August 20, 2020 

SUBJECT:     Request for Information (RFI) 

Description 

The U.S. Department of Energy (DOE) Office of Energy Efficiency and Renewable Energy (EERE) Bioenergy Technologies Office (BETO) is requesting information on research opportunities related to residential wood heater technology advancement 

Purpose 

The purpose of this RFI is to solicit feedback from industry, academia, research laboratories, government agencies, and other stakeholders on issues related to overcoming the technical barriers and challenges in the design of clean, efficient residential scale wood heaters. EERE is specifically interested in information on identifying the critical technology gaps and resources required to significantly reduce emissions and improve efficiency of residential wood heaters. Gaps of interest include but are not limited to the stove design, automation, catalyst development, retrofit technologies for older wood heaters, sensor technology, and stove performance testing methods. 

This is solely a request for information and not a Funding Opportunity Announcement (FOA). EERE is not accepting applications. 

Category 1: Residential Wood Heater Technology Advancement 

Technological Barriers 

1. What are the critical technical hurdles for improving performance of stoves for new installations (e.g. combustion chamber design, combustion air management, controls, mixing, sensors, etc.)? 

2. What are the critical technical hurdles for improving performance of stoves already installed in homes (e.g. combustion chamber design, combustion air management, controls, mixing, sensors, etc.)? 

3. What practical and new techniques are used to significantly reduce transient emissions (startup, shutdown, load changes)? 

4. What practical and new techniques are used to measure transient emissions that could be implemented in laboratory or field testing? 

5. How can new exhaust emission control technologies be developed and practically deployed? 

6. How could integrated hybrid systems, in which biomass heaters are combined with other technologies such as heat pumps, solar, and high efficiency gas and liquid-fired appliances, be a route to reduced emissions? What are the technology barriers to this approach? 

7. How could field measurement methods be improved to ensure that biomass-appliances do not create local air quality issues in long-term use? 

8. What stove features commonly encourage end-users to purchase new or replace a wood heater? Or, what stove features are commonly attractive to the end-user? 

9. What advantages or disadvantages would continuous field performance data provide for advancing stove designs? 

Tools and Capabilities

1. How are trial-and-error test methods used to improved stove performance and advance stove design (i.e. development by implementation of incremental change and testing)? 

2. Is access to performance testing facilities a barrier to development? 

3. What in-house test methods are relied upon to validate and facilitate wood heater development? 

4. How much could rapid performance measurement methods shorten R&D test cycles? 

5. What specific test methods would be of interest to your enterprise? 

6. How are modeling and simulation tools being applied to improve wood heater designs? 

7. How could modeling and simulation tools be improved to meet your needs? 

8. What are the fundamental modeling gaps to enable broader use of modeling and simulation such as Computational Fluid Dynamics (CFD) to improve wood heater design? 

9. How are current measurement methods meeting your needs for evaluating performance and emissions from wood heaters? What could be done better? 

10. What performance/emissions measurements are most challenging to obtain? What makes obtaining these measurements challenging? 

11. What are three primary challenges your enterprise faces for advancing stove designs?

 Request for Information Response Guidelines 

Responses to this RFI must be submitted electronically to FY21MultiTopic@ee.doe.gov no later than 5:00pm (ET) on September 21, 2020. Responses must be provided as attachments to an email. It is recommended that attachments with file sizes exceeding 25MB be compressed (i.e., zipped) to ensure message delivery. Responses must be provided as a Microsoft Word (.docx) attachment to the email, and no more than 6 pages in length, 12 point font, 1 inch margins. Only electronic responses will be accepted. 

EERE will not respond to individual submissions or publish publicly a compendium of responses. A response to this RFI will not be viewed as a binding commitment to develop or pursue the project or ideas discussed.

Please identify your answers by responding to a specific question or topic if applicable. Respondents may answer as many or as few questions as they wish. 

Respondents are requested to provide the following information at the start of their response to this RFI: 

• Company / institution name; 

• Company / institution contact; 

• Contact's address, phone number, and e-mail address.

Massachusetts renews innovative stove change-out program

Changing face of wood stoves in America includes a comeback of catalytic stoves 

Massachusetts announced an 8th round of annual funding for its innovative wood stove change out program. The program was the first in the country to develop a change out program that gave higher incentives to fully automated stoves and stoves that provide a verified efficiency on the list of EPA certified stoves.  The program has since been discontinued but may come back again.

The program, updated in April 2019, changes some of the rebate levels and provides consistently higher levels of rebates than most change out programs. It now offers Massachusetts residents between $500 and $3,250 for upgrades, depending on the stove and income level of the family.  To be eligible, households must have an operating, uncertified wood stove to trade in for a new wood or pellet stove.  Rebates can cover 30 - 80% of costs of the new stove and installation.

Governor Charlie Baker said in a statement the change-out program "improves air quality across the commonwealth and helps residents save money by adopting more efficient, cost cutting heating technologies."

The program favors appliances that burn more cleanly in the hands of consumers by offering the highest rebates ($1,750) to pellet and fully automated stoves that have listed efficiencies over 65%. The highest wood stove rebates ($1,250) can be claimed for catalytic (or hybrid) or non-catalytic stoves that emit 2 grams an hour or less and have a listed efficiency of 65% or more on the EPA list. The lowest rebate of $500 covers non-cat stoves that emit between 2 and 3 grams and do not have a listed efficiency. Income-based rebates for low income residents range from $2,000 to $2,750, plus the efficiency adder if the stove has a listed efficiency.

This table is reproduced from the Change-out Program Manual (pdf).

Massachusetts provides a helpful list of rebate amounts for all stoves that emit under 3 grams an hour. There are 596 stoves on the list. As a sign of the changing face of wood stoves in America, 216 or 36% of these stoves have verified efficiencies on the EPA list. Just two years ago, in the spring of 2017, only 87 stoves had listed efficiencies of 65% or higher. 

This shows that in a short span of time, consumers have far more access to efficiency data than in the past. Change out programs like this one help drive consumers to purchase higher efficiency stoves. According to people familiar with the Massachusetts program, most consumers buy stoves with listed efficiencies rather than forgo the $500 - $750 efficiency adder.  New York and Maryland also now include efficiency criteria in statewide stove incentive programs.

In a further sign of changing times, we are seeing a major resurgence of catalytic stoves. Fifty of the 216 stoves with verified efficiencies are cat stoves, compared to 61 that are non-cat. Many manufacturers are now using the term "hybrid" for stoves that have a catalyst and robust non-cat secondary combustion. Given the spotty reputation of catalytic stoves in the 80s and 90s, some manufacturers appear to be using catalysts to pass the 2020 standards but not advertising that the stove has one. In the Massachusetts change out program, hybrids are treated like catalytic stoves and receive the higher rebate.

Pellet stoves comprise the biggest share of stoves with listed efficiencies with 95 models. This high number of pellet stoves is a reflection of the ease of getting pellet stoves re-certified to the 2020 standards, which require efficiency testing and disclosure.

Steve Pike, CEO of the
Massachusetts Clean Energy
Center announced the program at
the Fire Place in Whately MA.

Possibly the most surprising part of the Massachusetts list is that the  6 stove models under 65% efficiency are all pellet stoves. It is vital for consumers to rely on the efficiency figures on the EPA list because most stove manufacturers continue to provide exaggerated or misleading efficiencies on their websites and promotional materials. For example, the Regency Greenfire GC60 made by Sherwood Industries was tested at 60% efficiency, which had to be disclosed on the EPA list.  But the manufacturer's website says "76.6% optimum efficiency."

Massachusetts' program gives its highest stove rebate of $1,250 to "fully automated woodstoves (FAW)" that consumers can "load and leave." A FAW is defined in the program as a "stove that (a) automatically adjust the stove’s airflow and therefore includes no manual airflow controls and (b) has sensors that provide temperature-control capabilities." There are currently four such stoves on the list. Determining which stoves can be designated as fully automated is tricky. Other states and change out programs are interested in this issue as well.   The development of automated wood stoves could eventually reshape how we think about wood stoves, as they transform an age-old technology into a modern, high-tech appliance.

One important characteristic of wood stoves that does not appear on any list of stoves is whether the stove was designed for, and tested with, cordwood. Change out programs may see value in giving an extra rebate to encourage more consumers to use stoves designed to burn with cordwood instead of crib wood.

The 2019 Commonwealth Woodstove Change-Out Program has a budget of $450,000, which adds to the more than $2 million in funding for change-outs since the program began in 2012. The program has helped more than 2,300 residents swap out their non-EPA certified, inefficient stoves for newer, cleaner models. More than 500 of these rebates went to residents earning less than 80 percent of the state median income.

The program is run the by Massachusetts Clean Energy Center (MassCEC) in coordination with the Massachusetts Department of Energy Resources (DOER). Residents must have the new stove installed by a Participating Stove Professional who ensures that the old, uncertified wood stove is destroyed. There are currently 65 stove professionals participating, double the number from 2 years ago. Installers are encouraged, but not required, to be NFI or CSIA accredited.

Excerpts of comments from the Advance notice of proposed rulemaking

The Alliance for Green Heat did an analysis of stakeholder positions which can be found here and also pulled out these excerpts for those who do not want to download and wade through hundreds of pages of comments, much of it repetitive.

The following excepts are what we view as key positions taken by stakeholders in the Advance response to the EPA’s request for comments on a range of issues, including:

·      compliance date for the Step 2 emission limits, 

·      Step 2 emission limits for forced-air furnaces, hydronic heaters and wood heaters, 

·      Step 2 emission limits based on weighted averages versus individual burn rates, 

·      transitioning to cord wood certification test methods,

·      compliance audit testing, 

·      third-party review, 

·      electronic reporting tool, and 

·      warranty requirements

We have taken key excerpts from all sides of the debate to highlight differences, The full comments can be found here.   Many other comments can be found in response to the EPA’s request for comments of the Proposed Ruleto give a sell-through for boilers and furnaces.  We only excerpted language for comments to the advance notice of proposed rulemaking, which elicited a far wider range of responses.

Excerpts are organized by: State Agencies, Industry, Retailers, Air Agencies, Federal Office and Non-profits. 

STATES

The Attorneys General of New York, Connecticut, Illinois, Maryland, Massachusetts,

Minnesota, New Jersey, Oregon, Rhode Island, Vermont, and Washington and the Puget Sound Air Quality Agency 

The step two compliance date is feasible and necessary to protect public health. Any delay in the implementation of the step two standards would have significant adverse public health consequences. Moreover, EPA has not provided any basis to change its previous determination that five years was an adequate amount of time for manufacturers to develop cleaner burning devices. 

·     The step two standards for wood boilers and forced-air furnaces are also feasible. 

·     Finally, the evidence shows that the 2.0 g/hr. emission limit is already too lax. In 2014, EPA proposed to set a limit of 1.3 g/hr, which the Attorneys General of New York, Maryland, and Massachusetts supported based on demonstrated cost effective design technologies that could reduce emissions. 

New York State Department of Environmental Conservation (DEC) and New York State Energy Research and Development Authority (NYSERDA)

Albany, NY 

1.     The 2015 New Source Performance Standards for wood stoves, hydronic heaters, forced air furnaces (40 CFR 60 Subparts AAA and QQQQ) should not be reopened. Any changes to the rule (see items 2-3 below) should be addressed during the first review period for these rules in 2023. 

2.     The Environmental Protection Agency should adopt the Integrated Duty-Cycle (IDC) Test Methods under development by Brookhaven National Laboratory and the Northeast States for Coordinated Air Use Management prior to the 2023 rule reviews. 

3.     The 2023 rule reviews should lead to PM emission standards based on performance data generated using the IDC Test Method. 

4.     EPA should ensure that third-party certification reviews are not conducted by the laboratories conducting the certification tests. 

In the event that EPA weakens the 2015 NSPS rules, it is likely that several states, including New York, may consider backstop regulations to bring the NSPS provisions back into effect, potentially resulting in a patchwork set of state regulations that may increase compliance costs to manufacturers. 

Western Governors Association

Denver, CO

The emissions from wood heaters represent a critical public health and environmental issue in the West. Since the 1980s, states have implemented regulatory and voluntary strategies to address these emissions. The efficacy of such strategies depends on an effective NSPS.

The Western State Air Resources Council (WESTAR) requested that EPA extend the comment periods for the NPRM and ANPRM for an additional 45 days to provide sufficient time for state regulators to fully evaluate these proposals. WESTAR also requested that EPA hold a second public hearing in the West, as the only hearing on these proposals was held in Washington, D.C., with a minimal two-week notice. EPA summarily denied these requests, hampering the cooperative federalism that this Administration has made a priority.

Western Governors request that EPA maintain the current NSPS compliance deadlines for new residential wood heaters. 

Oregon Department of Environmental Quality

Salem, OR

Oregon communities depend on the NSPS and particularly the 2015 NSPS for residential wood heaters to complement our efforts to attain the National Ambient Air Quality Standards for PM2.5 to protect community health and environmental quality. Since wood heaters are not manufactured in Oregon, any public health costs associated with EPNs proposed rules in the NPRM or this ANPRM are disproportionately accrued to Oregon. 

Cordwood test methods

ODEQ is concerned that this language [in the ASTM 2515 cordwood test method]  allows manufacturer instructions to change almost any aspect of the emissions test method, without the requirement, such as fuel species or loading, to include these changes in the test report or the owner's manual. 

This language is highly problematic and opens up the test to significant modifications that impact emissions measured during the test. The manufacturer should not be provided the discretion to determine what information is provided to owners or regulators regarding test results. 

Considering the test method research described above, EPA should build upon this multiyear effort by adopt a requirement now, to take immediate effect, for the concurrent use of a tapered element oscillating microbalance (TEOM) test method to measure real-time particulate matter (PM), using the NESCAUM Standard Operating Procedures, along with standard filter measurements for all EPA residential wood heating device NSPS certification testing, including pre-burn activities. For all testing, a complete real-time emission profile should be submitted as part of the non-confidential business information (CBI) portion of the test report.

EPA compliance audit testing

'

With respect to the selection of the lab to perform audit testing, one independent, third-party lab should be selected to conduct all compliance audit testing so that there is consistency across the program. The audit testing lab must not be allowed to complete certification testing for devices that it is auditing to ensure that the audit process is unbiased. 

With respect to variability in the compliance audit testing program, wood stoves that certify at less than 1 gram per hour (g/hr) should be allowed a variability of ± 1 g/hr. For units that certify at more than 1 g/hr, the current variability provision is adequate. 

Warranty requirements

EPA seeks comment on retention, revision or elimination of the warranty requirements included in the 2015 NSPS Rule. DEQ supports the retention of the warranty requirements for catalytic devices. For non-catalytic devices, EPA should add warranty requirements, particularly ones for key components related to controlling emissions from the device (including, among others, tubes). 

Mass. Dept. of Environmental Protection

Boston, MA

In summary, MassDEP opposes any delay or weakening of the existing Step 2 emission limits, which would defer needed reductions in air pollutants that adversely affect the health of Massachusetts citizens. The existing NSPS has resulted in manufacturers developing cleaner wood burning devices that are achieving real emission reductions, and it is critical that the NSPS be fully implemented according to the schedule in the 2015 rule. MassDEP supports the development of new test methods that better reflect real world operations of wood heating devices, which should be included in the next update of the NSPS in 2023. 

Wisconsin Department of Natural Resources,

Madison, WI

EPA should therefore recognize that modifying the Step 2 limits or adjusting the Step 2 compliance date for wood heaters would disadvantage manufacturers who already completed the Step 2 certification process to comply with EPA's original deadline. 

INDUSTRY

Hearth, Patio & Barbecue Association

Arlington, VA

Test methods

Since 2009, HPBA has led efforts to move from crib wood testing to cordwood testing for all residential wood heating product categories, and we continue to support that transition. 

Sell-through

HPBA believes that a two-year sell-through period is critical to the health of the hearth products industry for —wood stoves, pellet stoves, hydronic heaters, and forced-air furnaces. 

Revising the current standards to provide a two-year sell-through period (from May 2020 to May 2022) for Step 1 stoves, roughly three-quarters of which are well under the 4.5 g/hr emission limit, would have a relatively miniscule environmental impact. 

Central heaters

EPA cannot remedy the errors in the Step 2 emission limits for central heaters by extending the compliance dates for central heaters. EPA should repeal those standards altogether. 

The Step 2 limit for forced-air furnaces was not based on any data. 

The Step 2 emission limit for hydronic heaters is not achievable at reasonable costs. 

Weighted Averages vs. Individual Burn Rates 

Compliance with all emission limits should be on a weighted average basis. Manufacturers often focus on performance at more heavily weighted burn rates. 

Compliance audit testing

EPA should limit audit testing to instances where there is suspected fraud in certification test results. Alternatively, EPA should add language to the regulations that prohibits audit testing for appliance categories until there has been a determination on variability for the applicable test. 

ISO-Accredited Third-Party Review 

EPA should rely on ISO-accredited third-party certification bodies to issue certificates of compliance rather than continue to issue every final certification application itself. This would allow EPA to focus its limited resources on performing oversight and enforcement functions. 

US Stove

South Pittsburg, TN 

Transition from Crib Wood to Cord Wood Testing 

USSC is fully supportive of working towards a cordwood test method that better represents real world use of residential wood heaters. Our company was actively involved in the ASTM standards development process for ASTM E3053 

As of today, there are companies testing and certifying stoves under this cordwood alternative, however hindsight is not a rulemaking mechanism that the EPA can or should use to regulate industry. The “limit” had already been set at 2.5 g/h before a test method even existed, and thus the EPA has artificially put its thumb on the scale. The only test reports that the EPA is going to see are those manufacturers who have been lucky enough to meet the 2.5 g/h limit. That is not how standards should be set. 

Feasibility of  the 2020 timeline

The EPA has stated it has given 5 years to meet the Step 2 2020 requirements. Although that may be true when looking at the actual dates, we, nor our industry as a whole, have not been given those 5 years to meet these requirements.  The 5 years that the EPA intended, effectively moved to 3.5 years in the eyes of the wood heater marketplace. 

At USSC we analogize the 2015 rule for residential wood heaters to the feat of climbing Mt. Everest, you have to strategically take one step at a time. 

It is our opinion that EPA also did not consider the reduced revenue which has occurred because of the lack of sell-through. Therefore, we have not benefited from 5 years of revenue required to fund the work necessary to meet the 2020 deadline. 

Forced air furnaces

The Step 2 requirements for forced-air furnaces as stated in the 2015 NSPS should be repealed; Step 1 standards for forced-air furnaces should be revisited at a future date to determine whether more stringent standards would be appropriate. There was no justification or data on the EPA’s part to warrant the Step 2 requirements. As we have stated above, the economic feasibility in the marketplace of a Step 2 compliant forced-air furnace is impractical given today’s technology. To move from a previously unregulated product (with no voluntary program) to Step 1 where these products are approximately 75% cleaner, and then in just 3 or 4 years later (small vs large forced air furnaces) move to approximately 97% cleaner (EPA estimates) at Step 2, without any data to justify a Step 2 limit, is preposterous and unrealistic.

Hearth & Home Technologies

Lakeville, MN

Test Methods – Transition to Cordwood

HHT strongly supports moving to a cord wood standard as it better aligns with the fuel type used in the real world, but manufacturers have invested millions of dollars designing, testing and certifying to Step 2 crib wood standards and will need additional selling time to recoup their investment to fund future cord wood designs. 

HHT recommends using ASTM E3053 until such time there is data showing that the ASTM method doesn’t replicate real-world cord wood emissions or that a new Federal Reference Method is needed. 

Step 2 Emission Limit for Wood Heaters 

The wood stove and pellet stove users tend to be very different people. With respect to different emissions standards, we believe this is a secondary issue to the EPA first understanding the precision and repeatability of the different fuels before making any more changes to emissions standards. 

The EPA Compliance Audit Testing 

It is not appropriate for the EPA to select a lab to perform audit testing. With so much variability, it makes more sense to keep compliance audit testing with the same lab.

ISO-accredited Third-party Review 

The only way to streamline the process would be to allow accredited third-party laboratories to do the emissions testing and grant the certificate of compliance. Having the EPA review the application and test report, which can take as long as 90 business days/16weeks to complete, is not a good use of time and resources. Instead, they should rely on their ISO-accredited third-party laboratories to issue certificates and the EPA retain oversight and enforcement with the laboratories. 

Warranty Requirements for Certified Appliances 

We would support eliminating the warranty requirements of the NSPS. All manufacturers already have warranty language that if the appliance is not installed and operated according to the installation/owner’s manual, the warranty will be voided. This language would be the warranty whether the EPA required it or not, it is standard warranty language for an appliance. 

Lamppa Manufacturing, Inc. 

Tower, MN

If our small company (Lamppa Manufacturing, Inc.) can pass the Phase 2 NSPS mandate (we were actually 40% cleaner than the Phase 2 mandate), these other manufacturers with their sizeable R&D resources should also be able to meet the mandate within the timeframe. Lamppa Manufacturing achieved the mandate solely by hard work and determination and by borrowing from our family's retirement funds. 

Lamppa Manufacturing adhered to the law and the timeline and has created a business plan based on meeting the NSPS. Our new manufacturing facility is being built at a cost of $1.8 million, plus the cost of additional production capital equipment . This investment would not have been undertaken if we knew the EPA was going to weaken or re-write the standard. 

Blaze King

Walla Walla, WA

We feel strongly that had EPA taken into consideration our comments for the 2015 NSPS, EPA and state regulators would have cordwood data that is real-world. 

Blaze King feels that Method 28R should be retained with crib fuel testing. We also feel that the goal of regulators, from various parts of the country with various species of wood, could be addressed. 

When a manufacturer advises EPA of an upcoming test of a wood heater, required by law, EPA would then direct the lab of record to conduct a randomly selected additional cordwood run. EPA would direct the test lab to conduct 1 run from low or medium low or medium high or high burn categories. Additionally, EPA would direct a species of wood for that run. The one extra cordwood run emissions result would not influence the weighted average. This would eliminate the need to have a cordwood standard specific passing grade and yet provide cordwood data. As an example, regulators from Washington would shortly have data for how catalytic wood heaters perform on low with Douglas Fir. Meanwhile, Eastern regulators would soon receive data on how secondary combustion stoves perform on hardwood on another burn category. 

Blaze King Industries, Inc. is aware of a letter sent to EPA date September 7, 2018 from the State of Maine Department of Environmental Protection (DEP). We are deeply concerned about a concerted effort by a state agency and a single manufacturer to work in concert to spread false, misleading and out of date information in an effort to secure market share. It appears the DEP is interpreting EPA’s solicitation of comments to include not just the bifurcation of pellet heaters from cordwood heaters, but additionally the return to bifurcated standards amongst cordwood heaters. The letter sent to EPA contains outdated and misleading falsehoods and statements. Blaze King Industries, Inc. is 100% in opposition to the bifurcation of cordwood heaters based upon current data and sound reasoning. 

In reviewing comments filed by retailers in the NOPR regarding sell through, we recognized the names of dealers that submitted the form letter provided to them by the manufacturer mentioned previously. We contacted those dealers to inquire why they signed a form letter that contained false statements regarding catalytic wood stoves. The response we received each time was...”Didn’t even read it, we thought it was about getting a sell through.” 

Blaze King encourages EPA to make their decisions, as they have in the past, on science and data. Not the claims of two parties working in concert to benefit a single manufacturer. 

Masonry Heater Association

North America

Although the MHA has submitted numerous comments, data research, and proposals, the EPA has not moved forward to consider the implications of adding masonry heaters to the EPA Certified List of Products. 

By leaving masonry heaters out of the EPA Certified Products List, the EPA is drastically limiting clean burning heating choices for American consumers, which is against the EPA’s purpose.

The inclusion of masonry heaters in the NSPS would allow a cottage industry to grow into an industry that could encompass masonry contractors and hearth retailers throughout North America and promote the replacement of inefficient masonry fireplaces into safe, clean burning hearth systems. MHA research is “open source” and MHA intends to continue to share test data and assist state and federal agencies to promote clean burning options for customers who want the benefits of radiant heat and single batch burning appliances. 

Heat Master, 

Manitoba, Canada

We hope that the following improvements can be made to the regulations:

·       Eliminate Step 2 emissions until more data on cordwood testing using a widely accepted testing method can be collected to determine an effective, achievable level that reflects real world results as accurately as possible. 

·       Go back to the weighted average rather than individual run criteria in testing 

·       Use ISO Accredited 3rd party view to speed up the approval process for newly tested models 

·       Start categorizing pellet fuel appliances and cord wood appliances separately 

RETAILERS

Yoder Outdoor Furnaces LLC
Floyd, VA

My biggest concern has been the complete lack of enforcement by the EPA. Any person willing to take an hour or two can find on the internet numerous smaller manufacturers advertising untested and unapproved models of wood stoves and hydronic heaters. This has been a huge hindrance to sales of approved Step 1 units (like our G series) as they are $1,500 to $3,000 higher than these cheap polluting models. Our sales post 2015 are about 50% of pre-2015 levels. HeatMaster is promoting that their dealers comply with the 2015 NSPS. Which we should, but it has come at a cost.I would guess that until enforcement actually happens no manufacturer can afford to invest heavily in testing as these cheap illegal models will not allow them to recoup costs. 

RLS Energy

Eaton Rapids, MI

Currently there is very little enforcement of the law. In my area I have heard of installs that to not comply. A commercial stove, legal at a business is not legal at a home. But no one checks. Any law without enforcement is nothing more than a request. Honest manufacturers and dealers will follow the law and the unscrupulous characters will cheat. I lose out when the cost of a compliant stove is above the cheater stove. If EPA wishes to regulate our products, they need to enforce it so that the good dealers and manufacturers who are acting 

in good faith don’t get punished. All we ask is for a level playing field.

Anonymous (retailer)

 In the last 3 years, I have lost approximately 50 sales to other manufacturers and dealers that have completely ignored the law and sell illegal appliances to customers. I support reducing emissions from wood burning appliances, but I feel as though the EPA needs to enforce their lawmaking if they are making laws. We are trying to follow the laws but feel as we are being punished for it by lack of enforcement on companies who aren’t. 

AIR QUALITY AGENCIES

Northeast States for Coordinated Air Use Management (NESCAUM)

Boston , MA

NESCAUM opposes any changes to the emission standards promulgated under the 2015 NSPS. There is simply no need or basis to delay or weaken the standards in light of the large body of evidence demonstrating they are technically feasible and cost-effective. 

NESCAUM does not support any sub-categorization scheme under the NSPS and urges EPA to maintain the current single standards for all space heating devices and for all central heaters. Establishing different emissions standards based on control technology is contrary to the fundamental construct of the NSPS program, which embodies the notion that emissions standards are established according to the best system of emission reduction (BSER), rather than on specific control technologies. If EPA decides to sub-categorize, it must provide details as to the data used to deem the current BSER analysis deficient and complete new BSER analyses for each potential category to support sub-categorization. 

EPA must require that a different lab be used for audit testing than was used for certification testing to minimize biases associated with the pre-existing relationship between test facility and manufacturer. NESCAUM suggests that EPA consider using a single and independent federal lab, such as Brookhaven National Lab, for all compliance audit testing. 

NESCAUM recommends that EPA use the Integrated Duty-Cycle (IDC) approach as the platform for certification testing of all residential wood heating appliances in the future. This procedure is designed to be accurate, representative, repeatable and affordable. It incorporates emission measurements during typical operating situations, including start-up, reload, and transition across various heat output loads. The single-day test allows for replicate testing without increasing certification test costs. 

NESCAUM does not believe that the ASTM or CSA cordwood test methods for heaters, furnaces and boilers, as currently designed, effectively replicates real-world conditions nor do they provide solutions for precision and variability concerns. 

Existing information indicates that redesigning wood heating devices to comply with Step 2 emission standards has not generally resulted in increased retail prices. In fact, verified consumer cost data from state woodstove change-out programs show that on average, cordwood stoves with emission performance levels below the Step 2 standard of 2.0 grams per hour are priced somewhat less than those with certified emissions above 2.0 grams per hour. Many states in the Northeast provide incentives that further reduce the cost of purchasing and installing high efficiency, low emissions wood heating appliances. 

NESCAUM requests that EPA sunset EN303-5 as a qualified certification method for the NSPS as soon as possible, but no later than the May 2020 deadline in the rule. 

EPA should adopt a requirement, to take effect immediately, for the concurrent use of a tapered element oscillating microbalance (TEOM) test method to measure real-time particulate matter (PM) during certification testing. We recommend using the NESCAUM Standard Operating Procedures. 

National Association of Clean Air Agencies (NACAA)

Wash. DC

Compliance dates

EPA must undertake a review of the 2015 NSPS in 2023 and, based on its review, must revise the standards, if needed, to reflect improvements in methods for reducing emissions. EPA should reserve any review of or amendment to the level of or compliance dates for the 2015 NSPS until the statutorily required NSPS review, to begin in 2023. 

Transition to cordwood

NACAA does not, however, support any changes in this regard at this time. Rather, the agency should begin now to develop new test methods as described in these comments, above. With a rigorous schedule these methods could be completed and available for the statutorily required NSPS review in 2023. We urge that EPA work closely with state and local air agencies, as well as other stakeholders, throughout this test-method-development initiative. 

Also related to testing, EPA should adopt a requirement now, to take immediate effect, for the concurrent use of a tapered element oscillating microbalance (TEOM) test method to measure real-time particulate matter (PM), using the NESCAUM Standard Operating Procedures, along with standard filter measurements for all EPA residential wood heating device NSPS certification testing, including pre-burn activities.

Weighted Averages Versus Individual Burn Rates for Hydronic Heaters and Forced-Air Furnaces 

In the final 2015 NSPS Rule EPA did not include a weighted-average approach for HH and FAF Step 2 compliance and, instead, called for these devices to meet the standards at each individual burn rate to prevent large emission discharges. 

NACAA opposes the use of a weighted-average approach, which minimizes peak emissions, thereby presenting a less accurate reflection of in-field performance and would have the effect of weakening the Step 2 standards. The best system of emission reduction (BSER) analysis conducted by EPA for the 2015 NSPS Rule, and which underlies the Step 2 standards, did not include use of a weighted average. If EPA believes compliance should be determined with a weighted average instead of an individual burn rate the agency should conduct another BSER analysis to make this case and also demonstrate why its analysis for the 2015 NSPS Rule resulted in a different conclusion. 

EPA Compliance Audit Testing 

With respect to the selection of the lab to perform audit testing, one independent, third-party lab should be selected to conduct all compliance audit testing so that there is consistency across the program and that a lab that conducts certification testing is not permitted to conduct audit testing. 

With respect to variability in the compliance audit testing program, wood stoves that certify at less than 1 gram per hour (g/hr) should be allowed a variability of ± 1 g/hr. For units that certify at more than 1 g/hr, the current variability provision is adequate. 

ISO-Accredited Third-Party Review 

NACAA does not support allowing the EPA-approved lab that conducted the certification testing to also act as the third-party reviewer of the test results and recommends that EPA amend the 2015 NSPS Rule to prohibit this from occurring. 

California Air Resources Board

Sacramento, CA

Test methods

CARB supports the progress of the integrated duty-cycle test method being developed by Brookhaven National Laboratory and the Northeast States for Coordinated Air Management (NESCAUM).5 The proposed test methods address what is absent in the current test methods. 

The ANPRM’s requests for information with respect to the emission limit for wood heaters do not request the right information, are biased and outcome seeking towards collecting evidence for weakened standards and miss the opportunity to collect the data necessary to perform an accurate and complete economic and regulatory impact analysis. 

Step 2 Emission Limits

Asking “whether Step 2 is achievable at a reasonable cost” is not the correct framing of the question. The answer to this question seems predetermined, particularly for those who ostensibly have “been unable to design a wood heater to meet the Step 2 standard.”28 There is no information provided as to how to identify what is “reasonable,” nor is there any request for the necessary evidence to back up a claim that a cost is not “reasonable.” Leaving a regulated entity to decide what cost is “reasonable” will undoubtedly provide a biased and outcome-seeking response. 

Electronic Reporting Tool (ERT) 

CARB supports the use of modern electronic reporting tools for both the certification process and subsequent public use. Electronic submission will speed up the certification process, increase transparency, and give the public up-to-date information on certified devices and those waiting certification, as well as information on devices that been denied certification and why. U.S. EPA should insure that information in the database will remain available. Wood heating appliances are made to last decades and the public should be able to get information on any certified stove, no matter when the certification was achieved.

Warranty Requirements for Certified Appliances 

The requirement to offer a warranty on a new residential wood heater is particularly critical in low-income households. Due to financial constraints, low income households often buy the least expensive devices; if problems arise, they may not have resources to buy replacement parts, leading to unsafe and higher polluting operations. 

Minnesota Pollution Control Agency

St. Paul, MN

Timing

This notice requests comments on nearly every aspect of the standard: test methods being used or planned for use; the feasibility of meeting the promulgated compliance deadlines; the feasibility of the promulgated emission limits; revising averaging periods used to determine compliance with the standard; how testing companies are regulated; and how testing data is provided to EPA. 

Some of these concerns may merit evaluation, however, the MPCA believes that conducting this assessment prior to final implementation of the standard is premature. EPA is already required to re-evaluate the NSPS under Section 111(b)(1)(B) of the Clean Air Act (CAA)-the Act requires EPA to re- evaluate NSPS eight years after adoption. The MPCA believes that EPA should reserve any review of or amendment of the 2015 NSPS, and instead conduct its revisions or re-evaluations under its authorities of the statutorily-required NSPS review after the compliance deadline. 

Weighted averages vs individual burn rates 

EPA is soliciting comment on determining compliance with weighted averages instead of individual burn rates. A federally enforceable emissions standard is composed of an emissions limit, a method for measuring or determining emissions, and an averaging period. Similar to our comment about using a new emissions test method, revising the averaging aspect of the emissions essentially revises the standard. In order to consider a weighted average, EPA must evaluate all aspects of the standard- emission limits, averaging periods and the emissions testing method that the emission limit is based on. 

Conclusion

The record also highlights the several decades EPA and states have worked with the wood heating industry to develop clean, efficient heating products. To that end, the compliance deadline should come as no surprise to any party involved in developing, testing, or manufacturing the equipment. The contemplated changes are deeply impactful to public health; implementation of the standard should not be delayed. 

Missoula Public Health Department, 

Missoula, MT

When the EPA considers rule changes to the 2015 NSPS, the Board recommends the following: 

1. Maintain, at a minimum, the 2015 NSPS Step 2 emission limits for new residential hydronic heaters, forced-air furnaces and wood heaters. 

2. Keep the 2020 compliance date for the Step 2 emission limits for forced-air furnaces, hydronic heaters and wood heaters as specified in the 2015 NSPS. 

3. Cord wood testing methods should continue to be developed and provided as an option for emission testing since cord wood more closely mimics how consumers use wood heating devices. 

4. As more is learned about appropriate cord wood testing methods, a path for switching exclusively to cord wood testing for wood heating devices should be incorporated into the wood stove NSPS. 

Any delay or weakening of the 2015 NSPS would harm public health and make it harder for local jurisdictions to maintain or achieve the National Ambient Air QualityStandards for particulate matter in the air 

FEDERAL OFFICE

Advocacy Office, Small Business Administration

(This office does not necessarily reflect the position of the SBA or the Administration.)

Wash. DC

Because Advocacy is an independent office within the U.S. Small Business Administration (SBA), the views expressed by Advocacy do not necessarily reflect the position of the Administration or the SBA. 

Advocacy strongly supports the proposal to provide a “sell-through” for hydronic heaters and forced-air furnaces and strongly supports extending a similar provision to wood heaters. 

In addition, in response to the Advance Notice of Proposed Rulemaking, Advocacy recommends EPA consider the following measures to reduce the burdens on small businesses. 

·       Delay the step 2 compliance date by at least two years. Small businesses have lost the sales of their step 1-compliant appliances for the 2019-2020 winter, which has had the effect of forcing exit from the market and delaying R&D for step 2-complaince appliances. 

·       Review certification procedures to eliminate delays that do not contribute to environmental benefits. EPA should examine its records of step 2 certification to determine whether EPA pre-approval has prevented non-compliant appliances from coming to market. If the significant delays reported by industry are a result of incomplete submissions that have not required subsequent changes to the underlying appliance, then EPA should allow self-certification based on third-party testing. 

·      Reconsider treating all residential wood heaters as one product category. EPA regulates residential wood heaters fueled by wood pellets the same as those fueled by cord wood. While this is consistent with EPA’s stated desire to not show preference to any particular fuel in its air quality regulations, it may not be appropriate in a market where the vast majority of intended air quality benefits come from replacements rather than new installations. A customer seeking to replace a wood heater fueled by cord wood is discouraged from changing out if the available replacements are mostly fueled by pellets. 

 NON-PROFIT ORGANIZATIONS

Earthjustice, Environment and Human Health, Inc., Environmental Defense Fund, Environmental Law & Policy Center, and National Parks Conservation Association

Wash. DC

Weighted Averages 

EPA’s suggestion that the agency may revisit the possibility of using weighted averages instead of requiring compliance with emission standards at each burn rate for central heaters would needlessly reopen an issue that was thoroughly examined and resolved in the 2015 final rule. See 80 Fed. Reg. at 13,684, 13,690. In order to ensure that wood burning devices do not harm public health in any reasonably anticipated operating mode, EPA must require units to comply at each burn rate, not merely on a weighted average of the unit’s performance at each tested rate.

Fuel-Specific Standards 

EPA’s observation that more pellet stoves meet the Step 2 standards than crib or cord wood stoves does not support the adoption of weaker emission standards for crib or cord wood-fired heating devices. The fact remains that the Step 2 standards are achievable using crib or cord wood. Section 111 does not require EPA to establish standards of performance that can be met by all types of sources using all types of fuel. 

Integrity of the testing and certification process. 

EPA seeks comment on whether compliance audit testing “should be performed by the same lab that did the certification test for a given wood heater appliance.” 83 Fed. Reg. at 61,592. EPA does not suggest what advantages this approach might have, but it has at least two clear drawbacks. First, engaging different labs to conduct audit testing will likely help to reveal ambiguities in the application of EPA’s test methods to specific products, by increasing the opportunities for different personnel at different testing labs to apply the same test method provisions to the same model of wood burning equipment. 

American Lung Association

Wash. DC

The Step 2 Standards adopted in 2015 were more than two decades overdue, despite explicit requirements in the Clean Air Act that such standards must be updated every eight years. They already included an unusually long implementation period. Normally, new source performance standards must be met immediately by the affected industry, particularly when the technology needed to meet these standards exists and is in use today. The European System showed in 2010 that comparable units were possible and produced greater efficiency in wood use and heat production (MusilSchläffer et al., 2010). Furthermore, as EPA notes, more and more American manufacturers produce many product lines that already meet these standards. However, the 2015 standards afforded industry five years to meet the new requirements, far longer than other industries, such as the automobile industry, receive. 

Alliance for Green Heat

Takoma Park, MD

Cats vs. Non-cats

AGH believes it is premature to artificially protect the market for non-catalytic stoves by extending a sell-through to all classes of stoves, including pellet stoves. 

Insufficient cost data on Step 2 stoves 

While we are likely to see a small rise in the price of many stoves as a result of Step 2 compliance, there is a noticeable lack of data supporting such a conclusion. 

Insufficient data that consumers will hold off buying new stoves 

There is very little data about the proportion of consumers buying a wood or pellet stove for the first time, as compared to those who are replacing an older stove. And often families switch from wood to pellet stoves, or vice versa. First time stove buyers and those who will buy a stove anyway, may be far more numerous than those who would have bought a new stove if it were $100 cheaper. 

Minimal public support for sell-throughs 

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In 2014, EPA received 1,750 Comments in response to proposals that set 2020 as the deadline for Step 2 compliance. Just 5 years later, the process led by the current administration’s EPA generated only 75 comments for the sell-through for furnaces and boilers, including comments from less than 10 individual citizens. In addition, there is no state, county or city that supports providing a sell-through for what constitutes the dirtiest appliance class among wood heaters. 

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