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)

AGH urges DOE's bioenergy office to expand focus of funding

The Bioenergy Technologies Office of the U.S. Department of Energy recently asked for input on promoting the development and testing of low-emission, high-efficiency wood heaters. The deadline to reply is 5:00 PM on Monday, September 21, 2020 and the Alliance for Green Heat (AGH) continues to urge stakeholders to provide feedback to the DOE.

Diagram of stove field testing unit.

We also urge stakeholders to reinforce points made by AGH in your submission to the DOE. Please feel free to copy any of the points we make below, put them in your own words and/or develop them further. If you feel any of our points are off-base and should be changed or expanded, please email John Ackerly at jackerly@forgreenheat.org. For more background, click here.

Dear DOE,

Thank you for requesting input through this Request for Information (RFI). We are especially thankful that BETO has embraced this relatively small effort to distribute $5 million to support developing and testing new wood heaters. We are also mindful that the effort required to run a $5 million grant program may be similar to the effort required to run a $50 million program.

The wood heating manufacturing community has not had this kind of support from a government agency in the past several decades. However, it came at a time when the manufacturing community was in the final stage of testing to meet the stricter 2020 EPA emission standards. Much of the community does not have experience applying for federal grants, which can be challenging for smaller firms.

R&D labs could apply to test stoves after certification to help assess effectiveness of designs on emission performance.

We are encouraged that some of the questions posed in this RFI may indicate BETO is open to expanding the focus of future grant cycles. Questions on the performance of stoves already installed in homes and field testing are important as they embrace the life cycle of heaters. Congressional language has urged BETO to “support development and testing of new domestic manufactured low-emission, high efficiency residential wood heaters.” Testing of new heaters can also occur once they are installed in the field. Testing can include various iterations of round robin testing before or after certification. And, the development of new heaters can include the development of component parts, software applications, and other essential stages in the development process, not just the final act of assembling a finished stove for certification.In short, we fully support BETO to follow the Congressional language and not add additional restrictions or preconceptions about the traditional stove certification process.

We think that the barriers to developing and testing new stoves are not the only barriers stove manufacturers face. Thus, we are unsure if the list of technical questions you ask will solicit robust feedback on many key issues pertaining to the development of heaters. The engineering expertise and solutions to these questions can be built up. Many academics, non-profits and jurisdictions are eager to engage in more field testing of new stoves, and to do additional types of testing before deployment. 

 

Norbert Senf, AGH's board chair, introducing the SBI team at the 4th Stove Design Challenge. SBI later won one of the DOE grants with their US partner.

We understand from discussions with industry that few of the larger mainstream stove manufacturers have applied for grants in the last two grant cycles. Yet, there are urgent funding needs in the broader wood heating sector to help the development and testing of genuinely cleaner and more efficient wood heaters.

Renewable energy technology development often happens quickly when there is significant government subsidies and expanding consumer demand. The DOE’s programs supporting solar PV, paired with Congressional support for significant tax breaks, is a good example.

BETO’s program can help on the technical side of this equation by promoting the development and testing of heaters that meet the requirements of modern renewable energy incentive programs. These programs often need to better understand field performance characteristics of the technology in question.

Round robin testing at US stove labs are badly needed to assess testing variability.

Unlike some European counties, U.S. federal and state agencies have barely ventured into the realm of aggressively promoting the cleanest heaters, which first requires the development and testing of classes of heaters that are appropriate for greater deployment. State policy frameworks are beginning to shift from decarbonizing electricity solely to also include decarbonizing heat, and it is likely that the federal government will do so as well in coming years. BETO can play a vital role in preparing for this by focusing on technical issues related to heater development and testing.

We are providing answers to those questions where we have the most expertise and where we think BETO can be most influential.

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.)?

A. We applaud BETO’s focus on supporting efforts to develop automated heater controls, as these are one of the most effective ways to improve performance over the lifetime of the heater.

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.)?

A. Some technical solutions, such as adding an ESP, exist; however, these quickly can become more expensive than a stove replacement. The most cost-effective changes relate to the fuel used, and significant change in this area may require new local and state firewood regulation. For BETO’s mandate to support not just the development of heaters but also testing, there is much work to be done on testing new heaters that have just been installed in homes to better understand how performance can be improved.

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

A. Automation of stoves is one of the most promising ways to improve transient emissions. Changes in test methods are also vital, and test methods depend on developing data about transient emissions and making that data transparent to the public.

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

A. There is an increasing variety of technologies to measure not just transient emissions, but all emissions, both in the lab and in the field. The problem is that there is little funding or mandates for them.

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?

A. Many of these systems exist as prototypes or are on the market, especially in Europe. There are few technology barriers to this approach. When policies mandate increasing residential renewable heating, hybrid systems will emerge to make use of the strengths of different technologies and the seasonal costs and availability of electricity, solar, biomass and stored energy. BETO could play an important role by focusing future FOAs on hybrid systems and making R&D funding available for the integration of wood heaters with heat pumps. Funding could be routed through heat pump companies, wood heater companies or even software companies to achieve this. Integrating solar thermal with biomass thermal also holds tremendous potential.

Annual emission testing using handheld devices like the Testo 380 is vital to understand impacts of wear and tear on emissions.

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

A. Testing new heaters in real world settings is vital before and after the certification process. Manufacturers need equipment to enhance their beta testing in homes during the winter(s) before they finalize and certify products. Academics and non-profits can use existing or newly developed equipment to test emissions of newly certified heaters once they are installed in homes. In terms of ambient air quality, a variety of sensors, including the Purple Air sensor network, exist or could be developed to help understand impacts of stove groupings. States that have enforcement capacity and use opacity criteria in the field, such as Washington State, have experience with identifying and understanding why certain stoves may be particularly problematic. Sensors or sensor networks could also calculate the benefits of deploying the cleanest heaters, instead of perpetually trying to monitor, enforce and manage emissions of traditional certified wood stoves that can burn unseasoned wood at low air settings at any time.

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?

A. Price is a top consideration. Clean glass is another. Aesthetics are always a driving factor. The actual or perceived ease of use can be very important. Heating capacity, log size and burn time are key for many consumers. There are also different considerations for wood versus pellet stove customers, and for those looking for a primary versus a periodic or secondary heater. Fuel management is also a big issue, with some operators switching to pellets to avoid the enormous work of wood stoves, and others giving up pellet stoves because they can’t lift 40-pound bags. For pellet stoves, durability, reliability and access to professional service should be higher priorities than they are currently. BETO could play a very productive role in developing durable pellet stoves that use interchangeable, easily sourced replacement parts, for example.9. What advantages or disadvantages would continuous field performance data provide for advancing stove designs?

A. This sort of data is extremely valuable, and funding programs to collect it would help develop and test new wood heaters. This data is also helpful in developing new test protocols, which in turn would lead to changes in stove design. Depending on the metrics produced and how they are communicated, data could help consumers operate stoves better. It could also help stove R&D departments, especially if the data came from the stove manufacturer's own stoves. If this data is only available in summary form via a regulatory agency, it would have diminished applications. There is tremendous potential and a wide range of opportunities to gather certain types of field performance for different stakeholders: users, neighbors, retailers, manufacturers, air quality agencies, academics, etc. Continuous field performance data is currently collected by solar PV installers, internet providers and auto makers, for example, for a wide variety of purposes. One of the most obvious is to help with remote trouble shooting, which in turn leads to the R&D of software and hardware that avoids those issues.

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?

A. Most mid-sized and larger manufacturers have their own in-house labs for testing. Increasingly, the definition of a testing facility or testing lab is broadening, as more affordable and handheld equipment comes on the market, enabling anyone to enhance their in-house testing capacity. The third-party labs used for certification have the capacity to handle testing but the time and cost involved is a barrier. If the time and cost involved were less, companies may engage in more R&D and update their stove designs more often. Currently, when a stove model gets certified, it can remain unchanged on the market for 10 or 20 years, or until required by the EPA to test again to meet a new NSPS.

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?

A. A variety of test methods and practices are of great interest to AGH, starting with cord wood testing using test methods involving multiple labs, or being used on new stoves after installation in the field.

Stove testing is often considered as exciting as watching paint dry. Here, AGH researcher Gabriel McConnel assists in DOE's Brookhaven lab in advance of a Stove Design Challenge.

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?

A. Current methods usually do not evaluate heater performance apart from the narrow conditions under which they were tested. There is much potential in affordable measurement methods. The more complex part is whether manufacturers will have the motivation to use them.

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?

A. 1. Funding. AGH could engage in extensive activities to advance stove development and testing with more funding.

2. Lack of a more robust community of academics, non-profits, agencies and private sector companies involved in innovative stove designs and testing.

3. Lack of policy frameworks that focus on decarbonizing residential heating and a lack of incentives for the very cleanest and most efficient heaters.
 

Sincerely,




John Ackerly,

President

Alliance for Green Heat

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.

HPBA 2020 Expo showcases all new stoves to smaller audience

Jack Goldman, right, opens the 2020
Expo in New Orleans.

Updated, April 9, 2020: The hearth industry’s annual marketplace for manufacturers and retailers concluded on March 14^th, a half a day early in New Orleans amidst a dwindling crowd and growing concern about the spread of Covid-19. This was the first hearth industry gathering since the late 1980s in which virtually all the stoves and boilers on the floor were newly redesigned and tested to meet stricter emission standards.  

Some manufacturers were clearly proud of what they felt were genuinely cleaner stoves while others were unconvinced or cynical of the new standard’s impact in the real world. 

Mark Shmorhun of the DOE's
Biotechnology office
attended the Expo to talk to
manufacturers about R&D
funding needs.

Due to Coronavirus concerns, Travis and Jotul, two large manufacturers, pulled out at the last minute, leading to a notably smaller Expo. U.S. Stove, having dropped their HPBA membership, decided not to attend this year, presumably because their inability to meet the 2020 emission standards on most of their appliances weakened their position in the hearth industry.  US Stove has 18 stove models that are 2020 compliant but no 2020 compliant furnaces yet, an area it had once domoniated.  US Stove responded to this blog, saying they are well positioned to move forward with a broad range of new and exciting products.

From the perspective of the Alliance for Green Heat, the 2020 Expo showcased several notable trends, some encouraging and others troubling.  

Vesta gives Best in Show award to an automated wood stove

Possibly the biggest highlight for AGH was seeing automated stoves take more of a foothold in the marketplace. Napoleon’s Eco Smart wood stove won Best in Show at the Vesta Awards, marking the first time that an automated stove won a Vesta Award.  The stove has an optical sensor that monitors particulate matter and can continually adjust air settings to produce a cleaner burn. According to Napoleon, the automation will only add $300 to the price and they expect the complete system with stove to retail for about $2,500. The stove also connects to the Napoleon cloud via the user's smart phone so they can monitor combustion conditions. The user can also allow the company to log data from the stove, providing a valuable record of how the stove runs. The stove is not yet EPA certified, but should be within months. 

The Charnwood Skye 2700, expected to
retail for about $3,300, several hundred
more than its non-automated cousin.

Charnwood, a British manufacturer, also was a finalist in the Vesta award, with their Skye E2700, also an automated stove that does much of what the Napoleon does, but with different technology.  Charnwood will be entering the US market for the first time later this year with this stove. Hugh Wells, head of the Britsh company told AGH, "We are very excited about this product because it does revolutionise how we burn wood by taking out user error." CFS-Teco did the certication testing in Portland and it achieved 78% efficiency, the highest of any non-cat. 

SBI should also have an automated stove on the market within a year, and MF Fire had their automated Catalyst on display at the Expo and have another one in development.  Maxitrol also exhibited a prototype of an automated stove and says that they are taking off in Germany.  Napoleon also won a second Vesta award for their novel "Heat & Cool Electric Fireplace," a mini-split heat pump housed in an electric fireplace.  

2020 stove trends

The 2020 NSPS has resulted in many more catalytic and hybrid stove models. AGH is particularly

Larry Brockman from the EPA's
voluntary Burn Wise program
talks the MF Fire staff about their
automated stove.

happy to see more hybrid models as they help reduce start-up smoke and provide back-up secondary combustion if the operator does not engage the catalyst. A more unnoticed trend is the rapid adoption of the ASTM E3503 cordwood test method. Data from the EPA list of stoves shows the average grams per hour for cordwood tested stoves is 1.6 grams – the exact same average for crib tested stoves. About 45% of all 2020 certified wood stoves were tested with the ASTM cordwood method, which reportedly has more flexibility in its parameters making it easier for manufacturers to pass the certification test. Nearly all of the smaller non-cat stoves were tested with cordwood. Quite a few very affordable stoves that sell primarily in big box and hardware stores are passing the 2020 standards, and some stoves barely had to undergo any redesign.  

A sophisticated, lower priced electronic precipitator

ESPs for wood stoves, considered
far-fetched just a few years ago, are
improving rapidly and popular in
Germany and Switzerland. 

Danish manufacturer Enervex brought a self-cleaning electronic precipitator, known as an ESP. They are commonly used by factories and restaurants, but now small and affordable enough for residential applications. ESPs are a type of scrubber that uses static electricity to remove particulate matter from exhaust fumes before the particulates exit the smokestack. Enervex’s innovation is to design a residential ESP that is self-cleaning, often a big problem, and to bring the price down. They expect theirs will sell for $1,200- $1,600 when it comes on the US market. There is a quickly growing market for them in Germany, now that they are recognized by the country's eco-label, Blue Swan, and some cities may require them. OekoSolve, a Swiss company, made the ESP being tested in Fairbanks.

HPBA recruits Appalachia Service Project to take 2015 stoves in May

To address the fate of potentially hundreds of wood stoves that are 2015 certified but not allowed to be sold after May 15, 2020, HPBA negotiated with the EPA to allow retailers to donate stoves to a non-profit who can them install them. HPBA is teaming up with the Christian ministry Appalachia Service Project, based in Tennessee, who repairs homes in Central Appalachia, making them warmer,

AGH President John Ackerly with
Adam Bean of the Appalachia
Service Project

safer, and drier. At the Expo, AGH met with Adam Bean, Home Repair Coordinator for the group, who is quickly learning about wood stove installations and trying to estimate how many stoves his group has the capacity to install, which will partly depend on securing donated NFI installing and training.

Pellet stoves out of the limelight

Even though pellet stoves were relatively easy to redesign and test at 2 grams an hour or lower, the market for pellet stoves has not been particularly good and there were not many on the Expo floor. There were no pellet stove finalists in the Vesta Awards, which may indicate a pause in innovation in the North American market.

EPA announces final NSPS rule during Expo

On the first day of the conference, the EPA formally announced that they would not allow a retailer sell-through. The EPA had said on October 15, 2019 that entities should follow the compliance dates but some felt that there was still a chance for a sell-through. HPBA expressed its disappointment in a written statement while the Pellet Fuel Institute claimed a victory because the EPA removed minimum requirements from pellet fuel while retaining the prohibition that pellet fuel must not contain any of the prohibited fuels listed in the 2015 NSPS. There remains considerable debate about whether the 5-year timeline would have been enough if manufacturers had started redesigning and testing to the 2020 standards early in the process. Key excerpts of the EPA ruling provide detailed insight into why the EPA did not allow a sell-through. Some did start early and began offering 2020 compliant models to their retailers as soon as 2018, while most did not start releasing 2020 models until 2019 or even this year.  The issue was far more complicated because manufacturers had large inventories of 2015 stoves and some needed the cooperation of retailers to buy their 2015 inventory well into 2019. An HPBA mailer to retailers in 2019 said: “retailers and distributors should NOT immediately stop buying anything that doesn’t meet Step 2” in part because there wasn’t enough variety and in part because manufacturers still needed revenue from sales of their 2015 inventory.

EPA holds 3-day wood smoke workshop

One of the main reasons AGH attends the annual HPBA Expo is to participate in workshops

The wood smoke workshop brought
scores of experts from across the US
to share new knowledge, tactics and
success stories.

organized by the EPA on wood smoke reduction strategies. This year the workshop was coordinated and supported by EPA's Burn Wise, the Western States Air Resources Council (WESTAR), the Northeast States for Coordinated Air Use Management (NESCAUM) and National Tribal Air Association (NTAA) and was going to be the largest one ever, with nearly 100 federal, state, local and tribal participants registered.  But some states like Washington banned their employees from travel and many other participants cancelled, leaving a group of about 60. The workshop mainly consisted of a series of talks and powerpoints about change out programs, cord wood test methods, the impact of the NSPS, DOE funding opportunities for stove R&D, retrofits and ESPs, low cost consumer air quality sensors, indoor air quality issues, addressing wood smoke complaints, etc. Most of the powerpoints can be dowloaded here. AGH also hosted a gumbo and etouffee networking reception on Frenchman Street for all the participants. 

The 2021 HPBA Expo is scheduled for March 4-6 in Nashville, Tennessee.

EPA urges manufacturers to stick to May 2020 compliance deadline; says its working towards a cordwood test method rulemaking

On October 15 the EPA provided an update on its wood heater website page urging “affected entities to continue efforts to certify compliance with the NSPS in light of the upcoming May 15, 2020, compliance date.” According to NSPS legal experts, the EPA sometimes issues such updates to provide more transparency when stakeholders need certainty due to an approaching deadline.  

[March 11, 2020 update: The EPA finalized amendments to the 2015 NSPS and did not provide a retailer sell-through.  They did remove pellet fuel minimum requirements but retained the list of prohibited fuels in the 2015 NSPS.]

The October 2019 update is widely interpreted to mean that there will be no sell-through for whole house heaters or any other significant changes in the regulations issued by the EPA in 2015. However, the details of any changes to the 2015 rules will come later this fall when the EPA issues the Final Rule.  

The news was welcomed by the Alliance for Green Heat and many stakeholders, including manufacturers and importers of wood heaters who have invested in R&D and retesting of their heaters that comply with May 2020 emission standards.   Nearly 200 models of wood and pellet heaters are certified to the 2020 standards and virtually all stove companies say they will be ready for May 2020.  Some include innovative designs that achieved emission levels that are six times cleaner than the maximum allowed in 2020.

The sectors of the wood heater industry that most needed a sell-through are the outdoor wood boiler and indoor forced-air furnace makers, both of whom are represented by the trade group Hearth, Patio and Barbecue Association (HPBA).  HPBA’s strategy of seeking relief from Congress and the Administration appear to have fallen through, leaving its litigation against the EPA as the most viable channel for relief.  But that relief will likely not occur before May 2020.

Test methods

 

A Canadian company who never
had an EPA certified heater
saw a new market open up
for their AirBilo Furnace.

Much of the EPA’s update addressed test methods, and the EPA noted that a newly approved broadly applicable alternative test method for furnaces “may facilitate the ability of manufacturers” of furnaces to comply by May 2020.  This is not the type of relief sought by HPBA, and it’s not yet known if many other furnaces will use this test method for certification.  However the EPA puts it in the context of providing some relief.  It was given to a Canadian company mostly known for maple syrup boilers, but who also makes a very affordable forced air furnace.

The EPA used this update to message that it is already moving on to the next proposed rulemaking, which will be on cordwood test methods.  The update said, “in the coming months, the agency is initiating a series of roundtable discussions with states and other stakeholders to inform the agency’s direction toward a cord wood-based compliance test method.”  In March 2016, the EPA laid out a process for developing improved cordwood test methods. By statute, the next NSPS should be in 2023 but the EPA could issue this rule making earlier.  AGH believes the next NSPS should not focus on reducing allowable PM without first modernizing test methods to ensure heaters are designed for real world use.

Part of the HPBA’s litigation focused on an agency decision to set a 2.5 gram an hour emission standard before setting a test method to meet that standard. Subsequently, an industry led ASTM committee developed the E3053 test method which has become a commonly used method along with the standard crib wood method that has been in use since the late 1980s.   The ASTM method is being widely used now but came under scrutiny by the EPA because of lax reporting by labs using the method.

NESCAUM is developing "Integrated
Dute Cycle" protocols based on the
way stoves are used by consumers.

Since the ASTM method became a “broadly acceptable” alternative test method, NESCAUM has dedicated substantial resources on a broad and ambitious effort to develop a range of new test methods for stoves, boilers and furnaces, as well as for pellet heaters.  The NESCAUM effort is partially funded by NYSERDA and the process and data is not fully public but ultimately it could provide the largest database of cordwood testing ever compiled to develop a North American test method.  Since test methods need to be data driven, this process may give these NESCAUM protocols an entry point and will challenge others to develop or make public data that can lead to a better protocol.