Showing posts with label Canada. Show all posts
Showing posts with label Canada. Show all posts

Monday, May 9, 2022

Gas stoves and fireplaces appliances need better regulation and transparent efficiencies

Public comment from the Alliance for Green Heat 

April 8, 2022

RE: Docket Number EERE-2021-BT-DET-0034: Notice of Proposed Determination of Miscellaneous Gas Products as a Covered Consumer Product

Thank you for the opportunity to comment on miscellaneous gas products as a covered consumer product. 87 Fed. Reg. 6786 (February 7, 2022).

In the United States, efficiencies of gas stoves are often unavailable, and it can be very confusing. The only reliable database is maintained by the Canadian government and consumers often do not know to check it, even if they want a more efficient appliance. Consumers who are trying to save on heating bills often use their gas stove or fireplace to heat the core of the house instead of using the gas furnace to heat entire house. Gas furnaces can waste up to 30% of their heat from leaking ducts. According to the DOE, “Ducts that leak heated air into unheated spaces can add hundreds of dollars a year to your heating ... bills."

We found that very few websites provide accurate information about gas appliances for consumers, in part because there are many gray areas due to lack of regulation. The CEO of one US manufacturer of gas stoves that we spoke to did not know if was required to test for efficiency or even if his products had been tested even though they were designed and marketed as heaters. We also called many retailers and received a wide mix of contradictory information. One told us we had to ask the manufacturer about efficiency. One had no idea how to determine efficiency. And one provided an efficiency from the “nameplate” but when we checked that number with the Canadian database, it was different. We concluded that consumers should beware of efficiency claims on manufacturer websites or from retailers and to always check the Canadian database if they wanted to know the efficiency of a product.

As a result of this, we strongly support the DOE finding that decorative hearths and outdoor heaters qualify as covered products under EPCA. Gas fireplaces and stoves are often used daily to provide heat for homes, as both a primary and secondary heat source. Consumers stand to save significant amounts of money and gas if these heaters are regulated and have to meet minimum efficiency standards. Many retailers advertise that gas inserts can easily serve as the primary source of heat for your home and claim that they use “50% to 90% less gas than gas logs and up to 75% less gas than a gas furnace.”3

Advertisements often
tout the heating benefits
of gas over wood in a
variety of ways.


We also support DOE’s determination to include propane products in the scope of this proposed coverage determination for miscellaneous gas products. Stoves and fireplaces that use propane are nearly identical to those that use natural gas and are very popular in areas that are not served by gas pipelines. The same companies that make gas appliances also make propane ones and it makes little sense to regulate one and not another and would create a confusing and artificial distinction for manufacturers, retailers and consumers. Propane is typically even more expensive than natural gas, so consumers stand to save far more if they have transparent and minimum efficiency ratings.


We are concerned that DOE may have underestimating the annual shipments of miscellaneous gas products. To the extent the DOE relied on figures from HPBA, they must consider that HPBA shipment data typically only includes appliance shipments by their member companies, not by all companies that make and ship gas appliances. In recent years, some of the largest gas appliance manufacturers have dropped their membership in HPBA, and as a result, shipments from those companies would probably not be included. HPBA does not disclose which companies provided data and which didn’t. Even for member companies, they cannot require disclosure of shipment data, but it appears member companies usually participate.

Thank you. Sincerely,

John Ackerly
President
Alliance for Green Heat

Monday, June 11, 2018

Meet the Teams: Canada’s largest stove company looks to the future in automated stoves


This post is the third in a series introducing the 12 teams participating in the 2018 Wood Stove Design Challenge in November.

By John Ackerly and Shoshana Rybeck, Alliance for Green Heat 

The SBI team 
Stove Builder International (SBI) built the innovative Osburn Volta pellet stove in 2012 and made important strides in understanding how sensors can control combustion. The Volta is unique in that it runs on direct current (DC) when all other pellet stoves run on the normal household AC current. The Volta has its own battery pack and can be easily integrated with solar power.

After seeing the announcement for the first Wood Stove Design Challenge, SBI knew that it could convert skills and lessons from the Volta to an automated cord wood stove. Their prototype was not ready for that competition, but lead engineer Nicolas Gagnon attended the 2013 event and was excited by what he saw.

Guillaume Thibodeau-Fortin, an SBI mechanical engineer, believes that wood stove automation is likely to be one of the main trends in stove manufacturing in the future. But finding the time and resources for the R&D was tricky. Guillaume started working at SBI in 2013 and knows that stove buyers are price conscious and they need to see far more value in an innovative stove than its ability to burn clean.

SBI’s location in Quebec, the French speaking part of Canada, gives them more insight and interaction with the European stove market where small, vertical stoves are more popular and where more companies are experimenting with automation. SBI’s headquarters is also not far from Montreal, North America’s largest urban area experiencing severe wood smoke issues. If there is any major North American city that needs a cord wood stove that can run reliably clean in the hands of consumers, it's Montreal.

“So we designed this for multiple reasons—not just to build a stove that operates cleanly in our customer's home. Automation also serves to improve safety, efficiency and ease of use,” Guillaume said.


The stove is built on two radically new ideas. The first is that the stove automatically finds the optimum combustion conditions. That is a core goal of all modern combustion, whether it’s in a car, a power plant, or now, a wood stove. The second is connecting that stove to the operator to engage, inform and educate the operator to better perform his or her roles.
Final model of the stove

A key problem with appliances that need periodic operating adjustments is educating the owner. Printed owner's manuals are often not good education tools, even when they are read and reread by the operator. The SBI stove is connected via Wi-Fi to a smart phone, and Guillaume’s vision is to transfer the old fashioned owner’s manual into a far more appealing, usable and effective interface on the phone. The stove can alert the operator when it’s time to reload for example, and instructions will appear that can include a link to a video about how to tell if your wood is dry.

To automate the stove, the first step was attaching a temperature sensor, but the key was to correlate data from the thermocouple with a static pressure sensor. Utilizing an oxygen sensor could have been better but the pressure of keeping down costs steered the team away from that strategy. The team then turned to computational fluid dynamics to track and predict gas activity in the firebox. 

Efficiency and particulate matter emissions are focal points of progress for wood stove design. With better efficiency, PM is usually reduced as combustion is more complete and therefore cleaner by nature. However, the opposite condition is not necessarily true, as emissions can be reduced by adding oxygen which ultimately penalizes efficiency. SBI is paying closer attention to efficiency, which many stove manufacturers did not do in the past, but ultimately, it’s the PM level that determines if a stove can go to market.  

Electronic board in the stove
SBI’s model for increased efficiency relies on sophisticated control of the primary air inlet and a digital user interface that is connected through Wi-Fi on the user’s mobile device. The stove includes three burn rates, low, medium, and high, and is set to each level via a mobile application. To achieve the user-set burn rate, the automatic stove then takes over, using temperature and static pressure sensors to open and close the air inlets and run a motor that adds primary air in or blocks it out depending on how high combustion is and what level the user would like. While the user has control over the desired heat output, the user does not actually have the ability to change the stove's air flow to raise or lower the burn rate mechanically. The inlet for the primary air cannot be opened or closed by the operator, unless the stove is running cleanly, and if so, the stove will respond in real time to the operator’s changes. If the stove is not burning cleanly, it will first get to a cleaner burn before getting to the desired heat output set by the operator.

Setting the heat level from the comfort of your couch via their mobile device should appeal to many customers. Knowing that you don’t have to periodically check to see whether you have given the stove too much or too little air should give everyone in the house more peace of mind. If the main person who operates the stove is out, the person who adjusts the stove doesn’t have to worry about over firing, making stove smolder, or putting out the fire. The internal temperature and static pressure sensors will bring the stove to the desired heat level in the safest and cleanest manner. 

When we spoke to the President of SBI, Marc-Antoine Cantin, about the development of an automated stove at the HPBA Expo in Nashville, we were struck with how hands off he was with the R&D process on the automated stove. He gave Guillaume and his team the autonomy and support to go through the multi-year process of developing a stove that the company can stand behind. To us, this indicated a company that is big enough to support engineers working on tangential, forward looking projects and an engineering team that has built the trust of management.  

While introducing an efficient, and user-friendly automated wood stove to the market is important, SBI understands that people are first and foremost looking for an affordable and reliable form of renewable heat. When designing and creating their model, the concept of affordability was always key. One of the three head engineers on the project said, “keeping it simple is best for efficiency and the bank.” For them, the 2018 Wood Stove Challenge is giving them the platform to challenge their engineering skills in order to prepare for a cleaner wood burning future.

Contact the team

Guillaume Thibodeau-Fortin
gthibodeaufortin@sbi-international.com

Maxime Legros
mlegros@sbi-international.com

Nicolas Gagnon
ngagnon@sbi-international.com


Wednesday, January 4, 2017

Residential heating with wood and coal in the US and Europe (excerpts)

This blog contains excerpts from a very important and readable report published by the World Health Organization (WHO) in 2015.  It is primarily from a health and policy perspective and is very valuable for North American as it provides more of a European perspective and is balanced in its approach. The entire 58-page report can be downloaded here

The report is particularly interesting as it hits on many themes that were considered or included in the 2015 EPA wood heater regulations, some of which will be litigated in 2017. It addresses best available technologies, indoor air quality, efficiency standards, stove changeout programs, black carbon, carbon neutrality, HEPA filters and many other issues. One of the overarching conclusions is that national policy should strongly favor pellet over cord wood appliances, a transition that has already occurred in parts of Europe, but not in the US.

Authors include experts from the US, Austria, Canada, Finland and Germany.  This publication was prepared by the Joint WHO/United Nations Economic Commission for Europe (UNECE).

The report describes the health effects of and policy options for dealing with residential heating with wood and coal in Europe and the United States. The results presented indicate that it will be difficult to tackle problems with outdoor air pollution in many parts of the world without addressing this source sector. National, regional and local administrations, politicians and the public at large need a better understanding of the role of wood biomass heating as a major source of harmful outdoor air pollutants (especially fine particles). This report is intended to help increase such an understanding. 

Executive Summary:
Measures are available to reduce emissions of solid fuels for residential heating in most places. Encouraging fuel switching (away from coal and other solid fuels) and use of more efficient heating technologies (such as certified fireplaces or pellet stoves) can reduce the emissions from residential wood and coal heating devices. Educational campaigns may also be useful tools to reduce emissions from residential solid fuel heaters.

Furthermore, filters may reduce health effects from indoor air pollution. Existing regulatory measures include ecodesign regulations and labels in the European Union (EU) and technology based emission limits in the United States of America and Canada. Financial fuel switching and technology changeout incentives – as well as targeted “no burn” days and ecolabelling – are other tools available to policy-makers.

p. 2. Residential heating with wood is a sector in which PM2.5 and BC emissions can potentially be reduced with greater cost– effectiveness than many other emission reduction options. Nevertheless, within Europe and North America only a few countries or states have set legal limits for minimum combustion efficiency or maximum emissions of PM and harmful gaseous compounds like CO and gaseous organic compounds (see section 6).

Coal:
p. 8. In the USA 55% of homes used coal/coke for space heating in 1940, but this fell to 12% in 1960, below 5% in the early 1970s and below 1% from the early 1980s (Schipper et al., 1985; United States Census Bureau, 2011).

One study estimates that reductions in the use of bituminous coal for heating in the USA from 1945–1960 decreased winter all-age mortality by 1% and winter infant mortality by 3%, saving nearly 2000 lives per winter month, including 310 infant lives (Barreca et al., 2014).

Based on this and evidence that indoor emissions from household combustion of coal are carcinogenic to humans, the latest WHO indoor air quality guidelines strongly recommend against the residential use of unprocessed or raw coal, including for heating (WHO, 2014a).

Infiltration of smoke into homes
p. 10. A household with wood-burning appliances is likely to be surrounded by other homes with wood-burning appliances, and wood burning also tends to aggregate temporally; thus, on cold evenings and nights most homes in the area may be burning wood.

Given that most wood burning occurs in cold locations where homes are well insulated, buildings are expected to have low infiltration (meaning that relatively small amounts of outdoor air pollution, including wood-burning smoke, enter the house and contribute to indoor air pollution), especially during the heating season.

In North America heating-season outdoor temperature is an important determinant of infiltration, and infiltration levels are generally lower in the heating than the non-heating season, when doors and windows are likely to be open more (Allen et al., 2012). In British Columbia the mean infiltration fraction of PM2.5 in winter was found to be 0.28, compared to 0.61 in summer, although infiltration factors for individual homes in winter ranged from 0.1–0.6 (Barn et al., 2008); another study reported similarly low mean infiltration levels of 0.32 Å}0.17 during the winter (Allen et al., 2009). Combustion of wood in residential areas and often under cold, calm meteorological conditions can nonetheless lead to high exposure compared to other pollution sources, owing to the principle of intake fraction.
  
Indoor pollution
Modern wood stoves and fireplaces, when operated according to the manufacturers’ instructions, release some PM and gaseous pollutants directly into indoor air, although in most cases the evidence for substantial indoor emissions from these modern stoves is very limited. With poor operation, poor ventilation or backdrafting, however, elevated concentrations of combustion products (such as PM, CO, VOCs, NOx and aldehydes) may result indoors. Acute CO poisoning, which can sometimes even be fatal, may occur due to indoor wood burning and infiltration of dirty ambient air), especially when ventilation of the wood-burning appliance is not managed properly.

Stove Change outs
p. 21. Such change-out initiatives have potential limitations. The Canadian Council of Ministers of the Environment (CCME) – the association of environment ministers from the federal, provincial and territorial governments – evaluated 12 stove exchange and educational efforts conducted in Canada and concluded that exchange programmes may have limitations relating to both the cost of new technologies and the long service life of appliances once installed. The assessment supported the use of regulation effectively to curb the sale of high-emission appliances. This approach is used in a number of Canadian provinces and American states.

The Canadian National Collaborating Centre for Environmental Health found that emissions standards (based on best available technologies) are needed to ensure that the newer devices installed through change-out programmes are among the cleanest available in the marketplace. Without these standards, change-out programmes may, in fact, be lost opportunities to install the cleanest available wood-burning devices, which will be in use for years to come.

The study also found that removal of conventional noncertified appliances (through exchanges, time limits or prior to the sale or transfer of a property) was the most effective strategy included in a model municipal by-law for mitigation of residential wood smoke (Environment Canada, 2006) (see “Other regulations and voluntary measures” in section 6). [Click for more on stove change out programs - editor.]

HEPA Filters
While household or individual-level strategies are not typically part of air quality management programmes, two studies from Canada indicate that inhome HEPA filtration might reduce health impacts from wood smoke. An initial single-blind randomized crossover study of 21 homes during winter, in an area affected by residential wood combustion as well as traffic and industrial sources, reported a mean 55% (standard deviation = 38%) reduction in indoor PM levels when HEPA filters were operated (Barn et al., 2008). Use of the HEPA filters reduced indoor PM2.5 and levoglucosan concentrations by 60% and 75%, respectively. [Click for more on HEPA filters - editor.]

Regulatory Emission Limits
p. 26. Over the past decade, the European Commission has worked towards the possibility of regulating solid fuel local space heaters and boilers, particularly those that use various forms of woody biomass fuel (wood logs, pellets and biomass bricks), to create proposed ecodesign emissions limits.

According to the Commission proposals, implementation of ecodesign standards would lead to significant reductions of PM2.5 emissions from solid fuel local space heaters and boilers compared to baseline projections. The draft regulation for solid fuel local space heaters2 states that in 2030 the proposed requirements for those products, combined with the effect of the energy labelling, are expected to save around 41 petajoules (0.9 million tonnes of oil equivalent (Mtoe)) per year, corresponding to 0.4 million tonnes of CO2. They are also expected to reduce
PM emissions by 27 kilotonnes per year,

Voluntary Measures
p. 30. The Wood Stove Decathlon, an initiative of the Alliance for Green Heat, was organized in 2013 to focus creativity and resources on designing next generation wood stoves. The main goal was to challenge teams of combustion engineers, engineering students, inventors and stove manufacturers to build wood stoves that are low-emission, high-efficiency, innovative and affordable, in a common process that may point to commercially attractive next generation stove production (Alliance for Green Heat, 2013). 

Policy Needs
p. 31 Any renewable energy or climate change related policies that support combustion of wood for residential heating need to consider the local and global ambient air pollution impacts and immediately promote the use of only the lowest emission or best available combustion technologies.

Legal regulations for wood combustion efficiency in new heating appliances are urgently needed throughout the world. These will both slow down the current rapid speed of global warming (relating to BC in fine particles and VOCs that promote ozone formation) and reduce the great burden of disease caused by wood combustion-derived particles (especially organic compounds carried by BC). Such regulations should include tight – but technically achievable – limits in particular for the primary emissions of particulate mass, gaseous hydrocarbons and CO from new boilers and heaters.

p. 32. As new wood-burning devices become more energy efficient and emit less pollution (especially PM), national governments need to prepare heater exchange regulations or voluntary programmes. Municipalities, counties and states should consider requiring heater exchanges at the time of home remodels or sales. In many cases, these regulations will be most successful if financial compensation is offered to assist with the cost of replacing old heaters with those meeting tight energy efficiency or emission limits regulations.

“No burn” areas are needed. Especially with current combustion technologies, it is important to define urban areas with dense populations and/or geographical features (such as valleys between mountains) where residential heating or cooking with small-scale appliances burning solid fuels (wood and coal) is not permitted at all or is at least limited to registered models of low-emission wood combustion devices. Residential heating with coal in small-scale appliances should also be permanently prohibited, at least in communities of developed countries, as should the use of wood log burners for central heating without a sufficiently large water tank (which otherwise leads to badly incomplete combustion and very large emissions).

Co-benefits for health and climate

As wood is burned ... carbon is released back to the atmosphere, not only as CO2 but in most household combustion also in the form of short-lived greenhouse pollutants such as BC, CO and VOCs including CH4. Thus, to be perfectly “carbon neutral”, wood fuel has to be not only harvested renewably but also combusted completely to CO2. For both climate and health purposes, the form these fuels’ carbon takes when it is released matters greatly, since BC and CH4 are both strongly climate-warming.

p. 34. A World Bank study found that replacing current wood stoves and residential boilers used for heating with pellet stoves and boilers and replacing chunk coal fuel with coal briquettes (mostly in eastern Europe and China) could provide significant climate benefits.

Another study coordinated by the United Nations Environment Programme and the World Meteorological Organization found that widespread dissemination of pellet stoves (in industrialized countries) could improve health, since these interventions lead to reductions in PM2.5.

If Arctic climate change becomes a focus of targeted mitigation action (because of threats from rising sea levels, for example), widespread dissemination of pellet stoves and coal briquettes may warrant deeper consideration because of their disproportional benefit to mitigating warming from BC deposition in the Arctic (UNEP & WMO, 2011). The World Bank found that replacement of wood logs with pellets in European stoves could lead to a 15% greater cooling in the Arctic (about 0.1 ÅãC). For Arctic nations the modeling strongly indicates that the most effective
BC reduction measures would target regional heating stoves for both climate and health benefits (Pearson et al., 2013).

Conclusions
p. 35. Given that residential wood combustion for heating will continue in many parts of the world because of economic considerations and availability of other fuels, an urgent need exists to develop and promote the use of the lowest emission or best available combustion technologies.

 It may be preferable in many cases to focus on making biomass-based home heating more efficient and less polluting rather than transitioning away from biomass to fossil fuels, given the climate change implications of using fossil fuel for heating.