Best Practices in Change Out Programs (and Why Some Programs Underperform)

Updated: May 2022 - Change-out programs are now commonplace in the wood stove community, particularly in the Northwest, with Libby, MT being the highest profile one.  In Libby and elsewhere, changing out old uncertified stoves to new EPA certified stoves has demonstrably contributed to cleaner air quality.  Typically, wood stove change-out programs start with government funding, and then leverage in-kind donations from wood stove manufacturers, stove retailers and others.  (An updated list of "best practices" for stove change-out programs is available here.)

However, change-out programs sometimes provide fewer air quality benefits than expected.  And, per ton of particulate matter removed from the environment, they can be very expensive.  Raw numbers from Washington State based on money they spent versus estimated emission reduction came to nearly $50,000 per ton of particulate.  When Washington State uses the EPA methodology for calculating cost per ton, the mean cost was between $14,000 and $19,000 per ton. 


In addition to the classic change out program designed to reduce excessive smoke in particular town, valley or region, change out programs can simply help rural households more efficiently use a local renewable energy source.  Also, manufacturers and retailers can undertake them in the slow, summer season.


In assessing the effectiveness of change-out programs, the Alliance for Green Heat found a lack of rigorous analysis or debate about how to best achieve air quality improvements. Some states are starting to develop more innovative features in incentive programs instead of following the pattern set by the EPA and HPBA. Here are eight strategies that will improve change out programs.  Virtually none of these strategies, that many consider key parts of change outs, can be found on the EPA or HPBA change out pages.  Expect push back from local government agencies, HPBA and/or retailers on some of these points, but all of them are becoming more and more accepted.

1. Controlling future installations of wood appliances

Too many change out programs occur in places were people are still allowed to install old, second hand stoves or even outdoor boilers.  Reports touting the success of change-outs in Pennsylvania, Indiana and the Great Lakes states don’t even mention that while old stoves are being removed, uncertified outdoor wood boilers were being installed in the very same communities.  In Vermont and Keene, NH, more uncertified wood stoves may have been installed since their programs ended than were removed.  Before spending limited dollars on change-outs, funds should be focused in areas where the locality has enough commitment to clean air to stipulate that old, uncertified stoves and unqualified outdoor boilers cannot be installed in the future. In urban areas where wood smoke is bad, local governments should consider banning the new installation of all wood stoves and only allow pellet stove installations.

2.  Prioritize which stoves get changed out first

We believe that some programs inappropriately used a first-come, first-served approach when stoves used as a primary of sole heating source in more densely populated areas could have been targeted first.  While this does not apply to valleys with inversions like Libby, where every stove is equally important, in places like Massachusetts and southern New Hampshire, where funds can run out quickly, stoves in the middle of towns which are used as a primary heating device should be given priority.  Some new epidemiology research is coming out saying that stove change-outs do not necessarily improve indoor air quality and the main benefit is to improve outdoor air quality that impacts the community at-large.  In change-outs that cover multi-county areas, or even statewide, as in Vermont's program, we think focusing on stoves in towns is warranted.  Last priority should be stoves in isolated houses that only use wood as a secondary heat source.  Fairbanks may be the best example of effective prioritizing based on location instead of using a first-come, first-serve model.  A related best practice that has been implemented by HPBA, EPA and others is giving priority or higher rebates to low income households. While this is a practical necessity in order for them to participate, it also helps the program ensure that they are getting more stoves that are primary heating appliance of the house.




3.  Focus on wood, not just stoves

Some experts are now wondering if a $150 rebate to help build a wood shed to keep wood dry may produce similar air quality results as a $1,000 rebate for a stove.  It’s well known that the equipment is only half the battle, and the other half is the fuel and the operator.  Requiring firewood dealers to bring a moisture meter when delivering wood and writing down moisture content on the sales receipt may also be a good strategy. Change out programs could prioritize homes with woodsheds, to help ensure that subsidizing a new stove will result in reduced smoke from the home.  Or homes with woodsheds could receive a higher rebate, which incentivizes proper storage and educates people about its importance.

4. Right-size the rebate and require partial payment

When rebates disappear in a few hours or even a few weeks, it likely means the rebate was too generous and a lesser rebate could have resulted in more change outs.  Also, rather than provided a fixed amount, programs that provide 50% or even 35% of the new stove should be considered, where possible.  When smaller, more targeted populations are involved like Keene, NH, larger rebates are required, as they also are with low-income populations.

5. Integrate wood stove inspections in energy audit and weatherization process

If your state is particularly interested in retiring older stoves, it is important that state subsidized energy audits and weatherization programs require that the auditor inspect the wood stove, just like they check other HVAC equipment.  Auditors can educate homeowners about the importance of upgrading to safer, more efficient equipment, spot dangerous installations, assist in removing dangerous stoves and sometimes help get stove upgrades to be subsidized through low interest loans or other programs.  The Building Performance Institute (BPI) is taking the lead to develop guidelines for energy auditors to inspect wood stoves.  In recent years, energy auditors have failed to include wood stoves in hundreds of thousands of homes.

8. Ensure big box stores are included in the program
As long as professional installation is being required in a change out or incentive program, including stoves from big box stores can make funding go much further and enable more low and middle-income households to participate.  Allowing purchases from hardware chain stores can make all the difference for lower income families to trade out that old stove and afford a new one.  Good quality stoves can start around $1,000. One of the highest rated pellet stove brands, Pel Pro, sell for about $1,300 at outlets like Tractor Supply and Northern Tool. Professional installation can be done by CSIA accredited chimney sweeps if local NFI trained staff at specialty hearth stores will only install their own products.  Especially if larger rebates are not provided to low-income families, this is a vital way to help them overcome high upfront costs and help stretch program funding and change out more stoves.

9. Include heat pumps and gas stoves, with efficiency requirements

Most change out programs now offer non-wood or pellet appliances, as they should.  Consumers should be given a selection of the cleanest appliances that meet their needs.  If gas appliances are included, require that they be at least 70% efficiency based on the Canadian gas appliance database.  The US offers to reliable database of efficiency on gas appliances and manufacturer and retailer information is often mistaken, wrong, absent or confusing. Consumer education on gas stoves is crucial. See here for AGH public comments on why the DOE should regulate gas stoves and their efficiency.

Background

Based upon an informal survey of 10 change out programs in 2014, we found the average rebate for a new wood stove was $627 dollars, but ranged from $300 to $1,050 per stove and much more for low-income change outs. The median rebate was $670.  Nine out of the ten programs surveyed offered additional assistance to low -income applicants, and three out of ten offered full rebates.

Change out programs, depending on their size and scope, can cost a great deal of money to run and advertise. Buy back or bounty programs that just pay to remove stoves and do not replace them, are increasing in popularity and should be considered alongside change outs.  They are far cheaper, require much less administration, and can be run on a year round ongoing basis.  The average cost per change out varies greatly between programs. Libby, Montana had a large budget and was servicing a low-income population so the cost per stove was higher.  Pittsburgh program’s average cost was relatively low, at $770 per change out.   Higher costs per stove do not necessarily mean they were less efficiently run, as there are so many variables and so much need for costly educational programs that target homeowners who are not changing out stoves, but may be emitting a lot of excess smoke. 

[Afterward: Sylvia Shultz of Clean Air Fairbanks took issue with part of this blog and you can read her response here.]

Click for larger version.

Postscript

Up until 2020, when EPA regulations changed, AGH had urged change-out programs to adopt practices that are no longer relevant.  We keep them here for historical interest and context.

* Require that new stoves meet stricter emissions and efficiency standards

Almost all change-out programs now require that the new EPA certified stove be 4.5 grams or less, but some are starting to require 3 or 2.5 grams an hour or less. Pellet stoves, which operate in the field much more like they did in the testing lab than wood stoves, should be held to 2.5 or 2 grams an hour at the most.  Some states, with varying degrees of success, are starting to experiment with minimum efficiency requirements and this is likely to be a standard requirement sometime in 2015.  Oregon provides a greater rebate level for stoves made by companies who agree to share verified efficiencies with their customers.  Most stove manufacturers will not release this information, preferring to use unverified and often exaggerated numbers.  Maryland requires a maximum of 3 grams for wood stoves and 2 for pellets. (The Maryland program is a renewable energy program and does not require the change out of an old stove, but about half the old stoves are disabled and destroyed anyway.)

* Require both wood and pellet stoves be EPA certified

Few programs have required that pellet stoves be EPA certified although there are substantial benefits of this.  EPA certified pellet stoves are usually more efficient than their exempt counterparts because exempt pellet stoves often use the 35 to 1 air to fuel ratio loophole to avoid certification but all that air reduces efficiency.  Some pellet stoves are as low as 40% efficient, and many are in the 50s and 60s, when they easily can be in the 70s.  Households should not be unwittingly subsidized to buy a low-efficiency pellet stove that will saddle them with much higher fuel costs for years to come.  Unfortunately, large and small pellet stove manufacturers currently self-report efficiencies and are notoriously adept at exaggerating and inflating their efficiency numbers.  The EPA and DOE have done little to counteract this and have at times contributed to the problem.

Australian Perspectives on the EPA's Proposed Stove Regulations

Courtesy of The Firewood Association of Australia

In the US the federal EPA has recently released a proposal to update the 1988 emission limits for new wood stoves.  While the new legislation is still in its consultation stage, it is proposed that it will be introduced as law in 2015 and will have a 5 year phase in period. 

In the US they measure particulate emissions in grams per hour instead of the grams per kilogram that we use in Australia, which makes a direct comparison difficult.  But the intent of the legislation is much the same as proposed in the recent draft of the Australian wood heater emission standards, which is to significantly lower emission rates for new heaters. [The Alliance did a more in-depth analysis of the new, proposed Australian wood heater regulations in August 2013. - eds]

Similar to the situation in Australia, it appears that these new limits are generally supported by the large heater manufacturers, who have the capacity to develop new, compliant models, but opposed by the smaller manufacturers who cannot easily afford the costs of development and testing.

In both the US and Australia the new limits will not apply to existing heaters, so any lowering of neighbourhood smoke levels will take a long time to materialise, given the 20 year plus lifespan of most wood heaters.  In both countries wood heater manufacturers would like to see governments support (or enforce) the replacement of old heaters with new models, for the obvious reason.  However, it appears that governments are reluctant to head down that path.

Because these new designs of wood heater are much easier to operate without creating excessive smoke, the gradual replacement of installed heaters should result in less smoky heater complaints.  The experiment carried out in the town of Libby, Montana where every wood heater in this small town was modernised or replaced, showed that improving the heater stock can have a modest impact on smoke levels (30%).  However, this experiment clearly shows that heater operation practice has by far the greatest influence on smoke emissions and is something that can by changed at no great cost with immediate impact.

Wood Stoves and the New EPA Soot Rule

Alliance for Green Heat, December 17, 2012 - The new soot rules announced by the EPA on December 14 require a 20% reduction in allowed particulate matter to 12 micrograms per cubic meter annually, which may make it tougher for counties with excess wood stove smoke to comply with federal air quality standards.  However, the current 24 hour standard of 35 micrograms per cubic meter remains unchanged, which is more likely the standard implicated by wood smoke.

Along with vehicles and power plants, wood stoves are one of the contributors to poor air quality in some of the counties facing non-attainment of federal standards. “Wood stoves continue to produce too much smoke partially because the EPA has failed to comply with the Clean Air Act and has not updated emission standards for a quarter of a century. The Clean Air Act says the EPA should review standards every eight years,” said John Ackerly, President of the Alliance for Green Heat. In addition, incentives for renewable energy technologies have not focused on the cleanest wood devices, like pellet stoves, as they have in Europe.

The Alliance for Green Heat reported earlier in July that the EPA projected this standard could push six more counties into non-attainment by 2020. The list included counties in California, Arizona, Michigan, and Alabama, as well as Lincoln County in Montana where a famous wood stove change out program took place in the community of Libby between 2005-2008. Epidemiology professor Curtis Noonan, who has studied the Libby change out program extensively, said in July that Libby could be in danger of becoming a non-attainment county in 2012 if the limit was set to 12 micrograms.

As of last Friday, December 14, 2012, the EPA has since changed its projections of what counties are likely to not meet the new standard by 2020. Lincoln County, Montana and several others listed in July appear to have fallen off the potential non-attainment list while more have been added. The total now stands at seven counties, all of which are located in Southern California.

States will be required to make area designation recommendations by December 2013 with final designations from EPA due out in December 2014.  Implementation plans are scheduled for 2018 with the goal of attainment by 2020. 

The EPA has multiple air quality standards for fine particulate matter pollution (PM2.5), which is sometimes referred to as soot.  In addition to the recently updated annual standard of 12 micrograms per year, the EPA also has a 24 hour PM2.5 standard of 35 micrograms per cubic meter, last updated in 2006. Wood smoke is likely to have a much greater impact on the 24 hour standard violations than the annual one, and there are over 100 counties that are in non-attainment of the 24 hour standard as of December 14, 2012.

To view the sources of annual PM2.5 emissions in your state or county, visit: http://www.epa.gov/cgi-bin/broker?_service=data&_debug=0&_program=dataprog.national_1.sas&polchoice=PM

Wood Stove Changeouts Improved Air in Libby, but …

 

Four years after the changeout of 1,200 uncertified wood stoves in Libby, Montana, the definitive air quality study has been released.  Not surprisingly, it found that changing out stoves improved air quality and children’s health.  But some findings were surprising.  For one, indoor air quality did not always improve; in fact, it got worse in some homes.  Another interesting find was that no health differences could be found in kids from homes with wood stoves compared to those without them.  Overall, the air quality benefits were not as great as expected.  The detailed report was published along with a thorough critique of the report by health experts pointing toward what future studies should also consider. 

* Air emission standards in the United States typically regulate the specific type of device, the fuels, and heat outputs. A recent report indicated that this may allow gaps and variation in coverage, and some residential and small-to-medium–sized biomass units may not be subject to environmental regulations (Handley et al. 2009). In contrast, regulations in Europe are issued according to heat output and type of feeding device (manual or automatic), which provides 100% coverage. More importantly, European PM2.5 standards for wood-burning appliances are significantly lower at about 0.02 to 0.05 lb/million BTU heat output compared with state regulations in the United States at, for example, 0.1 lb/million BTU in Massachusetts and 0.6 lb/million BTU in New York State (Handley et al. 2009). This indicates that in the United States there is room for improvement in terms of reducing emissions from wood-burning appliances. (p. 40)

* It is not clear whether the total number of wood stoves in the community increased in the meantime, because more people may have chosen wood as a cheaper fuel, because of an increasing population size, or both. (p.43)

* In addition, there may be other sources of PM2.5 in the area, such as wood- or coal-burning fireplaces and boilers that were not covered by the changeout program. New York State has noted a tripling in the sales of outdoor wood boilers since the early 1990s (p. 44)

* The wood stove changeout program should be considered a success because 95% of older, high-polluting wood stoves in Libby, Montana, were replaced with more efficient certified wood stoves or with heating systems that did not burn wood. .. However, the air quality improvement was not as large as might have been expected based on the dominant contribution of wood burning to ambient PM2.5 concentrations in the area and the approximately 50% expected reduction in emissions anticipated from each certified stove compared with uncertified models. (p. 45)