10 States sue the EPA to improve wood stoves, but the grounds are dubious

Old stoves removed during change out
programs range from ones like these ...

Ten states and one large air agency filed a notice that they intend to sue the EPA over its weak wood stove testing, certification and enforcement programs. The lawsuit is one of the only ways to keep the agency on the required timeline of updating its wood and pellet heater regulations every eight years. Otherwise, the agency can easily let timelines slip and put wood heater policies and regulations on the back burner as both Republican and Democratic administrations have usually done.

The Alliance for Green Heat (AGH) supports the lawsuit for these reasons: EPA needs to keep focused on this technology and keep doing the testing that can get better test methods and stoves that operate better in the hands of the consumer. Automated wood stoves that use sensors, computer chips and actuators to mix the fuel and the air, like in cars, probably offer the best hope for cleaning up wood stoves. But they may be left out of the next updated regulations, known as New Source Performance Standards (NSPS).

... to stoves that are decrepid
and/or dangerously self-installed.

However, AGH does not agree with much of the faulty narrative that says new stoves are not likely to be cleaner than old stoves. And maybe most worrisome is that the AGs of so many states appear willing to make such claims without citing data to support it. 

Unlike the dynamic around auto emissions, where car manufacturers are pitted against the EPA, in this case all fingers are pointed at the EPA for being too lax. The EPA’s wood heater program has had huge weaknesses and it is an easy target. But it is important to understand that the EPA is not a monolith, and it is the wood heater certification and enforcement programs in Washington that are far more of a problem than the section in North Carolina that does the test methods and change out programs.  

One of the many problems with the filing by 10 state Attorney Generals (AG) is that it is mainly based on a review of the EPA’s certification program done by the State of Alaska and Northeast   States for Coordinated Air Use Management (NESCAUM), with funding from New York State Energy Research and Development Authority (NYSERDA). It is not based on testing of new stoves in the field compared to old, uncertified stoves in the field. The narrative that the EPA has been wasting money on change-outs because new stoves aren’t necessarily cleaner than old ones seems to be gaining traction despite evidence to the contrary. Moreover, it distracts from the real, complex tasks at hand and is divisive. As a public relations strategy, it has been successful, gets good media coverage and rallies liberals.

The reality is far more complex. Ironically, it also misses what blue states care about: maximizing renewable energy in smart ways and creating more equity in the energy transition. Starting with the NESCAUM report, pellet appliances have been sidelined from the narrative and they are not even mentioned at a time when much of America is confused about the difference between premium heating pellets and industrial pellets to make electricity. If wood and pellet stoves are to play a role at helping the US reduce residential fossil fuel and protecting low to moderate income (LMI) households from the high costs of the new energy paradigm, it is vital for AG offices to understand the role of the technology in America. 

The Notice to Sue, likely leading to a lawsuit can be good for our common goals of getting cleaner wood stoves, but AG offices need to understand some things. First, we don’t need a new NSPS before we have new test methods. (One of NESCAUM’s many roles is providing data for new test methods, but compared to other labs, NESCAUM’s lab is way behind schedule, which complicates the whole timeline.) Second, the goal of getting better repeatability of a test result within a lab and between labs does not necessarily lead to a cleaner stove in the hands of homeowners. Third, tilting scales toward hybrid stoves may help in the short run, but is not necessarily a long-term or nationwide solution. Fourth, there has never been much agreement on what constitutes the best systems of emission reduction (BSR) in stoves which hinders the EPA in writing regulations that can force technology to change and improve. 

Wood and pellet heaters can help the nation in our transition to electrification by giving homeowners a back-up heating source, lowering stress on the grid during wintertime and providing LMI households protection from rising electricity costs which helps achieve equity. And environmental justice is improved in poor communities not just by a reduction in woodsmoke but also by improving energy security so that homes do not have to choose between heating and eating. For low-income households, change-out programs have been very important by removing unsafe stoves that pose a fire risk, improving not just ambient particulate matter (PM) and indoor PM, and adding heat pumps to many homes. 

The next NSPS will be best served by an EPA with the budget that enables them to collect their own data and properly manage the certification and enforcement programs, which are still far from effective. Underfunding leaves the EPA vulnerable to just reacting to one side or the other, and making poor decisions like revoking a cordwood test method that should have been changed and improved instead. That revocation was also prompted by the same group of states, most of which lack the expertise to understand the complexities and the politics of such a move. Tightening up that test method would have helped the EPA gather vital data it needs for this NSPS and not rely on data from parties who are sparring for an upper hand in the process.

The mostly blue states leading this lawsuit also need to manage wood and pellet heating far better in their own borders, as all states do. Vermont is a good model which is also heavily promoting heat pumps. States should be promoting pellet stoves and boilers and demanding stricter PM limits for those appliances. They should also limit the new installation of cord wood stoves in densely inhabited areas unless, or until, automation and mini-electrostatic precipitators can make cordwood units far cleaner. While cordwood stoves are essential for rural LMI households and help them get off fossil fuels, manually operated wood stoves are simply not a good energy solution where lots of homes are close together, particularly when the topography leads to frequent inversions, trapping PM close the ground where we breathe. 

As for the solution to reduce wood smoke in Fairbanks, even Albert Einstein would be scratching his head. Managers of that change-out program have done an admirable job and used many different strategies. They also uncovered huge problems in the EPA’s stove certification program which were hiding in plain sight. But we should not expect the next NSPS to make much of a dent in that intractable problem. 

Nationally, the solution lies in far more funding for R&D in stove technology, more attention to enforcement of current regulations, more experts for state AGs to rely on and collaboration. Like many big energy issues, the solutions are multi-faceted and rely on a collaborative approach by stakeholders. We should take this lawsuit as a wake-up call.

Expanded tax credits for modern, high efficiency wood and pellet heaters a big step in the right direction

Maine Senators Collins and King were
primary, bi-partisan champions of an
investment tax credit for wood heat.

Update for 2023 - The legislative victory that achieved the 26% tax credit in 2020, has now been upstaged by a law that will give a 30% tax credit as of Jan. 1, 2023.  The only downside to the 30% credit is that is has a $2,000 cap, which makes it of little value for homeowners who want to install very expensive whole house wood or pellet heating systems. Click here for our blog on the 2023 - 2032 wood heater tax credit.

2020 - 2022 - On December 28, 2020 President Trump signed into a law legislation passed by Congress which was the largest renewable energy spending bill in a decade and included incentives for solar, wind, advanced wood heat and a host of other technologies. This marks the first-time modern wood heating systems have been granted an Investment Tax Credit (ITC), rather than the far smaller tax credit wood heating technologies had been receiving.

The incentive provides a 26% tax credit for stoves and boilers that are 75% efficiency or higher. Consumers can easily identify efficiency levels by checking the EPA lists of certified wood and pellet heaters. The credit has no upper limit and lasts for three years, declining to 22% in 2023.

The effort to pass such an ambitious bill was led by the Biomass Thermal Energy Council, who started lobbying for it in 2009. In recent years, another significant push was led by Charlie Niebling, a consultant for Lignetics and former Chairman of BTEC. The Alliance for Green Heat contributed time and resources to both of these efforts, along with many other BTEC members.

As the founding Chairman
of BTEC, Charlie Niebling
was a chief architect of the 
bill and perhaps its most
ardent advocate.

Many Senators and members of Congress signed on to various iterations of the bill over the last decade, but it was Senator Collins and Senator Angus King who provided the final push, along with Chairman Richard Neal in the House of Representatives.

The legislative effort gained momentum as new EPA regulations required wood and pellet heaters to be cleaner and to disclose their efficiencies. “This is an important step forward but it is only one piece of a much larger puzzle to modernize the technology and the test protocols,” said John Ackerly, President of the Alliance for Green Heat.

Analysis

Wood and pellet heaters that at least 75% efficient are cleaner on average than those that have efficiencies below this threshold. Pellet stoves that test over 75% efficient emit five times less carbon monoxide (CO) than those with efficiencies under 75%. Wood stoves that test over 75% efficiency emit less than half of the CO of their less efficient counterparts.

The 75% efficiency threshold favors pellet technologies, as consistently dry fuel and automated combustion make it far easier to achieve consistently higher efficiencies. Sixty percent of all pellet stove models are over 75% efficient, compared to only 40% of wood stoves. Most catalytic and hybrid wood stove models are above 75% efficient, but only 12% of non-catalytic stoves will be eligible for the tax credit.

The seventy-five percent efficiency requirement was originally chosen about seven years ago, when fewer appliances could meet that level. With today’s technology, 75% efficiency is not a particularly high threshold, but it is much higher than how the 75% threshold was interpreted by industry to meet the previous $300 wood heating technology tax credit. That credit, under Section 25C of the tax code was also pegged to 75% efficiency but Congress did not consistently specify high heating value.

Using efficiency as the sole metric to identify wood and pellet heaters to receive public subsidies is a blunt and imperfect metric but satisfies legislators’ need for simplicity. Particulate matter (PM) emissions from cord wood stoves and boilers are a more important metric for public health. Efficiency is a more valuable tool for pellet appliances since their lab tested efficiencies are a reliable indicator for the efficiency homeowners' get. But wood and pellet appliance manufacturers sometimes purposely lower their efficiency to achieve other goals valued by consumers. Some pellet stove manufacturers use excess oxygen, leading to lower efficiency, to keep the viewing glass clean. Some wood stove manufacturers use excess oxygen to achieve cleaner, faster combustion and to prevent the operator from giving the unit too little air, which causes smoldering. The State of Alaska is currently exploring new metrics to identify cleaner wood heaters, including using the amount of PM created during the first hour of certification test burns.

Using efficiency as a metric does help deploy heaters that will save consumers money with a low-carbon renewable. Since the early 1900s, wood fuel has been the primary way that American households have avoided or reduced fossil heating fuel. An estimated half of American households who heat with wood gather all or most of it themselves, making it a highly sustainable fuel in a country with extensive forest cover.

This bill will help Americans afford to replace older wood heaters or buy higher efficiency ones and have them professionally installed because the tax credit covers the cost of installation. It will also help scores of small pellet mills across the country that mainly use sawdust produced by sawmills. Finally, the bill will also help manufacturers of more efficient wood and pellet appliances and encourage them to redesign heaters to be more efficient.

Benefits of a tax credit do not help everyone equally. Lower income families benefit far more from a rebate granted at time of purchase and many do not have the income level to benefit from a tax credit. And, the 75% efficiency threshold excludes the value wood stoves sold at hardware chains that are affordable to lower income households. Unlike wood stoves, many low cost pellet stoves are at least 75% efficient.

“The Alliance for Green Heat applauds this increased tax credit and calls on Congress needs to do more,” said Ackerly. “We need a dedicated federal fund to switch old, uncertified stove to cleaner heating technologies, similar to the federal program for diesel trucks. We also need increased funding for DOE and National Labs to focus on R&D to develop a new class of automated wood stoves and smart pellet appliances that integrate with solar and heat pumps and reduce electricity demand during winter electricity peak events,” Ackerly continued.

A separate bill included report language that directs the DOE to continue the $5 million grant program for R&D to modernize residential wood and pellet heaters. The Alliance for Green Heat worked with Senator Collins’ office to ensure this report language was included again.

The massive omnibus package included other provisions that could help advance cleaner and more efficient wood and pellet heating:

• $1.7 billion reauthorization of the Weatherization Assistance Program to support low-income families by retrofitting homes with cost-saving clean energy technologies.
• Robust funding for EPA “core” programs to protect clean air.
• Reauthorization of the EPA Diesel Emissions Reduction Act (DERA) program, which is a model for a national wood stove change out program.
• $200 million timber hauling businesses that experienced a loss of at least 10% of gross revenue between January 1, 2020 and December 1, 2020, compared to the gross revenue earned in the same period in 2019.

 Related stories

Guidance on the 26% tax credit for 2022 and changes for 2023 (Oct. 2022)

AGH urges IRS guidance to recognize efficiencies in the EPA Database (Feb. 2021)

West Penn Power Energy Fund to support a design competition that pairs automated, electricity producing wood stoves with solar PV

June 27, 2018- The Alliance for Green Heat received a $5,000 grant from West Penn Power Sustainable Energy Fund (WPPSEF) to support the 2018  Wood Stove Design Challenge, a competition to automate and make electricity from wood stoves from November 9 - 13.

The grant funds will be used to test and promote stoves that are automated and produce electricity, both of which could be popular in Western Pennsylvania as they become more commercially available in the next few years. Twelve teams are competing and they will be rigorously tested for emissions, efficiency, electricity output and other qualities.,

Automated wood stoves can enable consumers to “load and leave” and get a high efficiency clean burn through sensors that can adjust by the minute and are far more effective than a human operator. Electricity producing stoves can recharge cell phones, power light bulbs in the event of a short or longer power outage caused by storms, grid failure or any other reason.  Within 3 – 5 years, electricity producing wood stoves may also be a more common option in the northern US to complement low wintertime solar PV output. In the future, thermoelectric wood stoves may be able to produce half as much electricity as a residential solar PV installation in December and January in northern states.

Wood is a popular residential heating source in Pennsylvania. According to the latest Census figures, Pennsylvania has the highest number of households heating with wood outside New York and California. Approximately 3% of all homes in the Commonwealth use wood as a primary heating source, but in 16 counties, 10% or more of households use wood or pellets as a primary heat source according to the US Census: Fulton (20%), Sullivan (20%), Juniata  (19%), Forest (16%),  Potter (16%), Tioga (15%), Susquehanna (15%) and Bradford (14%), Bedford, (13%), Huntington (13%), Mifflin (13%), Perry (13%), Crawford (11%),Wayne (11%) and Warren (10%).  More than half a million Pennsylvanians use it as a primary or secondary heat source.  

“Woody biomass is an abundant renewable heat feedstock which has been used by generations to provide low-cost heating for homes across Pennsylvania.  WPPSEF seeks to better understand how modern, innovative wood stoves can affordably help meet energy needs while operating far more cleanly than traditional wood stoves,” says Joel Morrison, Director of the WPPSEF.

The Alliance for Green Heat promotes modern wood and pellet heating systems as a low-carbon, sustainable and affordable energy solution. The Alliance works to advance cleaner and more efficient residential heating technology. The Wood Stove Design Challenge in November 2018 will the fourth Design Challenge hosted by the Alliance for Green Heat. Founded in 2009, the Alliance is an independent non-profit organization and is tax-exempt under section 501c3 of the tax code. 

The West Penn Power Sustainable Energy Fund (WPPSEF) is a 501(c)(3) nonprofit organization that invests in the deployment of sustainable energy technologies that benefit West Penn Power ratepayers in Pennsylvania. WPPSEF investments are focused in three broad categories:

✓     Deployment of sustainable and clean energy technologies; 

✓     Deployment of energy efficiency and conservation technologies; and 

✓     Facilitating economic development, environmental betterment, and public education as they relate to sustainable energy deployment in the WPP service region.

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Visit http://www.wppsef.orgfor further information.

Contact John Ackerly, 

Alliance for Green Heat, 301-204-9562
jackerly@forgreenheat.org

Contact Barbara Robuck, 

West Penn Power Sustainable
Energy Fund, 814-865-7380
wppsef@ems.psu.edu

Vacuum left after one of nation’s top stove regulators and experts retires

When Rod Tinnemore was invited to speak about wood stoves, he didn’t sound like a regulator.  He spoke his mind, he made people laugh and he was never at a loss for words.  Rod was in charge of wood heater regulations in Washington State, the state with the toughest regulations in the country.  By the time he retired in April 2017, he left behind a far-flung community of stakeholders who admired him – or at least respected his judgment.

Rod Tinnemore became an Environmental Planner at the Department of Ecology in 2008, years after the state was pummeled by industry for the audacious move of requiring all heaters to meet a standard of 4.5 grams of particulate per hour.   Rod became the guy who enforced that decision, and it was one he was happy to enforce, because he felt stoves could and should be required to burn cleaner than the federal standard of 7.5 grams an hour.

Washington State also required that all stoves sold and installed in the state be EPA certified.  To enforce this, Rod regularly emailed residents residents trying to sell old, uncertified stoves on Craigslist.  “Most people didn’t know the regulations and were happy to discard the stove instead, but some just sold it another way.  Periodically, we found big box stores selling new, uncertified stoves and had to send them overnight certified letters as well,” Rod recalled.

Rod’s retirement leaves a vacuum among the regulator community, as there are very few non-federal stove regulators who have the depth of experience and expertise that Rod had.  He influenced policies in change out programs in Washington State and beyond and was one of the most influential state regulators in the EPA's process to develop the New Source Performance Standards (NSPSP).

“Rod was able to build bridges between different factions and he was a diplomat – but he also knew when to take a stand,” said Lisa Rector, a Senior Policy Analyst at the Northeast States for Coordinated Air use Management (NESCAUM).

Many key figures in the wood stove industry thought highly of Rod, in part because he was accessible, responsive and practical.  “Rod had a healthy appetite for knowledge and was a great listener with no preconceived bias.  He was always asking great questions so as expand his knowledge base,” said Chris Neufeld, a vice president at Blaze King and Co-chair of the solid fuel section of the Hearth, Patio and Barbecue Association (HPBA).

Some in industry butted heads with Rod because Washington State regulations prevented almost all outdoor and indoor wood boilers from being sold and installed in Washington.  But even companies representing those appliances often said that they he dealt with them fairly.

At least once, in 2013 when HPBA did not like an initiative Rod was spearheading, they had a lobbyist go to the legislature to send a message that Rod’s department’s funding could be in jeopardy if he pursued the initiative.  Rod ultimately had to back off, ending his exploratory work to start a consumer green label for wood stoves.

Rod was also considered one of the insiders of a small group of regulators in the United States who really knew what he was talking about.   Rachel Sakata, who did similar work for the State of Oregon as an Air Quality Planner, said that she continually relied on Rod’s expertise.  “Rod also was a champion for pushing for cleaner devices and thanks in part to him, we now have stricter regulations for wood heating devices that help protect the public,” said Ms. Sakata.  “And he continued to push for developing testing protocols that mimic real world conditions,” she said.

The Alliance for Green Heat also worked closely with Rod, recruiting him to serve as a convener and a judge for our Wood Stove Design Challenge events in 2013 and 2014.  He also served on a committee that we pulled together to integrate stoves into energy audits, leading to BPI adopting them in 2015.  The Alliance was also one of the stakeholders urging Rod to develop a consumer green label for stoves.

After Rod left office, the Alliance for Green Heat interviewed him, in between various trips and activities, for this blog.

Q. What do you consider one of your successes?
A. Working on and helping to fund a new cordwood test protocol that someday could become a Federal Reference Method (pdf) or possibly a state sanctioned cordwood protocol. We focused on testing various tree species to see which ones produced more PM, but most importantly we tried to get a protocol that resembled how homeowners start and use their stoves – which Method 28 did not. This initiative is now being managed by NESCAUM using Mark Champion’s lab in Vermont and I am very pleased with how it’s progressing.

Q. What was something that you did not succeed at?
A. Not being able to continue working on a consumer green label for wood stoves. This country needed a label to recognize high performing stoves and we still don’t have one that is robust and well recognized.

Q. Who were your closest colleagues?
A. Decades ago, West Coast regulators led the efforts to reduce wood smoke, but more recently, its shifted to the East Coast. California is very progressive but not influential on wood smoke issues because it is so fragmented into so many air districts. Other than Oregon, it was more fruitful for me to work with NESCAUM, NYSERDA, Brookhaven National Lab and the Wood Stove Design Challenge events.

Q. What was the best advice your boss ever gave you?
A. He told me early on that my job could be whatever I made of it.

Q. What was best guidance from your department?
A. The Department of Ecology had a policy of returning phone calls within 24 hours and emails within 48 hours. I thought that was good policy and I tried to live up to it every day.

Photo essay: wood stoves around the world

(Updated, March 2022) Heating with wood stoves is common in many countries around the globe, particularly in rural areas where wood is plentiful.  Wood heating is also tied to poverty to a certain extent in most countries and can rapidly grow when fossil fuel prices spike.

We show typical wood heating stoves in 40 countries, though its impossible to capture a country's stove heating culture in a single photo.  Most countries where wood heating is popular have a wide range of stove technology, from older, obsolete stoves to modern, expensive models.  We focused on older stoves as they tend to be more common in most countries to show the widespread problem of aging stoves that need to be replaced with newer ones - or other affordable heat sources.  Most countries have no regulations that set particular matter standards for new stoves. The issue of public funding for change out programs is often not an option.

We compiled a separate photo essay of firewood collecting cultures around the globe that tell equally important stories about the benefits of using a free, local fuel as well as the problems it can cause.

A home in the United States

Many countries are neglecting the development of a generation of cleaner wood and pellet heating stove technology.  Wood stove technology is developing in many countries, as shown in some of the photos below. But the pace is far too slow to match the economic opportunity and environmental and benefits that wood offers, and the air quality dangers it can otherwise pose.

Over the last 10 years, we have seen populations turn to wood stoves in large numbers our of political and/or economic necessity. The invasion of Ukraine is driving increased energy prices, and thus the increased reliance on old and new stoves; the 2008 banking crisis in the US and Europe contributed to a meltdown in Greece, leading to widespread unemployment and a nationwide resurgence in wood stove use; incentive structures in the U.K. have led to more wood stoves, instead of pellet stoves.

These photos show how this ancient fuel source persists in helping to affordably keep people warm.

Albania

Armenia

Bhutan

Byurakan, Armenia

Australia

 Austria

Azerbaijan

Belarus


Bulgaria

Canada

Chile 

China 

Czech Republic

Denmark

Ecuador 

Finland

France



Georgia (formerly USSR)

Germany

Greece



Hungary

India

Italy

Ireland


Japan

Kazakhstan

Kyrgyzstan

Korea 

Lithuania

Montenegro


New Zealand

Norway

South Ossetian Autonomous Oblast
(former USSR) 

Peru

Poland

Portugal


Romania

 Russia

Slovakia

Syrian refugees (in Bulgaria)


Tajikistan

Tibet

Ukraine

United Kingdom




United States

Vatican