Consumers can now rely on almost all stove tax credit certificates issued by manufacturers

A sampling of tax credit certificates
issued by various manufacturers 

After ten years, almost all stove and boiler manufacturers appear to be accurately informing their consumers about which models are eligible for the tax credit for wood heaters that are at least 75% efficient.  Some outlets, such as We Love Fire, a network of 280 hearth retailers, go out of their way to educate customers on how to ensure the stove they are buying qualifies for the credit and urges them to check the EPA’s database.

There was widespread exaggeration and misleading advertising about stove efficiencies in the preceding decade, and the EPA did not require wood and pellet stove manufacturers to disclose the efficiency of their models, or even to test for it until 2015.

Consumers are often advised to download the manufacturer certificate and keep it in their files, along with the receipt for the stove, as proof that they properly took the credit.  However, the IRS does not require manufacturer certificates, and a screenshot of the EPA database, showing an efficiency of at least 75% for your model is even better documentation.

 

When Congress passed the new, higher tax credit legislation in 2020, they specified that the minimum 75% efficiency level must be measured using the higher heating value (HHV), eliminating previous ambiguity. However, Congress did not specifically refer to the EPA’s database, which lists the HHV efficiency of all stoves, boilers and furnaces.  Almost all of industry accepts the EPA database should be used to confirm efficiencies and encourages consumers to check it.  The Hearth, Patio & Barbecue Association (HPBA), the industry’s largest association, broke from its past practice and took a strong position that consumers should rely on the EPA database to determine efficiency.

 

The Ashley line of stoves is owned 
by US Stove, which issued this
current certificate.

AGH reviewed scores of certificates issued by stove and boiler manufacturers by brands such as Hearthstone, Jotul, Lopi, Quadrafire and many others and found for the first time that they all were providing their consumers accurate information.  We found only one stove manufacturer, US Stove Company, still willing to list stoves as qualifying for the tax credit that are under 75% efficient.  US Stove issued a certificate saying that four of its pellet stove models qualified for the credit despite test reports from third party EPA-approved labs showing the models have efficiencies of 64%, 66% and 69% (which is also how they are listed on the EPA database).  (As of Sept. 2022, US Stove still claims these units qualify for the tax credit.) The average pellet stove is about 73% efficient. Their test reports are provided on the US Stove website.  

John Voorhees, Vice President for Compliance at US Stove, signed the tax credit certificate that states

The Ashley certificate juxtaposed with
the EPA database 

“Under penalties of perjury, I declare that I have examined this certification statement, and to the best of my knowledge and belief, the facts are true, correct, and complete.”  AGH reached out to Mr. Voorhees for clarification and to ensure the US Stove position was included in this blog, and though we exchanged many emails and US Stove provided relevant information, the company declined to permit AGH to quote from that exchange.  AGH will update this blog if US Stove chooses to provide any information that we can make public.

 

It is unclear why US Stove singled out the four models on this certificate when other models are listed with higher efficiencies, though none are above 75% except for one pellet stove made by their Breckwell brand.  When the tax credit was first passed by Congress in 2009, most companies declared that all of their models qualified.  That year, US Stove issued a certificate saying that 24 models were eligible for the credit requiring a minimum of 75% efficiency.  

In 2009, like many manufacturers, US
Stove listed all or almost all of of their
 models as meeting the requirements of
the 75% minimum efficiency tax credit.

Today, most boiler and furnace companies also seem to be following Congress’s plain language and only certifying units at 75% or more.  Boiler efficiencies are more complex because there are several test methods and the resulting efficiencies aren’t as comparable as they are with wood and pellet stoves. AGH found one indoor wood furnace manufacturer, Hy-C who makes the Shelter furnace, tested at 70% efficiency by the lab but the company issues a Certificate of Qualification that it meets the 75% HHV threshold. 

 

Tax credits for consumer appliances have a variety of purposes, in addition to incentivizing consumers to buy higher efficiency appliances.  They are designed to influence manufacturers to improve product efficiency, accelerate market penetration of more efficient products and potentially prepare the market for future mandatory requirements.  Currently, there is no required minimum efficiency for wood and pellet heaters.  For pellet stoves like the ones in question, they range from 58% efficient for a model produced by US Stove, to an 87% efficiency unit from Cleveland Iron works.

 

Wood and pellet stoves and boilers are an excellent way to reduce fossil fuels and affordably heat your home, especially in seasons like this one when fossil fuel prices are high.  Federal tax credits are an efficient way to help households reduce fossil fuel use with a renewable, low carbon fuel.  However, unless consumers use seasoned wood of under 20% moisture content, wood stoves can produce excessive smoke and will not reflect the efficiency achieved in the test lab.  AGH considers pellet stoves to be the optimum choice, as their combination of high efficiencies and very low particulate matter make them suitable for both rural and more densely inhabited towns and suburban areas.  Unlike wood stoves, the efficiency numbers achieved in the lab can generally be achieved by consumers if the unit is maintained properly. 

 

Even though most manufacturers are now issuing tax credit certificates for stoves that are at least 75% efficient, AGH urges consumers to also check the EPA’s database of wood heaters to be sure.  AGH has been in touch with IRS officials, urging them to issue guidance that wood heaters must be listed at 75% efficient or higher on the EPA database to close any remaining loopholes that a few manufacturers still try to use.  

Further reading

AGH urges the IRS to recognize efficiencies in the EPA database, Feb. 2021

Guidance on the 26% tax credit for wood heaters, Jan. 2021

A review of wood and pellet stove efficiency ratings, Jan. 2014, updated May 2020

How to claim the tax credit, Feb. 2018, updated Jan. 2021

Inspector General investigating EPA’s oversight of its residential wood heater program

On October 22, 2021, the EPA’s Office of the Inspector General announced it was launching an investigation into the EPA’s residential wood heater testing and certification program. The memo announcing the investigation was directed at both the Office of Enforcement and Compliance (OECA) based in DC and the Office of Air and Radiation (OAR) whose staff is mainly based in Triangle Park, North Carolina. The report is scheduled to be published sometime next year.

The Office of the Inspector General is “an independent office within the EPA that helps the agency protect the environment in a more efficient and cost-effective manner.” It identifies areas it believes need investigation and issues a public report with recommendations. While it does not have enforcement power, the EPA is expected to take the Office's recommendations seriously. There can be disagreements over priorities and that is already happening in the water program and elsewhere. The OIG also submits semiannual reports to Congress. In the event that the EPA ignores any of the recommendations made by OIG, it is possible that the agency can be pressured to address them through hearings, appropriations riders or funding. The EPA OIG can also uncover criminal behavior, which would be addressed accordingly by the U.S. Attorney's Office.

 

More specifically, the memo announcing this evaluation says, “Our objective is to determine whether EPA effectively uses its oversight and enforcement authority to ensure that all residential wood heaters reaching consumers are properly tested and certified in accordance with established standards. … We may also choose to include a sample of regions in our evaluation and to conduct work at laboratories and third-party certifiers in selected regions.”

A current ad for uncertified
outdoor wood boilers

Before publicly announcing this evaluation, the OIG contacted the Alliance for Green Heat on Oct. 13, 2021 and held a conference call with AGH on Oct. 21. For years, AGH has been raising alarm bells about the lack of EPA enforcement in a number of areas, including the numerous companies that continue to manufacturer and sell outdoor wood boilers. AGH has often contacted the EPA Office of Enforcement and published stories on our newsletter on companies who make and/or distribute uncertified residential central wood heaters, including ACME (Missouri), EZBoiler (Michigan), Hyprotherm (Arkansas) and MBTEK (Pennsylvania distributor of Polish appliances). AGH has spoken with most of the companies by phone and they say that they have never been contacted by the EPA or a state agency about certification issues.

AGH also raised EPA’s failure to contact the whistleblower regarding the credible allegations of fraud at US Stove Company, along with a number of other areas where enforcement action was needed.

The OIG’s evaluation is also believed to have been triggered by the NESCAUM report, Assessment of EPA’s Residential Wood Heater Certification Program, that found a “systemic failure of the entire certification process, including EPA’s oversight and enforcement of its requirements.” That report led the EPA to conduct its own review of the certification paperwork for all certified stoves. The EPA is contacting scores of companies to obtain missing information or for clarification. In some cases, it is requiring the company to have the stove tested again.

If you have evidence of misconduct or mismanagement regarding the EPA’s oversight of wood heater testing or certification, you can provide information using this form, and refer to case OSRE-FY22-0026.

Further reading:

EPA fines stove retailer, pursues informal enforcement with many others, Jan. 2020

AGH files report with Consumer Product Safety Commission on alleged fraud, April 2021

Report finds ‘systemic failure’ in EPA wood stove tests, March 2021

Safety recalls of wood and pellet stoves

Updated: July 2022 - There have been at least seven recalls of wood and pellet burning products since 1979 and one certification revocation.  Four of those were in 2015-2016.  While there are few reports of any injuries, recalls are expensive and time consuming for stove manufacturers.

(In addition to stove recalls, the Consumer Product Safety Commission recalled a camping tent sold by Cabellas in July 2022 because the "stove jack ring" where the stove pipe exits the tent, can deteriorate.)

Almost all recalls are voluntary, which is usually to the benefit of the company.  A successful recall effort often reaches about 65% of consumers, and it the case of wood or pellet stoves, it may depend on who sold them and how much effort the company actually made.  Its easier for some stove manufacturers to track down who purchased a particular stove if it was purchased through a specialty retailer compared to stoves purchased through hardware chains.  For the following seven recalls of wood and pellet stoves, there is no data about how effective each recall was.

The dangers posed by some of the stoves subjected to recalls are significant but may pale in comparison to the ongoing dangers of self-installed stoves that never get inspected.  The Consumer Product Safety Commission (CPSC)'s 1982 survey of more than 2,000 households indicates that 70% of stoves in use were installed by the consumer, and half of these "do-it-yourself" installations were never inspected by a building or fire inspector.  A very high percentage of self-installed stoves remains a high probability in the US, in part because of the increasingly high volumes of stoves sold through hardware chains and on-line.  The percentage of self-installed stoves purchased on the second-hand market could be even greater than the 70% figure found in 1982.  In addition to dangerous self-installation practices, the other main cause of stove-related house fires is excessive creosote build-up in chimneys that are not regularly cleaned.

 

The highest volume recalls have been pellet stoves, which pose less of a fire risk when self-installed, or from lack of chimney cleaning.

 

1. The recall impacting the most devices was the 2015 recall of the US Stove HomComfort pellet stove that could be mounted in a window or wall.  This recall involved 4,400 units, which provides one of the few insights into volumes of particular units.  The Chinese-made stove was sold at Northern Tool, Rural King, Home Depot and Lowes from 2010 to 2012.  There were 16 reports of fires and property damage, but the recall did not happen until three years after the product run.  US Stove offered $868 cash or $1,200 credit towards the purchase of another US Stove product. Those amounts are still available from US Stove.  An updated version of the stove is 2020 certified but only supposed to be mounted in walls, not windows.

 

2. The next largest recall was England Stove Works pellet Smartstove.  The US-made unit was only sold for a few months in the fall of 2015. After the company received four reports of incidents and one minor injury, it initiated recall the following year.  Englander sent consumers a free repair kit to remedy the issue.  An updated version of the stove is 2020 compliant and on the market.

 

3.The next largest recall was for 2,000 Mt. Vernon pellet stoves made in the US by Quadrafire, a subsidiary of Hearth & Home Technologies.  The $4,000 stove was sold for almost a year between 2014 and 2015.  There were eight reports of glass breaking after excessive pressure built up in the firebox but no reports of injuries.  The company remedied the issue by offering to arrange for free installation of an enhanced control board. The firm's dealers contacted known purchasers.  An updated version of the Mt. Vernon is also 2020 compliant and on the market.

 

 

4. The following year saw a much smaller recall of a Quadrafire device. This time it was a wood stove, the Explorer III, and involved 650 units.  The US-made unit was sold for about a year and a half for $3,000.  The danger was that the handle of the top lid could disengage and the lid could fall.  There were five reports of incidents, two of which involved minor injuries to fingers. The company offered to fix the problem through its dealer network. The Explorer is off the market.

 

 

 

5. A small recall of 200 Scan Andersen wood stoves made by Jotul occurred back in 2010.  A faulty door hinge led to the door falling off, and of the three reported incidents, one consumer received a bruised foot.  The stove was made in Norway and the fix was a free hinge repair.

6. Going back a bit further in time, there was a recall of 1,300 EPA certified, catalytic Vermont Castings Sequoia wood fireplaces in 2006.  At the time, Vermont Castings was owned by the CFM corporation and the units were made in Canada and the US.  They sold from 2003 to 2006 for about $2,200.  This was a more serious recall, as it involved insufficient insulation or a missing weld, and could cause these fireplaces to pose a fire hazard, though no incidents were reported.  Consumers were advised to stop using the product immediately, and it is not clear if the company offered any remedy after 2008 when they went bankrupt. 

 

 

7. The final recall listed on the CSPC database dates back to 1979, and involved glass for stove doors that posed a breaking hazard. The glass doors were in “Hearth-Glo” wood burning circulators made by the Jackes Evans Manufacturing Company. These sold in 1977 and 1978, right before the EPA began requiring wood stoves to be certified. One thousand stoves were involved and customers could get free replacement doors.

8.  While not yet a formal recall, the EPA is taking an unprecedented step of revoking the certification of a wood stove because the lab did not do the test correctly and the EPA certified the stove because it did not carefully read the lab test report.  The stove in question is the England Stove Works Model 50-T tested by Intertek, and the wood they used was too dry. It appears that Englander tried to test it again but couldn't get it under 2 grams an hour. Englander had requested a hearing, but they pulled out of the hearing process and the EPA is finalizing revocation of the model line in April 2022, which apparently will mean those models will have to be recalled from retailers.  

States take on the EPA in controversial wood stove proposal

Mary Uhl of WESTAR testifying at a
2018 air quality meeting.

Industry touts economic strain on stove retailers, but outdoor wood boiler and furnace manufacturers are also behind campaign for more time

Updated on June 17 - A virtual EPA hearing on June 8 pitted states against the EPA over emission limits from wood stoves, boilers and furnaces.  The EPA is proposing to ease the emissions compliance timeline for wood stoves and boilers but over a dozen states urged the EPA to withdraw its proposal.  Minnesota formally told the EPA and the wood heating industry that stoves and boilers must comply with the existing timeline that was set in 2015 for sales and shipments in their state.  California’s Air Resources Board took a more combative tone and said they are considering a lawsuit for the illegal sale of non-compliant stoves after May 15.

“Minnesota incorporated the 2015 NSPS and its 2020 timetable into state laws … which means that the May 15, 2020 compliance deadline is enforceable in Minnesota. EPA’s proposed revision will not change this deadline,” said Anne Jackson, an engineer with the Minnesota Pollution Control Agency in her written testimony.

Peter Solac, a long-time Minnesota
based stove retailer who may not be
able to take advantage of a federal
time extension 

Peter Solac, of Woodland Stoves and Fireplaces, is a stove retailer based in Minnesota who testified that he needed the additional time for 15 Step 1 stoves that he was not able to sell due to Covid-19.  He did not address the predicament that his state will not allow it.   Central Boiler may face an even greater problem, as its manufacturing facility is in Minnesota, and they apparently still had some Step 1 boilers they want to sell.  On June 17, Rodney Tollefson of Central Boiler said in an email that "we have almost zero inventory of 2015 level certified units.  We are not asking for a sell through for us.   Our testimony was requesting sell through for our dealers that have inventory."

US Stove has also indicated their interest to ship units from their manufacturing facility during the proposed sell-through.  On May 29, Brandon Barry of US Stove wrote that “our inventory levels are confidential. I will say that sell through would be beneficial for us at both the manufacturing and retail level.  Some product came back to our location and could be sold if sell through comes to fruition.” On June 10, Mr. Barry said that AGH had misunderstood his previous email that that “We have been buying product back from retail. All that does is hurt our cash flow, which ultimately impacts our ability to manufacture new 2020 products. We understand that this is a “retail” sell through under consideration and not a manufacturers sell through.”

List of registered speakers at the
June 8 EPA hearing

However, England Stove Works, another major value stove manufacturer that also had buy back agreements clearly said that they do not have inventory they need to sell during a sell-through but like many other stove manufacturers, they support the ability of their retailers to use a sell-through.  Other manufacturers who indicate that they do not have Step 1 inventory themselves include Blaze King, Empire, Hearthstone and SBI, but all support the sell-through for their retailers.  David Kuhfal, CEO of Hearthstone said, “Hearthstone proactively sold down all step 1 products however; we absolutely support the opportunity for our dealers to have some time to liquidate their Step 1 inventory.”  Hearth & Home Technology, the largest manufacturer of more expensive stoves, say that they have no Step 1 inventory and their retailers should have been able to clear out their Step 1 inventory on time as well.

AGH asked HPBA if they were also seeking a sell-through for manufacturers and received this reply from Emily McGee, their Communications Director: "the reason we didn't reply to your question was that we don't have a position on that specific issue (manufacturers selling Step 1 products during a potential sell-through). Our focus has been on the retailers and remains so."  Many retailers have gone further, saying that the sell-through should not be open to manufactuers.

Of the 17 people who testified, about half were in favor of the sell-through and half were against it.  As with previous hearings and written testimony on the EPA wood heater regulations, all states and regional air agencies representing states were against extending deadlines.  Several retailers, a distributor, two manufacturers and HPBA representatives testified in favor of it.  Three non-profits were represented with the American Lung Association and EarthJustice speaking against, and the Alliance for Green Heat who favored a limited sell-through.  AGH is urging the EPA to only allow the sell-through for retailers, not manufacturers and also to limit it to stoves, not to central heaters.  Manufacturers of central heaters have been at the forefront of the fight for extended deadlines and sell-through and pose the largest threat to increased air pollution.

John Crouch, in upper left, in Crested
Butte, CO in 1989 with Bob Ferguson.

The arguments made by both sides were relatively predictable, with very little common ground.  However, Roger Ayers of Dreamstyle Remodeling focused on the need to regulate fireplaces that he estimates emit 44 grams of particulates per hour. Why focus on the difference of a gram or two between Step 1 and Step 2 when any home can still install unregulated fireplaces.  John Crouch of HPBA reminded everyone that many Step 1 stoves were already under 3.5 grams an hour and “the EPA has done no in-home testing of Step 1 or Step 2 stoves and has no way of knowing if these Step 2 stoves are an improvement or not.” 

Industry has asserted that there should have been a sell-through period built into the timeline from the start, like there was in 1988.  Mary Uhl of WESTAR countered that contention in her testimony, saying “In contrast to the original 1988 NSPS, in which manufacturers and retailers were allowed only two years to transition to more stringent standards, they received five years in the 2015 NSPS update.” 

Most of the states and air agencies argued that the EPA lacked a legal basis for the proposal,  did not do any regulatory impact analysis and is proposing to substitute two of the worst sales months for two of the best.  Maria Smilde of EarthJustice closed her testimony saying “Considering that respiratory difficulties have been a common COVID-19 symptom, the EPA should not use one public health crisis to rationalize extending another, nor does the Clean Air Act permit it to do so.”  Anne Jackson made a similar point, arguing that, “Given the health burden of fine particulate matter, there is no good reason to provide additional time to sell noncompliant devices, especially hydronic heaters, in the face of fighting a deadly, respiratory virus pandemic.”

Possibly the most surprising arguments against the sell-through came from the Minnesota Pollution Control Agency. “Minnesota was expecting full support from EPA to notify manufacturers and retailers about the approaching May 2020 deadline, and to undertake enforcement as necessary, especially with internet sales, as that is the most difficult for Minnesota to monitor. With EPA’s announcement of a proposed sell-through period along with lax enforcement, Minnesota must now undertake a nation-wide communication effort to notify manufacturers and retailers that Minnesota law does not allow sales in Minnesota of non-Step 2 wood-burning appliances.“

California is an anomaly as stationary sources of pollution are controlled by local air districts, not by the state.  Their Air Resources Board commented “Many states, and over half of California’s 35 local air districts, including the largest air districts, have delegated EPA authority to enforce the NSPS.  Under Clean Air Act section 304, states, other jurisdictions, and private citizens can also file citizen suits for sale of Step 1 stoves before any sell-through is finalized.  EPA may have chosen not to enforce the Step 1 sales ban in the period before any sell-through is finalized, but others can.”

The EPA will be transcribing all the testimony from the hearing and entering it into the official record, as they consider whether to approve a sell-through. 

Related stories

EPA and states vigorously defend wood stove audit testing (Sept. 2020)

Company makes 2020 certified warm air furnace for under $2,000 - and stirs controversy

Paul Van Der Eems, Dan Haynes,
and David Walters of HY-C accept
a Vesta Award for their furnace.

Updated on April 5, 2019 - Many said it could not be done.  A competitor called it “preposterous.” But HY-C, a Missouri company that makes a budget line of warm air wood-fired furnaces, is well on their way to being ready for June 2020, when stricter EPA regulations come into effect.  

Their first 2020 compliant model, their smallest unit, was certified at 0.106 lb/MMBtu Output, well under the .15 allowable. The suggested retail price is $1,899 which is only $100 more than the previous unit that was certified to the 2017 standards.  HY-C won a Vesta Award for the furnace at the industry’s annual expo in Dallas last week.

In 2014, HY-C went to the EPA and urged them to adopt a laddered approach, giving companies several years to get certified and several more to meet a stricter standard. “The EPA was responsive, giving us a total of 5 years,” David Walters, President of HY-C recalled in a phone interview.  David said that  when they bought the company in 2011, the NSPS process was well underway, and they knew they would have to change and clean up.  “It wasn’t easy, but we did it, and that is good for the environment, for consumers, and for us, the manufacturer,” David said.

The HY-C FC100E is the first
low-cost wood fired forced air
furnace to meet the strict EPA
2020 emission standards.

The EPA won’t list a certified unit on the list of certified appliances until the company posts their lab test report on their website.  Parts of those reports are highly technical but provide key information for consumers and others. The HY-C report said the unit achieved 50% delivered efficiency and a stack loss efficiency of 71%. It was certified using a modified test protocol that had been approved in advance by the EPA.  Intertek laboratories did the testing using about 36-pound loads of cord wood that had about 22% moisture content.  The five tests ran 3 to 6 hours.  Their target output was 13,000 – 37,000 BTUs but the certification test obtained 20,000 – 34,000, due in part to the modified test protocol. 

To date, the only other company to have a 2020 compliant forced air furnace is Lamppa Manufacturing, which hit .09 lbs/MMBtu several year ago and a stack loss efficiency of 79%, far above the HY-C.  The Lamppa unit, the Vapor-Fire 100 is currently priced at $5,695 and also obtained a test protocol variance from the EPA in the test protocol.  The Vapor Fire weights 670 pounds, which may indicate thicker and more durable materials compared to the HY-C unit at 435 pounds.  (Update: SBI has certified a third wood furnace, under the Caddy brand.)

The Lamppa Vapor Fire
100 is the only other 2020
compliant wood furnace,

Another big player in the forced air furnace space is US Stove, and it’s unclear when they will have a 2020 compliant unit.  Of their eight units certified to the 2017 standards, one came in at 33% efficiency and an average of 60% efficiency. US Stove is urging the EPA to repeal the Step 2 standards for forced air furnaces, arguing that agency picked a “compliance limit out of thin air with not [sic] real data to support it.”  In a filing with the EPA, they said that the EPA’s timeline of going from an uncertified appliance category to meeting .15 mmBTU “is preposterous and unrealistic.”  HY-C appears to have just proved otherwise.

However, the willingness of the EPA to approve alternative test methods can be controversial, and companies often claim a competitor got an unfair advantage with a particular variance.  The EPA is not supposed to approve variances that make the protocol easier to pass, but that may just what is happening in some instances.  Variances are a critical tool for the EPA to allow for innovative products to be fairly tested and they also create a precedent for others to receive similar variances.

The largest player in the Canadian forced air furnace market is Stove Builders International (SBI) and they do not directly compete in the budget market with US Stove or HY-C.  SBI is also working on certifying furnaces to the 2020 standards but “we are trying to achieve the desired performance without using the alternative test method that the EPA has granted to others,” said Marc-Antoine Cantin, of SBI.  “We want to put out a product that cycles combustion and doesn’t just cycle the blower, while the unit is kept burning at a single burn rate,” Cantin said.  

HY-C sells their furnaces through a variety of distributors and retailers, including many big box stores. They provide all of their own customer services and have tens of thousands of units in the field that provide them with intensive customer feedback.  They make all of their furnaces in St. Louis Missouri and have extremely little inventory of non-2020 inventory left and expect to start shipping 2020 compliant units in July.  “We worked hard with distributors, so the pipeline of older units is dry,” Walter told us.  As a result, they have abstained from the debate as to whether the wider industry needs a 2-year sell through for units that are not 2020 compliant.  Lamppa has been an outspoken defender of the original timelines, arguing that a 2-year sell through would be unfair. Click here for more on that debate.

The EPA exempt US Stove 
1357 Hotblast  "coal only" furnace 
also advertises "21 in. log 
capacity" at Home Depot (Home
Depot discontinued the unit
a week after the story appeared.)

Both US Stove and HY-C say that their customer base is very price sensitive and need a furnace under $2,000, if not close to $1,500.  Other industry experts have questioned how so many people came to expect a whole house furnace for less than the price of an average wood stove and assumed that price would have to climb substantially to meet 2020 emission standards.  At the core of the fight between industry, states and air quality agencies is whether the price of wood appliances and costs to manufacturers should drive EPA standards more than other factors.  While HY-C was able to meet both the timeline and the emission standards, it is still unclear how well it will be received by the general public.  US Stove also make “coal only” units that are exempt from EPA emissions and sell side-by-side in many stores with the regulated wood units. HY-C has a coal only unit but only sells a few each year direct to consumers and not through retailers.

According to one industry insider, Tractor Supply Company stores is the biggest seller of wood furnaces from their 1,700 US stores.  Floor staff at chain hardware stores like this have reportedly been trained to inform consumers that the “coal only” units can burn wood perfectly well.  Companies that make both wood and coal units benefit from this and can sustain market share, even as EPA standards tighten.

Certifying to 2020 standards appears to have led to shorter burn times and more finicky furnace and boilers for some units.  HY-C advertised up to 12-hour burn time and a maximum of 130,000 BTU output for the unit as certified to 2017 emission standards.  The EPA listed BTU output up to 45,000.  The 2020 version only had up to 6-hour burn times in the lab and a maximum of 34,000 BTU output.  Both the 2017 and the 2020 model accept 20-inch logs.  Can the 2020 version meet consumer expectations at virtually the same price? 

But for now, HY-C achieved what they set out to. “We planned to build a better mouse trap and we feel that we succeeded, with advice from industry experts and our consumers,” David Walter said.  “In America, we should not take for granted that we have clean air and water, thanks to Congress and decades of work by the EPA,” Walter continued.  If anyone thinks the EPA efforts are a waste of time, Walters says all you have to do is visit Shanghai or some other foreign cities. “It’s so polluted you can barely walk outside and see the other side of the street,” he said.

AGH testimony on EPA's proposed sell-through for wood boilers and furnaces

On November 21, 2018, EPA proposed amendments to the New Source Performance Standards (NSPS) for Residential Wood Heaters issued in 2015. The proposed amendments would allow retailers an additional 2 years to sell the existing inventory of hydronic heaters and forced-air furnaces. EPA is also taking comment on a similar sell-through provision for wood stoves and on whether the pellet fuel requirements should be revised.  This is the statement delivered by John Ackerly, the President of the Alliance for Green Heat at the EPA hearing held on December 17, 2018.

Via Public Hearing

U.S. Environmental Protection Agency  

EPA WJC East Building

Room 1117A&B

1201 Pennsylvania Avenue NW

Washington, DC 20460

Attn:              Docket ID No. EPA-HQ-OAR-2018-0195

Re:                  Statement of the Alliance for Green Heat in response to EPA’s Proposed Standards of Performance for New Residential Wood Heaters, New Residential Hydronic Heaters and Forced-Air Furnaces, 83. Fed. Reg. 61,574 (Nov. 30, 2018).

Thank you for the opportunity to testify here today.  My name is John Ackerly and I am the President of the Alliance for Green Heat. We promote modern wood and pellet heating systems as a low-carbon, renewable and affordable energy solution. We just hosted the 4^thWood Stove Design Challenge, highlighting R& D and innovation in the sector.  This industry has a lot to be proud of and some of people in the room today make some of the cleanest wood and pellet stoves in the country, enabling consumers to substantially reduce fossil fuel usage.  This is a critical juncture for the EPA with regard to residential wood heaters and there is a lot at stake with regard to air quality, energy and human health.

The Alliance for Green Heat strongly opposes the proposed amendmentsthat would allow manufacturers to sell Step 1 hydronic heaters and forced-air furnaces right up to May 2020 and retailers an additional 2 years to sell them.

I want to start by saying that this sell-through is a waste of EPA’s resources.  The agency has far more important things to consider, such as addressing how we transition to testing with cordwood.  The EPA does not have endless time and resources to regulate wood and pellet heating. Please spend EPA’s valuable resources on issues that will advance our industry and improve efficiencies, not prolong the old technology that threatens the health of rural communities.

Second, it is very surprising that the EPA would consider relief for outdoor wood boilers, hydronic heaters and furnaces.  Most of these heaters are the biggest source of the air quality problems from this industry.  Given the high levels of emissions from these units, they give a bad name to all the cleaner types of wood and pellet heating appliances currently available to consumers.  EPA should not reward a small part of the industry that has not invested in technology to improve performance and emissions of its heaters.  Tens of thousands of low-income and rural communities could be stuck with these higher polluting units for decades to come if EPA finalizes a sell-through.  

Third, EPA’s preamble says that the agency is proposing a sell-through because “it is reasonable to assume that retailers may become increasingly reluctant to purchase non-Step 2-compliant wood heating devices.”  But isn’t that the desired outcome? Improving air quality and human health by increasing the efficiency of the residential wood heater sector is a principal goal of the original regulation.  It is the intended result of the regulation to move retailers to focus inventory on Step 2-compliant devices.  There is evidence that some retailers would likely switch to manufacturers that are producing 2020 compliant models.

Lamppa Manufacturing is one such manufacturer.  Lamppa is a smaller manufacturer, and they are looking to connect with retailers.  Their unit is very affordable at a retail price of $5,295 and is compliant with the 2020 Phase 2 standard. Tarm Biomass, who makes 2020 compliant wood and pellet boilers is getting calls from dealers looking for 2020 product.  So are others who have 2020 compliant units. . Competition in the marketplace is fundamental to consumers having access to more efficient and cleaner burning appliances. This proposal works against these market forces, and in effect subsidizes the worst performing technologies.

Step 2 compliant Lamppa furnaces
being built

We all know that this isn’t just to help retailers sell stranded inventory.  After all, who are the retailers?  Some of them are Home Depot, Tractor Supply, Northern Tool and other chains that need no help. Increasingly, retailers are on E-bay and it’s hard to even tell who they are, much less monitor compliance. And a big problem is that many manufacturers want to keep selling these Step 1 units  and never intend to do the R&D to become Step 2 compliant.  Giving them 2 more years just undercuts those who have the ability to meet Step 2. 

It is important for the agency and all stakeholders to reflect on the impact of Step 1 units on air quality and energy use.  One such unit made by US Stove Company is rated as only 33% efficient, yet the EPA says that their “proposed actions are anticipated to have negligible impacts on energy costs or usage.” In fact, there is clear evidence that cleaner, more advanced units will lower energy costs by decreasing overall energy use and improve air quality.

Units made by US Stove are often improperly or illegally advertised by their dealers, like this one that says it can be used with wood or coal. (Dec. 13, 2018 screen shot)

Fourth, EPA should work to improve compliance of a sector that, at times, has been reluctant to change and at times, simply ignores regulations.  Currently, there are thousands of illegal, newly manufactured uncertified new outdoor wood boiler and furnaces being openly sold around the country.  A recent conversation with a manufacturer in the Midwest claiming it offers “the highest quality outdoor furnace available on the market” even though the manufacturer has no certified units and openly sells non-Step 1 units.  The manufacturer said that EPA’s laws and regulations may not apply in Missouri, and that the regulations may have already been overturned.  This manufacturer has 81 dealers in 21 states and no indication anywhere on their website that wood furnaces and boilers need certification. Even more concerning is that EPA’s compliance office indicated that the agency has no record of the manufacturer’s existence or continued operation.  Many smaller companies also continue to sell and advertise uncertified outdoor wood boilers. 

An uncertified Acme wood furnace currently on the market. (Dec. 13, 2018 screen shot)

The Alliance is concerned that establishing a 2-year sell-through would add another layer of work and complexity to a regulation that has already shown serious enforcement challenges.

Finally, by providing a last-minute sell through, EPA is moving the “goal posts” in the middle of the game.  Manufacturers and retailers require regulatory certainty to make business decisions that make the sector more efficient, cleaner, and safer. Putting those companies that took the EPA deadlines seriously and invested in cleaner technology at a competitive disadvantage is simply bad policy.    

Companies have shown that best available technology is available and affordable.  We need an EPA to craft a regulatory framework that supports efforts to modernize the sector and then stick to it.  Do not approve this proposal.