Recommendations for California's wood stove replacement program

In the fall of 2022, the California Air Resources Board (CARB) published their draft guidelines for their annual wood smoke reduction program. The State legislature committed $5 million for the program that offers financial incentives for homeowners to replace older, high-polluting wood burning devices with newer, cleaner burning units.  The Alliance for Green Heat submitted the following comments, urging California to 1. focus first on households in more densely populated areas where the public health ramifications are the highest, 2. to consider the benefits of hybrid stoves over catalytic stoves and to expand the number of eligible non-cat stoves, 3. to make sure California fully integrates wood stoves into its energy audit and weatherization programs, which would lead to more voluntary stove removals and repairs, 4. and to study and better understand the actual carbon footprint of firewood based on estimates of how people source their wood.

Dec. 8, 2022 

Hon. Steven Cliff, 

Executive Officer

Channel Fletcher, 

Deputy Executive Officer, Environmental Justice

California Air Resources Board

1001 I St,

Sacramento, CA 95814

 

Dear Mr. Cliff and Ms. Fletcher,

Thank you for the opportunity to provide comments on your draft Program Guidelines to reduce wood smoke. Funds to replace older stoves with cleaner sources heat are funds well-spent, especially since many old stoves provide primary heat to homes of marginalized, lower-income households.  

1.      Focus on households in densely populated areas

Our biggest recommendation is to focus your resources on households in areas that are more densely populated and/or experience frequent weather inversions, where the public health ramifications of older wood stoves are the highest.  Stoves in very rural homes with few or no neighbors will have very few public health impacts. This is an area that more change-out programs should explore.  Hopefully, homes in these sensitive areas would opt for heat pumps or pellet stoves. For homes in densely populated areas, we would also encourage you to see if the home has a woodshed or a way to store their fuel.  

2.     Replacement devices

We fully support CARB’s decision to replace older wood stoves with low-carbon alternatives such as heat pumps and pellet stoves.  We would be wary to include electric resistance stove heaters because this may burden lower income homes with higher electric bills than they can afford, assuming electric rates rise in the future.  We are glad that CARB does not include gas stoves as that would have a counterproductive carbon impact and hinder electrification goals.

We do not have a high level of confidence in catalytic stoves as they often are not maintained or used properly as the years go by, especially in lower income homes who may not be able to pay to replace the catalyst when needed.  Hybrid stoves are a far better option, and we would urge CARB to focus on hybrid stoves because they still provide valuable PM reduction technology even if the cat is not engaged.  It is important to understand how stoves are likely to work in the real world, once they leave the lab, and cat stoves are a class of stoves that can work even worse than non-cats if they are not maintained or used properly, particularly after the home or stove is sold and the device is being operated by a new owner.  Some owners of older cat stove do not even know they have a cat stove.

We are extremely concerned that CARB is only making four models of non-cats eligible for change-outs. The four non-cats selected by CARB may operate better than some with greater testing flaws, but there is no proof that many non-cat stoves are just as good as the four you identify.  The process undertaken by the Alaska and NESCAUM was valuable in many ways, but it does not easily lend itself to being used to qualify stoves for change-out programs.  If CARB wants to identify non-cat stoves that would burn more cleanly, allowing more single burn rate stoves to qualify may be the best way.  However, most households do not want single-burn rate stoves, particularly if the stove is their primary heat source.  

A major dilemma for your program is that you are trying to serve many marginalized, lower income households and balance their legitimate energy needs with the impact their smoke will have on neighbors.  By choosing only 4 non-cats, you are sidelining the heating needs of these households in favor of a very questionable process to identify only 4 models, some of which are not likely to be available near these homes.

We support the effort undertaken by Alaska and NESCAUM but decisions like this, to select four stoves, takes their data beyond its usefulness. We think there is disconnect between limiting to 4 non-cats and serving low-income households.  Though we understand the desire to put Alaska’s work to use, it will likely be ineffectual in reducing PM in this change-out program. 

3.     Inspection, repair and safety

One of the best ways to start to identify, repair and/or remove old stoves is to ensure that local energy audits and weatherization programs have integrated wood stoves into their work.  Most energy auditors still do not have the training or the software to do undertake stove inspections, even though DOE and state regulations claim to require that all heaters are inspected.  If they did, they would find many self-installed stoves that are dangerous, higher polluting and in need of replacement or removal.  LIHEAP funding and low-income weatherization programs will cover these costs where the stove is the primary heat source.  If the stove is a secondary heater, these programs could cover repairs.  Few states have demanded that the US Department of Energy develop standards for inspecting wood stoves, like there are for boilers and furnaces, and the DOE is still hesitant to take this on, even though it would have a major impact for lower-income households across the country.  We urge CARB to review how wood stoves are inspected during energy audits and weatherization programs in California and see whether they are being repaired, replaced or removed.

4.     GHG reductions 

We are pleased that CARB is no longer using carbon to justify switching from a wood stove to a gas stove.  In its 2016-2017 Woodsmoke Reduction Program Guidelines, CARB stated, ”Switching from an uncertified wood stove to a natural gas or electric heating device reduces GHG emissions.”  We find this statement to be without scientific basis.  We understand that the GHG calculations are not central to how CARB runs this change-out program, but we want to open a conversation about it.  

In the current Program Guidelines, CARB seems to assert that 100% of carbon released from wood and pellets should be attributed to this form of heating.  The Guidelines say that “biogenic CO2 is included in the calculation of GHG benefits for these devices.”  We agree that some biogenic carbon should be included, as some carbon can be attributed to all energy sources.

To make scientific estimates of carbon released from firewood that would not have been released anyway, there is a lot of data that can be considered.  For CARB to start to gain a basic understanding of the carbon cycles from firewood, you could also ask on your change-out application, “where do you get your wood?”.  A researcher can also get data from a sampling of California firewood dealers and households who use firewood. 

By not engaging in basic research, CARB is putting the burden on low-income households who heat with wood and is inferring their carbon impact of their heating is far higher than it is. This flies in the face of current thinking about energy justice that seeks to remediate social, economic, and health burdens on those disproportionately harmed by the energy system. 

Estimating carbon from gas, oil and electricity involves a complex set of assumptions and calculations and there is no reason that similar effort could be made to assess the carbon cycle from firewood.

In California, as in the rest of the country, it is likely that a substantial number of homes who heat with wood acquire their firewood in a very responsible way by using dead and downed wood, as lower-income households do around the rest of the country.  A lot of firewood used for home heating could otherwise end up in the landfill where it would produce worse GHG emissions.  

The Minnesota Residential Wood Combustion Survey Results, (May 2019) done by the Minnesota Department of Natural Resources is one of the most definitive studies on firewood procurement and use.  The report says, “Most of the wood cut (84%) by residential households comes from dead or downed trees, land clearing, and logging residues (Table 15). Approximately 9.3% comes from live standing trees in the forest.”  This is a crucial statistic for understanding carbon impacts of firewood.  If 84% of wood cut by households comes from dead of downed trees, it means that carbon was already in the process of being released unlike when a live tree is cut.  

Household income generally correlates to how firewood is procured and how much firewood is used.  The lower the income of a household, the more wood they use and the more likely they gather their own wood, assuming wood is being used for heating, and not for recreation.  More urban and higher income families are more likely to purchase wood. The chart below is based on EIA data.

The Minnesota Residential Wood Combustion Survey Results, found that 60% of firewood is cut by households and 40% is purchased.

 

Table 15, below, provides further detail of where firewood comes from in Minnesota, and these trends are likely to exist in other states. 

Table 17 shows a breakdown of firewood from both household and loggers.  Even where firewood is provided by commercial loggers, most of it is still from trees that are dead, down or from the residues of a commercial harvest, which usually is for sawlogs (lumber).

In conclusion, we believe that whether firewood comes from a “locally or nationally approved” forestry plan is not as relevant as existing data about where firewood comes, how sustainable it is and how to understand carbon implications. From a carbon perspective, we believe a rigorous look at the carbon footprint across the value chain of gas production and usage will always be higher than the footprint of firewood, across its value chain. The Achilles heel of firewood is the excessive PM that comes from most wood stoves, and it is that PM which fully justifies change out programs like this one.

As we initially stated, we fully support this program and see it is improving over the years, and we hope that our comments help improve it in future years.  Thank you for undertaking the program and accepting comments from the public. 

Sincerely, 

John Ackerly

President

Further reading: State Parks give downed trees to public for firewood (March 2023)

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)

Massachusetts first in recognizing efficiency and automation in wood stove program

Updated, April 12, 2019: Massachusetts has developed the first wood stove change out program in the country that recognizes the value of automated stoves and stoves that disclose their verified efficiency to consumers.  The program details, updated in April 2019, offers Massachusetts residents between $500 and $3,250 for upgrades, depending on the stove and income level of the family.

The Commonwealth Woodstove Change-Out Program has committed $1.8 million in funding for change-outs from 2017 through 2019. The 2017 program represents the sixth round of funding since the program's launch in 2012. The program has helped more than 1,400 residents swap out their non-EPA certified, inefficient stoves for newer, cleaner models, and approximately 500 of these rebates went to residents earning less than 80 percent of the state median income.

The program is like scores of others across the country, but Massachusetts is the first to give an additional rebate of $500 for pellet stoves and $250 for wood stoves that are above 65% efficient (actual tested efficiency reported to the EPA). Most manufacturers do not disclose the actual efficiency of their stoves but provide exaggerated, misleading efficiency values on their websites.

The program is run the by Massachusetts Clean Energy Center (MassCEC) in coordination with the Massachusetts Department of Energy Resources (DOER).  It is also the first program that gives an additional rebate for stoves that have automated features and control the airflow with sensors or other devices, providing a cleaner burn for the consumer. 

Most stoves are eligible for a $500 - $1,250 rebate depending on how clean they are, but four automated stoves qualify for a $1,500 rebate, or a $2,750 rebate for income-qualified families.  Three of the four automated stoves also qualify for an additional $250 that have efficiencies above 65% that are verified by the EPA.

The additional rebate for automated stoves may only come to $250 or $500, but the recognition of this new class of stoves is a significant step for the stove industry.  These stoves are more known in Europe, but in the US, the terminology, rationale and classification of automated stoves is still in its infancy. 

The Mass program may be a sign of how change-out programs can adapt to changing wood stove technology.  Automated stoves help achieve one of the biggest challenges stoves face: how to get stoves to perform as well in the home as they did in the lab.  The Mass program explains, “The low emission and high efficiency lab test ratings are more likely to be realized in households because user error is minimized.” 

One of the next huge steps for wood stoves is to have them designed and tested with cord wood instead of 2x4s and 4x4s, the fuel they are designed for and tested with today.  In the next 2 or 3 years, change-out programs are likely to also start awarding additional rebates for stoves made by manufacturers willing to start designing and testing with cord wood, something that the new EPA stove regulations are making possible.

Stove eligibility

The EPA requires all stoves to emit 4.5 grams of particulate matter per hour or less, but the Mass program only allows stoves that emit under 3.5 grams.  The list of stoves eligible in Mass is 24 pages long and explains their rebate eligibility.  The Maine, Maryland, and New York programs also require lower gram per hour limits than the EPA.

The MassCEC does not allow gas stoves to participate in the program because Massachusetts statute prohibits them from providing incentives to fossil fuel use, said Peter McPhee, Renewable Thermal Program Director at the MassCEC.

Non-catalytic stoves: The Mass program is more aggressive than any other change-out program in providing bigger incentives for cleaner wood stoves.  They offer $500 for non-cat stoves that emit 3 – 3.5 grams per hour, $1,000 for stoves from 2 – to less than 3 grams per hour and $1,250 for stoves that emit less than 2 grams per hour.  Of the 309 non-cat stoves on the market today, 166 are eligible for some level of rebate because they emit 3.5 grams per hour or less.

Catalytic stoves: To be eligible, a catalytic stove must emit 2 grams per hour or less.  Of the 67 cat stoves on the market, 27 are under 2 grams and eligible.  Catalytic stoves under 2 grams get a $1,000 rebate, $250 less than a non-cat stove that is under 2 grams.

Pellet stoves: Like catalytic stoves, pellet stoves must emit 2 grams per hour or less, and are eligible for $1,250 (plus an additional $500 for an efficiency bonus, if they have a verified efficiency.)  Of the 115 pellet stoves on the market, 81 are eligible as they emit 2 grams an hour or less.  Providing similar rebates for wood and pellet stoves is increasingly rare as most change-out programs give 50 – 100% higher rebates for pellet stoves, compared to wood stoves.  Nationally, the median rebate for a wood stove is $600 for wood stoves and $1,000 for pellet stoves.

Automated stoves: Four stoves qualify as automated under this program: The Quadra Fire Adventure II and Adventure III, the MF Fire Catalyst and the RSF Delta Fusion.   All of these stoves break new ground in operating cleanly while drastically reducing the margin of human error, which is considerable. More European or American automated models are likely to come onto the market in coming years.

 Efficiency

A number of states are trying to include efficiency in their change-out programs, but Mass is the first to do so.  The underlying problem is that before 2015, stoves were not required to disclose their efficiency.  Today, only a quarter of wood stoves on the market disclose their actual, verified efficiency.  Stoves certified since May 2015 are required to test for and disclose their efficiency.  Some companies have taken the extra step and voluntarily disclosed their actual efficiencies and do not exaggerate their numbers on promotional materials.

If a program only gave rebates to stoves with verified efficiencies, the consumer would only have 125 out of 500 stoves to choose from.  So, Mass chose not to make efficiency disclosure a requirement, but gives a $250 or $500 bonus for stoves that meet a minimum efficiency of at least 65%, well under the average stove efficiency which is around 70%.  This will likely drive sales towards manufacturers who disclose their efficiencies and will also educate consumers about the importance of selecting highly efficient wood and pellet stoves.  An additional $500 is significant.  More manufacturers may start to disclose their efficiencies to be eligible for higher rebates as other states begin to recognize efficiency as Mass did. 

Of the 38 pellet stoves that disclose actual efficiencies, four are not eligible for the change-out program as they emit more than 2 grams an hour, and 3 are not eligible for the $500 efficiency adder as they are less than 65% efficient.  This leaves 31 pellet stoves eligible for the $250 adder.

Of the 23 catalytic stoves with verified efficiencies, four are not eligible as they exceed 2 grams per hour and one of those four is under 65% efficient, leaving 19 eligible for the $500 adder. 

Of the 66 non-cat stoves with verified efficiencies, 17 exceed 3.5 grams and are not eligible for the program.  Two others are not eligible for the $250 adder as they are under 65% efficient.  This leaves 37 stoves eligible for the $250 efficiency adder.

Participating retailers

Residents must have the new stove installed by a Participating Stove Professional who follows the guidelines of the program, which includes ensuring the old, uncertified wood stove is destroyed.  There are currently 32 participating stove retailers, four of which are outside of Massachusetts and three of which are chimney sweep businesses.  However, MassCEC says that they expect a total of 40 – 50 in coming weeks. They are likely to be NFI or CSIA accredited, but are not required to be.  Residents are encouraged to find installers who are. 

Programs that require residents to work with participating retailers can effectively limit the range of stove models that they can buy.  Retailers like to install stoves that they sell, so they can make profit on both the sale and the install.  But some eligible stoves available at Home Depot can offer real bargains particularly for lower income families.  Some participating retailers or chimney sweeps may install stoves purchased elsewhere by consumers, but some may decline to do so.  Many eligible wood and pellet stoves are made by small companies and a few are made by companies that sell direct to consumers. They may have a harder time participating in this change out-program.

The rebate is provided to the participating retailer, not to the homeowner, which is common in change-out programs.  This enables the consumer to get the discount immediately at time of payment.  Participating retailers must promise not increase the price of stoves or installations for customers using the program.  And MassCEC promises to pay the rebate to the Stove Professional within thirty (30) days.

Income qualified

Another notable feature of the MassCEC program is its generous rebate levels for families that are well above the poverty line, but below the median income of Massachusetts families.  Families are eligible for the higher rebate amounts if they earn 80% of the median income that is $87,000 for a family of four and $59,000 for a family of two. 

“We wanted to be able to drive benefits towards more people who really need assistance in the up-front capital costs,” said Peter McPhee from MassCEC. 

Incomes are much higher in the Boston urban area than in the rest of the more rural state, so a majority of families will be eligible for the higher rebates in more rural areas where demand for wood and pellet heat is highest.  In the western Mass county of Berkshire, the median family income is about $50,000.  Total project costs are estimated to be an average of $3,000 to $4,300.  Income eligible families receive between $1,500 and $3,000, or 40% to 100% of project costs. 

MassCEC has held change-out programs for the past five years and pending funding, may hold more in the coming years.  The program has $1.8 million in funding for 2017 through 2019.  Program managers are not only aware of changing technology in wood stoves but also the changing policy landscape.  The EPA’s emission standards are under attack from the Republican right-wing in Congress and the main stove industry association is suing the EPA over them.  The MassCEC program manual hints that they will continue with the emission standards developed under the Obama Administration: “Should NSPS requirements be modified in the future, MassCEC will likely retain these future emissions level requirements.”