Wood smoke in low-income communities is an environmental justice challenge for the EPA

The Alliance for Green Heat, along with eight firewood banks across the nation that support the comment, submitted a response to the EPA's Request for Information on the Environmental and Climate Justice Block Grant Program (ECJ Program). This was a great opportunity to practice viewing wood heating through an environmental justice lens. Below is the submitted comment.

"Re: Environmental and Climate Justice Block Grant Program - Request for Information (Docket No. EPA-HQ-OEJECR-2023-0023)

Summary 

The Environmental and Climate Justice Block Grant (ECJ) program presents an opportunity to address marginalized communities who primarily heat with wood and experience excessive wood smoke that is a health hazard. The EPA has neglected wood heating technology and wood heating regulations, contributing to thousands of communities living with excessive indoor and outdoor wood smoke.  

Wood heating communities include many tribes and also rural areas in the colder parts of the United States that have always relied on wood heat. The technology has stagnated, in part due to lack of attention by the EPA and DOE, who appear to regard wood stoves as an antiquated appliance relied on by poor households, and not worthy of development.  A recent report from the EPA’s Office of Inspector General found that the EPA wood stove certification program is broken, leaving consumers vulnerable to stoves that may have higher emissions than they should (EPA OIG, 2023).  For decades, under administrations of both parties, the EPA’s wood heater certification program has been underfunded and understaffed, jeopardizing those communities that rely most on wood heat, which include many of the poorest rural populations.   

The OIG report recognized the environmental justice issue in poor communities that primarily heat with wood, but it used data that obscures the extent of the problem. The EPA looked at all households, including urban ones, rather than focusing on income levels of rural homes that use wood. A very flawed study commissioned by the EPA in 2010 found that “the average risk from residential wood smoke is lower for people living on Tribal Lands than for the general population,” (Analysis of Exposure to Residential Wood Combustion Emissions for Different Socio-Economic Groups, 2010). Thus, the final 2015 NSPS, the updated wood stove regulations, found that there were no “disproportionately high and adverse human health or environmental effects on any population, including any minority, low-income or indigenous population,” (EPA, 2015).

As our country electrifies and looks to the heat pump to decarbonize heating, wood stoves will likely remain popular for some time or even increase in popularity. In rural areas, power outages are becoming more, not less common, and people are wary of relying solely on electric heat. In addition, for millions of households wood is a free fuel and despite the efficiency of a heat pump, wood will always be cheaper than electricity. There still does not appear to be the political will at the EPA to address the needs of LMI communities that rely on wood to heat their homes.  

We urge the EPA to consider funding programs that:

1. Change out old wood stoves for heat pumps or newer wood stoves, depending on the needs of LMI households.

2. Support Firewood Banks that help LMI households get seasoned wood, energy audits, repairs for dangerous wood stoves and ultimately trade up to cleaner heaters.

3. Explore the development of affordable, computerized wood stoves that drastically reduce PM and give households the chance to heat with a renewable without excessive air pollution.

4. Provide training to do health and safety inspections of wood stoves during energy audits. Currently, energy audits programs for LMI households are not equitable in inspecting wood stoves, as they do for fossil fuel heaters which are typically found in wealthier homes.  Wood heaters should not be treated as a second-class appliance. 

By funding such projects, the ECJ program will help achieve Justice40 Initiative objectives by investing in cleaner, renewable heating in rural, firewood dependent LMI communities.  

Comment addressing item (2) types of actions related to President Biden’s Justice40 Initiative

We recommend that the Environmental and Climate Justice Block Grant program consider how best to support the fuel poverty and resilience of wood heating populations due to their rural geographic location and socioeconomic status. 

Lower-income households rely on wood heating more than higher-income households (Figure 1). The reasons for this range from accessibility to affordability. In our work, we hear stories of burning kitchen cabinets as a last resort for heating a home. Stories of elder community members making the choice of whether they should pay for heat, pay for their prescriptions, or pay for groceries is not uncommon. 

Figure 1. Data from 2015 OIG analysis of U.S. Energy Information Administration data. 

The average household income of homes using wood as a primary heat source is $76,490, the second lowest of any heating category (above homes that lack a primary heat source and just below homes that use electric heating) (Figure 2). 

	No. of Homes	Average Household Income
Utility Gas	58,643,017	$102,942
Propane	5,961,261	$89,662
Electricity	48,468,896	$77,460
Fuel Oil	5,426,218	$102,019
Coal	111,521	$80,480
Wood	2,022,868	$76,490
Solar	255,514	$141,873
Other	575,782	$85,732
None	1,337,827	$74,136

Figure 2. ACS 1-Year Estimates-Public Use Microdata Sample. Average of US household income in past 12 months.

Energy production and distribution have created archetypal cases of environmental injustice—

mountaintop removal for coal mining in Appalachia, nuclear waste siting on Navajo reservations in the West, oil refineries in southern Louisiana. Another example is the incredibly high percentage of homes that still heat with wood in poor rural areas that have not yet become part of the fossil fuel age. Areas where the majority population identifies as Native American, particularly in the Southwest, are likely to either heat primarily with wood or find it as the second most popular heating fuel in the area. This further makes the case that regulating and supporting wood stove households is an environmental justice issue. For example, in Apache County, Arizona, nearly 54% of homes are heated with wood (U.S. Census Bureau, 2021) with 71% of people identifying as Native American (U.S. Census Bureau, 2020). In McKinley County, New Mexico, a similar story. Around 44% of homes heat with wood (U.S Census Bureau, 2021) and 78% of people identify as Native American (U.S. Census Bureau, 2020). In San Juan County, Utah, about 38% of homes are heated with wood (U.S. Census Bureau, 2021) as 50% of the population identify as Native American (U.S. Census Bureau, 2020). These are not the only examples that represent the important role wood heating plays in Native American populations. Acknowledging that wood is used for primary heating by only 1.4% of homes nationally, this is a staggering rate of wood burners for a certain population and one that should not be overlooked when discussing funding to rectify environmental injustice (U.S. Census Bureau, 2021). The map below illustrates the concentration of wood fuel users by highlighting the often rural geography of their location as well as the prevalence of wood fuel on Southwest reservations. 

Muyskens et al. 2023. “U.S. home heating is fractured in surprising ways: Look up your neighborhood.” Washington Post. https://www.washingtonpost.com/climate-environment/interactive/2023/home-electrification-heat-pumps-gas-furnace/?itid=hp_desktop-dont-miss_p005_f002.  

Considering that there is legitimate concern over the capacity of our energy grid to handle increasingly harsh climate change-driven natural disasters (Climate Reality Project, 2022), wood stoves may help in some areas during the transition to electricity. Making sure wood stoves are safe to use in LMI households should be paramount. Maintaining realistic expectations for the performance of our energy grid, given that U.S. households experienced more electric disruptions in 2021 than the previous high level of disruptions in 2020 (U.S. Energy Information Administration, 2021), would ensure more energy resilient communities. In this way, wood stoves could play an empowering role for households that fear electric disruptions as well as the increasing costs (U.S. Energy Information Administration, 2023), and environmental concerns of natural gas (Jordan, 2022). 

Proper wood stove inspections, referrals for possible wood stove change-outs, and heat pump installation consultations when wood heat does not best serve a household anymore are needed. Multiple firewood banks that we have worked with have expressed interest in offering these services if they could secure funding to train volunteers to properly inspect and then facilitate the next steps to address the household’s needs. Firewood banks have an intimate view and partnership with fuel-poor households and are in a unique position to facilitate a more energy-equitable outcome. Because socioeconomic status and geography play such an intricate role in identifying environmental injustices, a mechanism to support firewood banks to provide these services would be of great help.

Providing households who struggle to keep their families warm with an emergency fuel source is one thing but ensuring that these families are using this fuel source in a safe wood stove appliance is another. We suggest that the ECJ grant funds programs address the reduction of indoor and outdoor air pollution, the prevention of house fires, and the repair or removal of wood stoves."

Signed By

Alliance for Green Heat  Takoma Park, MD Koho4Hopi  Second Mesa, AZ Pikunivi Wood Haulers Second Mesa, AZ Oglala Lakota Cultural & Economic  Revitalization Initiative (OLCERI)  Pine Ridge, SD Kootznoowoo, Inc.  on behalf of the village of Angoon, AK

Cullowhee UMC Project F.I.R.E. Cullowhee, NC Petersham Community Wood Bank Petersham, MA Rural Organizing and Resilience Marshall, NC St. Michael & All Angels Episcopal Church Wood Bank Eureka, MT

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)

Wood stove inclusive energy audit standards still missing in America

By John Ackerly and Caroline Solomon 

The DOE's weatherization program for
low income households is the largest 
weatherization in the US

In 1988, when wood stoves were at the height of their popularity in the U.S., the Department of Energy issued a memo clarifying that wood stoves in DOE-funded energy audits and weatherization programs should be included and could be replaced.  But, they also said that “DOE considers wood stoves to be a unique measure… and …  it is the energy audit which is the driving force for determining whether a wood stove should be replaced.”

 

This was a victory for the many states that wanted to use DOE funding to repair and possibly replace old wood stoves that pose health, safety, and environmental risks. However, fast forward to today – 33 years later – and wood stoves remain a “unique measure” and are often overlooked in DOE funded energy audits. Nearly 10 million homes have been audited and weatherized with DOE funding and all homes with gas furnaces, for example, had those furnaces inspected for safety – and efficiency.  But there is no consistency or uniformity for how a stove should be inspected or when it and how it should be repaired or replaced.  To understand how and when the breakdown happened, we went back in time and dug into countless documents, reports, and energy audit standards. Here’s what we found out.

 

In 2012, we wrote a blog about how energy audits were routinely overlooking wood stoves, many of which were unsafe, dirty, and hazardous. At that time, many auditing standards, including those approved by the Department of Energy’s Weatherization Assistance Program (WAP), did not contain guidelines for how energy auditors should inspect wood stoves while in a home.

 

In 2013, AGH worked with the Building Performance Institute (BPI), who developed long-overdue standards on safety inspections for wood stoves. But the standards were voluntary, and eight years later, we found that virtually no one is using them, and most energy audit companies don’t even know they exist. AGH continued to work with EPA staff, who were also eager to see stoves consistently included in energy audits, but our impact was minimal.

 

In the summer of 2021, AGH turned again to the DOE, who runs the nation’s largest auditing programs through their Weatherization Assistance Program (WAP). Senior WAP officials were very accessible and open to discussing the issue, and pointed to their regulatory language, which dictates that “all heating systems, regardless of type” be inspected, repaired if necessary, and even replaced under some circumstances. DOE has to approve each of the audit programs used with their funding. So far, so good.

 

Things began to unravel when we dug into hundreds of documents, from national audit program notices to state weatherization plans to work specification field guides to local application forms and field data collection forms. The problem is not that wood stoves are excluded, but that very few states have any detail about how to inspect a wood stove. Usually, documents from the DOE all the way down to a county audit program have all of the details about inspecting, repairing, and reporting on a gas furnace, for example. Boilers are often well-described, but details dry up very quickly when it comes to wood stoves. The result is a patchwork of state programs, with some meeting DOE regulations, and others falling far short.

 

The problem also involves national auditing tools, approved by DOE.  NEAT is the most popular energy audit tool and is used in about 35 states.  It addresses wood stoves in its Health & Safety audit mainly as an indoor smoke issue.  It references inadequate floor protection and oversizing but does not mention clearance to combustibles or cracks in the firebox or glass.  Adding to the issue is that DOE published Standards for Conformance that includes a lengthy list of “tune-ups/efficiency improvements” for furnaces and boilers, but not even one for wood stoves.

 

Far from being a unusual heating device, wood stove
are more common that many other heaters in the US

If wood stoves were just a tiny fraction of heaters, like coal stoves are, overlooking them would make more sense.  But there are more wood stoves in America than there are oil boilers, oil furnaces or propane furnaces, and almost as many as gas boilers.  Some states, like Maine, New Hampshire and Wisconsin have provided extensive guidance around wood and pellet stoves.  Oddly, Oregon, a state with far more problems with wood smoke, has little guidance, resulting in fewer inspections, repairs and replacements of old wood stoves.

 

One distinct feature of wood stoves makes them particularly in need of safety check-ups: unlike other heating systems, many if not most wood stoves are homeowner-installed, and these stoves are often not up to code.

 

AGH is now midstream in our effort to work with DOE officials, DOE contractors, state officials, and others to get feedback on how to correct this problem. One DOE contractor who is deeply involved in the matter says she thinks we can begin making substantive changes quickly, but systemic problems like this, take years to address. 

 

We are currently preparing a report that (1) assesses audit programs approved by the DOE, (2) assesses state Standard Work Specification guides and (3) Assesses how local WAP programs collect information about heating systems. Stay tuned for more in-depth coverage of this issue.

 

We expect our report will be extremely helpful to the DOE who could update guidance to ensure a minimum level of stove inspections to establish more uniformity how stoves are inspected and what repairs should be considered.  The report should also be helpful for states that want to address the safety and performance of old wood stoves.

 

We want to thank the scores of people who have helped address this problem, starting with folks at BPI who worked on it back in 2012 and 2013, to all the federal, state, and local WAP officials we interviewed this summer.

 

And thanks to all our supporters who provided data about how and whether their stove was included in their energy audits. If you have had an audit recently, please share the results with us (info@forgreenheat.org).

 

John Ackerly is President of the Alliance for Green Heat and Caroline Solomon is an AGH fellow.

Best Practices in Wood and Pellet Stove Incentive Programs

A report prepared for the University of Maryland Extension Woodland Stewardship Education program

By John Ackerly & Melissa Bollman

Alliance for Green Heat

2016 update: A new set of best practices for wood stove change-out programs is now available here. Many of them overlap with best practices for incentive programs.

October, 2014 - As more and more states are beginning to provide incentives for modern wood and pellet stove installations, an array of criteria are being used to guide which stoves should be eligible and what other requirements should be included. This report looks at environmental, economic, energy efficiency, social equity, and consumer values and suggests ways to maximize program impact.

The federal wood and pellet stove incentive program that lasted from 2009 to 2013 is widely regarded as a particularly poor model. It allowed consumers to claim a $300 tax credit for the purchase of any new wood or pellet stove provided it was EPA certified (non-exempt) and at least 75% energy efficient. The energy efficiency requirement was quickly rendered meaningless as stove manufacturers were allowed to self-rate efficiency using any number of available methods. The EPA certification requirement, while it eliminated the highest polluting and most inefficient stoves, was similarly not sufficient for ensuring the best available technology was appropriately incentivized. Also, the federal program did not take important criteria such as professional installation and location into consideration. Thus, a new stove that emitted 5.5 grams of fine particulate matter (PM2.5) emissions per hour could be self-installed in a densely populated urban area and still be entitled to the tax credit.

A table summarizing all statewide incentive programs can be found at the end of this essay. Click here to download a pdf version of the report.

Summary of recommendations:

At a minimum, we believe programs should only incentivize wood and pellet stoves that are certified by the Environmental Protection Agency (EPA) and meet a stricter emission limit than the EPA’s minimum requirement. Energy efficiency is another important criterion that should be considered in stove incentive programs, although lack of reliable, independent data makes accounting for efficiency too difficult as of Fall 2014. To ensure new wood and pellet stoves work as cleanly and efficiently as they are designed, and to protect consumer safety and minimize the risk of fire, incentive programs should require subsidized stoves to be installed by certified hearth professionals. To ensure taxpayer funds for new stoves are spent in an efficient way and limit the negative environmental effects of wood smoke in urban areas, we recommend that new installs of wood stoves should be limited to rural areas, or that programs only make pellet stoves eligible for incentives. We also recommend that programs better target low- and middle-income residents.

There are several examples of state stove incentive programs that contain innovative and “best practice” features, but all programs have opportunities for improvement. We hope this report provides a resource for all programs.

1. Certification of equipment

Wood Stoves

Limiting the eligibility of wood stoves to EPA certified models is a basic feature of stove incentive programs.  The federal tax credit did not mention EPA certification, as it was supposed to be primarily an efficiency incentive.  Several unregulated boilers claimed to be eligible, but we are not aware of any uncertified stoves that claimed the credit.

The EPA provides a list of certified wood stoves available for download on its website with other useful information such as the stove manufacturer’s name, model name, emission rate, heat output in BTU per hour, and estimated or actual tested efficiency. Wood stoves certified by the EPA are independently tested to ensure they meet a particulate emissions threshold, which currently is 7.5 grams per hour for non-catalytic wood stoves and 4.1 grams per hour for catalytic wood stoves. Consumers can identify EPA certified wood stoves through a label affixed to the back or side of a stove as well as a hangtag, pictured below.

         EPA began certifying Phase II stoves in 1990, so some certified stoves are nearly 25 years old and need to be retired almost as much as some uncertified ones need to be. Stoves certified in the past 5 years are considered much cleaner and more effective than older, certified stoves.

Pellet stoves

            Pellet stoves are generally perceived to be cleaner and more efficient than wood stoves as a class, and few stove incentive programs have restricted pellet stove eligibility to those certified by the EPA. However, independent test data shows that this widely held belief about pellet stove efficiency may be incorrect. Some pellet stoves on the market are as low as 40% efficient, and many are in the 50% and 60% range, when they easily can be in the 70s given available technologies. We believe that households should not be subsidized into unwittingly buying a low-efficiency pellet stove that will saddle them with much higher fuel costs overtime. The list of EPA certified pellet stoves can be found on the same list as certified wood stoves. EPA certified pellet stoves are usually more efficient than their uncertified (exempt) counterparts because exempt pellet stoves often use the 35 to 1 air to fuel ratio loophole to avoid certification, at the cost of lower efficiency.

This issue will be obsolete at some point in 2015, when all new pellet stoves will be required to be certified under new EPA stove regulations.

Masonry heaters

Masonry heaters are such an expensive, niche product that they almost do not need discussion in these programs.  However, we encourage programs to make certain masonry heaters eligible, even though they are not certified. The EPA is currently considering a method to certify masonry heaters that may be released in the next year. In the meantime, Washington and Colorado maintain their own lists of certified masonry heaters approved for sale. These lists can be a useful reference for designing new stove incentive programs inclusive of masonry heaters. Colorado does not set a specific emissions limit, but maintains a list of over 30 approved masonry heaters by manufacturer. Washington sets an emissions limit of 7.3 grams per kilogram of masonry mass, which may be more useful to policymakers creating incentive programs. Washington may be setting the bar low, considering that the EPA has proposed a limit equivalent to 1.8 g/kg for future regulations.

2. Stricter emission limits

            While stove incentive programs in Montana, Idaho, and Arizona use EPA limits to set emissions criteria, several other stove incentive programs set stricter emission limits for eligible appliances than the EPA’s 7.5 and 4.1 grams per hour for non-catalytic and catalytic stoves. Setting stricter emission limits for wood stoves can help identify which stoves can perform best under optimal conditions. Some of the cleanest stoves by EPA emission standards may perform better in the real world. Equally important is using dry fuel and operating the stove correctly to obtain good real world performance. Pellet stoves, which operate in the field much more like they do in the testing lab as compared to wood stoves, should be held to 2 grams per hour, as in Maryland and New York’s program, or 2.5 grams per hour at the most, as in Oregon, Maine and the federal Housing and Urban Development (HUD)’s PowerSaver low interest loan programs.

The state of Washington has been a leader in establishing stricter state-wide limits. Currently they are 4.5 grams per hour for non-catalytic stoves and 2.5 grams per hour for catalytic stoves. Washington’s list of approved wood heating technologies, including masonry stoves, provides an easy standard policy makers can build into incentive regulations.

A state of Oregon incentive program requires stricter limits of 3.5 grams per hour for non-catalytic stoves and 2.5 grams per hour for pellet and catalytic stoves, which was adopted by Efficiency Maine’s stove incentive program. To take it a step farther, Maryland’s current limits are 3 grams per hour for wood stoves and 2 grams for pellet stoves. As the EPA continues to refine its certification criteria, we suggest that stove incentive programs adopt Maryland’s approach of limiting the eligibility of incentives to a certain grams per hour cutoff according to the data on the EPA’s certified stove list.

The argument against using stricter emission limits for wood stoves has some merit, but on the whole we and many other independent experts think it’s worthwhile.  It’s true that the test labs often know exactly how to test a stove, and can hit the stove’s sweet spots to get a low number of emissions that a consumer never will. Manufacturers that hire a test lab to do R&D on a stove before testing it may be likely to get even better numbers, because the lab is that much more familiar with the stove. The new EPA stove regulations are changing the test protocol, which may require stoves to burn cleaner on all test runs instead of averaging the test runs.  This could give emission numbers more relevance in the real world.

3. Efficiency

There is still no easy way to use efficiency in stove incentive programs, and as a result stoves are excluded from scores of state, local and utility incentive programs that are rooted in energy efficiency. Despite the benefits of having them included in incentive programs, industry has been reluctant to disclose efficiency numbers, much less agree to schemes where some stoves would get incentivized and other not.    

Pellet stoves are ideally suited to be part of many energy efficiency incentive programs, if they would release their tested efficiency values. Their continued exclusion may contribute to the perception that this technology does not fit into the mainstream energy efficiency movement, or worse, that it is not “green” enough to be included. Since one company, Hearth & Home Technologies, makes a very large percentage of the pellet stoves sold in the US, including many very efficient ones, they could significantly move the market by taking leadership and disclosing their actual, tested efficiency numbers.

Efficiency has become a thoroughly muddled, confusing, and controversial issue as they are several ways of measuring efficiency and results can be misleading. One of the greatest problems with this approach is the lack of third party tested efficiency data. The EPA list has verified efficiency data for only about two dozen units comprising mostly of the highest performing catalytic stoves. By only using stoves that have actual third party efficiency listing, a program would be basically limiting the selection to one non-catalytic Jøtul stove and a variety of large catalytic stoves. Only one pellet stove company, Seraph, has provided real efficiency data to the EPA thus far.  

Setting efficiency as an eligibility requirement would help encourage manufacturers to provide third party efficiency data to the EPA, which most have been reluctant to do in the past. The proposed new EPA stove regulations will require all stoves to be tested and listed for efficiency, but there is widespread concern that the EPA will not require, or even have the capacity to make, efficiencies available to the public within the first year or two after promulgation.

            The State of Oregon’s residential energy tax credit for wood and pellet stoves is the only one that has put the effort into a workable and innovative system to incentivize the purchase of more efficient stoves without excluding inefficient stoves from eligibility. The more efficient the new stove is, the higher the tax credit the consumer receives. If the stove does not have an actual measured efficiency on the EPA list, the amount of the credit varies by stove type. Non-catalytic stoves are worth the least credit, catalytic stoves the second least, and pellet stoves the most. If the stove has an actual reported efficiency, then the consumer receives a tax credit based on how much more efficient the stove is than the minimum Oregon has established. The maximum rebate is $1,500.

 Both Massachusetts and Maine have attempted to use stove efficiency as an eligibility metric but the metrics were not clear or feasible and it had to be dropped.

A local utility program in Fort Collins, Colorado offers homeowners zero-interest loans if they upgrade their wood burning appliance or fireplace to a more efficient class of heater, according to the default efficiencies provided by the EPA. For example, homeowners can upgrade an uncertified stove to a certified stove, or a wood stove to a new pellet stove, but not the other way around. This unique method of incentivizing the purchase of more efficient wood appliances has the potential to help consumers save money, but only if the EPA provided more accurate efficient data on pellet stoves. 

We find it is a good practice to include efficiency in the criteria, but we must acknowledge that the managers of these programs are struggling with some unintended barriers and consequences. Oregon is fixing one problem, which had led the tax credit calculation to favor non-catalytic stoves over the cleaner catalytic or pellet stoves. This put the agency in charge of the program, the Oregon Department of Energy, at odds with the Oregon Department of Environmental Quality. The Oregon tax credit amount is based on the efficiency improvement over the EPA’s default efficiency. So a non-cat tested at 70% would have a 7% improvement over the 63% default. A pellet stove tested at 75% would not have any improvement over the 78% EPA default efficiency. The program thus unintentionally puts pellet stoves at a disadvantage because the EPA has set unrealistically high default efficiency for pellet stoves.

4. Rebate amounts

Providing a higher rebate amount for pellet stoves than wood stoves is another common “best practice.” Maryland provides $700 for pellet stoves and $500 for wood stoves, steering households who may be on the fence towards a pellet appliance, which will be cleaner. With lower install costs for pellet stoves, the higher rebate may also be a reason more than 70% of consumers use the rebate for pellet stoves in Maryland. 

Right-sizing the rebate amount is also something that all programs must grapple with.  Funding that goes too quickly, or not quickly enough can sometimes cause problems. One money saving incentive that more jurisdictions are employing is bounty, or paying consumers $200-$400 to remove an old stove from circulation without replacing it with anything. For areas with excessive wood smoke pollution, this may be a far more effective per dollar of investment than a change out program.

5. Professional Installation

Requiring professional installation is standard for virtually all incentive programs. Wood and pellet stoves are potentially dangerous appliances and must be installed with the utmost concern for safety. Hundreds of homes burn down every year due to poor installations and lack of attention to clearances.

 Homeowners seeking to avoid the added cost of a stove installation are often tempted to self-install. In some cases, installation can be greater than the cost of a stove itself. State codes vary about permits and installation requirements for wood stoves, so state incentive programs that require professional installation can play a large role in helping to address this safety issue. Pellet stoves, which do not require a full chimney system, tend to entail less problematic, unsafe installs. However, with any appliance that presents a fire hazard, a professional installation by a hearth professional is a good practice.  

Options for incentive programs include requiring that stoves be installed by hearth professionals that have Chimney Safety Institute of America (CSIA) http://www.csia.org or National Fireplace Institute (NFI) http://www.nficertified.org certifications. Another option is simply to require a certified contractor, or someone who has been approved to do specialty energy efficiency or weatherization work, install the stove. An added benefit of requiring hearth professional stove installation is that CSIA, NFI, and MHA would also be more likely to help advertise the incentive program if they are involved.

Most current state incentive programs, if they require professional installation at all, do not limit the eligible installers to hearth professionals. For example, Maine’s program initially required stoves to be installed by contractors with a solid fuel license, but did not provide for hearth professionals to do installations. In New York, a Energy Star professional is required.

Maryland’s program also initially required professional installation, but later waived the requirement after receiving a number of consumer complaints. Maryland began accepting self-installations provided that the owners provided documentation that the stove has been inspected post-install by either a county inspector or an insurance adjuster. While we believe requiring professional installation is the best practice, requiring inspection at a minimum can be a good compromise.

6. Low-income considerations

Some incentive programs offer higher rebate amounts to low-income families. This tends to be very common in change-out programs, and less common in non-trade out incentive programs. In New York, however, change-out of an old one stove is required to receive a rebate for a new one, unless the household is low-income, when the rebate is offered without a change out.

Change out programs tend to have limited budgets, but are usually very popular among consumers. Whether it’s a change out, or a straight incentive program, it is best if taxpayer funds are spent on consumer who need it most and not wasted on “free riders” who would make the purchase anyway without the incentive. When rebates disappear in a few hours or even a few weeks, it likely means the rebate was too generous and a lesser rebate could have resulted in a more installs.

To ensure stove change-out program funds benefit low-income consumers, the programs can be opened to them first and heavily advertised in low-income regions.

            Maryland considered a higher rebate for low-income families, but was dissuaded by added bureaucracy it involves and lack of data to demonstrate that it would be successful. 

            The use of income to qualify households for incentives or subsidies has had little support in renewable energy programs, even though it could be done relatively easily. Incentive programs for solar or geothermal rarely, if ever, disqualify families with high household incomes of $250,000 per year or more. Wealthy people like subsidies as much as low and middle-income people and it’s often very unpopular to steer taxpayer subsidies away from the richest families, who often have oversized homes.

As long as professional installation is required, incentivizing more affordable stoves from big box stores can make funding go much further and enable more low-income households to participate. Good quality EPA-certified stoves start at $700 and one of the most popular stoves in the country sells for $900. If stoves could be bought at a deep discount in bulk, program administrators may also get CSIA professionals to establish a discounted fixed price for a certain type of installation. Professional installation can be done by CSIA accredited chimney sweeps if local NFI trained staff at specialty hearth stores will only install their own products. Such a fixed price would be possible for pellet stoves and for wood stoves on single or two story homes where the pipe is mounted on the exterior of the house. If larger rebates are not provided to low-income families, this is a vital way to help them overcome high upfront costs.

7. Minimizing Free-Riders

A perennial problem with all rebate and incentive programs is that some people who take the rebate or the incentive would have made the purchase anyway, and so the funds serve little purpose.  Determining whether a program has a high or low number of “free-riders” is also difficult. 

            This is regarded as a cost of doing business for many rebate programs, such as those for purchase of Energy Star appliances. For stoves, the number of “free-riders” is far higher if consumers don’t learn about the incentive until they are making a purchase in a showroom.  However, if only the cleanest stoves are incentivized, and professional installation is required, programs can have the impact of resulting in cleaner, safer installs. They can also reward those manufacturers who invest more in R&D and produce cleaner stoves, spurring more innovation.

8. Household/area eligibility:

While pellet stoves can be acceptable in rural and more densely populated neighborhoods due to their more consistent low emissions, there are legitimate concerns about programs that encourage or subsidize the installation of wood stoves in densely inhabited or urban areas from a health and nuisance perspectives. Maryland’s program, for instance, is only available to homes that do not have access to natural gas, a backdoor way of limiting installs to more rural, sparsely inhabited areas where available heating fuels are expensive and residents can benefit the most from energy cost relief.  Initial data from the program shows there have been more wood and pellet stove grants awarded per capita in the more rural and less affluent counties than the more populated central region of the state, indicating there has been some success in this method.

A Woodstove Change-out Program in parts of Connecticut, Massachusetts and Rhode Island provided a $3,000 voucher to households who receive Medicaid, Low-income heating assistance, or the Women’s Infant and Children’s Nutrition Program.

Incentive programs can also work closely with low-income heating assistance (LIHEAP) programs, to ensure that families who receive LIHEAP are aware of the program and can access it.

Instead of using access to natural gas as an indicator of housing density, zip codes or counties could be designated as areas where an incentive may be appropriate. Another option would be to limit wood stove installs in more densely populated areas to only when an old, uncertified wood stove is being removed and recycled.

8. Energy Audit:

Energy audits are rarely used even in programs to incentivize modern, bulk fed pellet boilers, much less stove programs. But increasingly, incentives for stoves are available as part of a deeper energy retrofit that starts with an energy audit. Auditors can educate homeowners about the importance of upgrading to safer, more efficient equipment, spot dangerous installations, and assist in removing dangerous stoves. The Building Performance Institute (BPI) is taking the lead in developing guidelines for energy auditors to inspect wood stoves. Requiring energy audits in conjunction with professional installation would assist in states providing a more holistic energy service to consumers when incentivizing wood stoves. The Alliance for Green Heat and University of Maryland Extension produced a draft of steps to inspect a wood stove as a resource.

9. Dedicated outside air:

Several incentive programs in Oregon, Maine and in some HUD Power Saver programs require a dedicated outside air supply, but the requirement is far from accepted in hearth professional circles. In very tight homes, which are still relatively rare in the United States, outside air supply is important, but to require it for all homes not only adds a potentially unnecessary cost, it could even be a drawback.  If a home were found to be very tight, and has competing venting needs, such as a vented kitchen hood, a wood stove may compete for indoor air which could even reverse the flow of air down the chimney. In such a case, a dedicated outside air vent may be recommended for the stove. In Oregon, the requirement could mean simply a $35 vent that provides air within several feet of the stove. Many leading experts question the use of outside air.

10. Education:

Any program incentivizing new wood burning appliances should be coupled with educational materials on correct stove use and efficient burning practices. New appliances used incorrectly can negate the benefits of a new stove, contribute to more air pollution, and turn public opinion against wood burning and the program. It is well known that in terms of achieving ideal efficiency and cleanliness, choosing the right stove is only half the battle; the other half is the fuel and the operator. No matter how modern or clean a wood stove is, it is crucial that the operator use dry, split wood and give their stove enough air to maintain a clean burn. The EPA Burn Wise program, is a great resource for consumers that should be promoted by incentive programs. Consumers could even be asked when they receive an incentive to sign a pledge promising to only burn dry wood.  

11. Partners and Outreach

A “best practice” for virtually any incentive program is building a network of engaged partners who are committed to the particular goals of the program. For instance, if benefitting lower income populations is a goal, partnering with a local or state low-income heating assistance program can help get the word out to that population. Conversely, we found one incentive program in Alabama, where even the local hearth retail stores did not know it existed.

If the program is run by a state energy office, bringing in the expertise of the state air quality office is also important to ensure that agencies aren’t working at cross-purposes, as what happened in Oregon.

12. Reducing emissions

            Using a rebate or incentive to steer consumers toward the cleanest wood or pellet stove has some positive emission benefits on its own. Some states, such as Idaho, have for years required people to turn in an old, uncertified stove to get an incentive for a new one.  This resembles an ongoing, state-wide change-out, more than a stand alone incentive program, as it is not open to people who do not already have an old stove. Possibly the oldest continuously operating stove incentive program is in Arizona, where the state gives an incentive to put a EPA certified stove in a fireplace, to reduce the use of fireplaces for heating. And, in New York, the return of an old stove is waived for lower income families who want to buy a new pellet stove and do not have access to natural gas.

13.  Providing moisture meters and subsidizing wood sheds:

Moisture meters are effective yet inexpensive tools for ensuring homeowners only burn dry wood. One option is to provide a free ($10) moisture meter to every home that has a stove installed. One major woodstove manufacturer has begun to include a free moisture meter with each purchase of one of its wood stoves. States have the option of teaming up with the EPA’s Burn Wise program, which is promoting voluntary efforts like this to help wood stove owners burn cleaner and more efficiently.

Incentive programs could subsidize, prioritize or even require homes to have or build woodsheds. This would help ensure that subsidizing a new stove will result in reduced smoke from the home, or homes with woodsheds could receive a higher rebate, which incentivizes proper storage and educates people about its importance. An even more ambitious and more innovative concept would be to provide a firewood shed with every project. The EPA Burn Wise has a modular woodshed plan that cost $217 in materials and can be built off site or onsite.  Some experts question if a $150 rebate to help build a wood shed to keep wood dry may produce similar or more air quality benefits as a $1,000 rebate for a stove. The logistics of this is not necessarily easy, but it is something worth considering.

14. Monitoring and Evaluation

            Assessing the effectiveness of the program using agreed upon method is important. Many renewable energy incentive programs, including those that involve solar and geothermal, struggle with accurate and meaningful assessment often because the agency in charge of the programs wants to show it as a success.  Meaningful third party assessments can be expensive and may not be worthwhile unless the program is ongoing and there is an opportunity to change the program, something that outside interest groups may oppose. But tweaking program requirements is almost always necessary, and key stakeholders play a vital role in this. 

            For wood and pellet stoves, assessing the success of a program can be especially difficult because there is no easy way to meter heat output or fossil fuels avoidance. Particulate emission testing can be done in smaller, valley settings, but is difficult to monitor in state-wide settings.  Surveys of all participants via mail and email could be very useful and are an underutilized tool for gaining insights into program results. Surveys of hearth retailers can also be important.

Conclusion:

“Best practices” in stove incentive programs are likely to be increasingly important as more options for smart deployment become possible. States with more expertise and more background in wood heat are more likely to have ability to incorporate more best practices into their programs. Trying to include too many best practices can make programs too complicated for both consumers and the implementing agency, so it’s important for program designers to tailor the requirements to the program goals. Using a state’s program requirements for a solar incentive program is often a good starting place when developing wood and pellet stove incentive programs.

At this point in the evolution of stove technology, we feel that pellet stoves are particularly ready to be part of more incentive programs. However, public disclosure of efficiencies by manufacturers will make this process much quicker.

 Almost all programs have had to make adjustments after establishing requirements that did not work as planned.  While this is a normal part of the learning curve of establishing a program for any appliance or technology, we hope this short report may lead agencies to ask the right questions and consider effective options.

A Comparison of Eligibility Requirements for Stoves Incentive Programs October 31, 2014

* This efficiency level was not measured or enforced in any meaningful way.

** This program only allows upgrades from lower to higher efficiency using the EPA default numbers.

*** MD and ME allow for professional inspection in lieu of professional installation.

**** No efficiency minimum; higher efficiency stoves get higher rebate amounts.