Gas stoves and fireplaces appliances need better regulation and transparent efficiencies

Public comment from the Alliance for Green Heat 

April 8, 2022

RE: Docket Number EERE-2021-BT-DET-0034: Notice of Proposed Determination of Miscellaneous Gas Products as a Covered Consumer Product

Thank you for the opportunity to comment on miscellaneous gas products as a covered consumer product. 87 Fed. Reg. 6786 (February 7, 2022).

In the United States, efficiencies of gas stoves are often unavailable, and it can be very confusing. The only reliable database is maintained by the Canadian government and consumers often do not know to check it, even if they want a more efficient appliance. Consumers who are trying to save on heating bills often use their gas stove or fireplace to heat the core of the house instead of using the gas furnace to heat entire house. Gas furnaces can waste up to 30% of their heat from leaking ducts. According to the DOE, “Ducts that leak heated air into unheated spaces can add hundreds of dollars a year to your heating ... bills."

We found that very few websites provide accurate information about gas appliances for consumers, in part because there are many gray areas due to lack of regulation. The CEO of one US manufacturer of gas stoves that we spoke to did not know if was required to test for efficiency or even if his products had been tested even though they were designed and marketed as heaters. We also called many retailers and received a wide mix of contradictory information. One told us we had to ask the manufacturer about efficiency. One had no idea how to determine efficiency. And one provided an efficiency from the “nameplate” but when we checked that number with the Canadian database, it was different. We concluded that consumers should beware of efficiency claims on manufacturer websites or from retailers and to always check the Canadian database if they wanted to know the efficiency of a product.

As a result of this, we strongly support the DOE finding that decorative hearths and outdoor heaters qualify as covered products under EPCA. Gas fireplaces and stoves are often used daily to provide heat for homes, as both a primary and secondary heat source. Consumers stand to save significant amounts of money and gas if these heaters are regulated and have to meet minimum efficiency standards. Many retailers advertise that gas inserts can easily serve as the primary source of heat for your home and claim that they use “50% to 90% less gas than gas logs and up to 75% less gas than a gas furnace.”3

Advertisements often
tout the heating benefits
of gas over wood in a
variety of ways.

We also support DOE’s determination to include propane products in the scope of this proposed coverage determination for miscellaneous gas products. Stoves and fireplaces that use propane are nearly identical to those that use natural gas and are very popular in areas that are not served by gas pipelines. The same companies that make gas appliances also make propane ones and it makes little sense to regulate one and not another and would create a confusing and artificial distinction for manufacturers, retailers and consumers. Propane is typically even more expensive than natural gas, so consumers stand to save far more if they have transparent and minimum efficiency ratings.

We are concerned that DOE may have underestimating the annual shipments of miscellaneous gas products. To the extent the DOE relied on figures from HPBA, they must consider that HPBA shipment data typically only includes appliance shipments by their member companies, not by all companies that make and ship gas appliances. In recent years, some of the largest gas appliance manufacturers have dropped their membership in HPBA, and as a result, shipments from those companies would probably not be included. HPBA does not disclose which companies provided data and which didn’t. Even for member companies, they cannot require disclosure of shipment data, but it appears member companies usually participate.

Thank you. Sincerely,

John Ackerly
President
Alliance for Green Heat

New EPA Stove Regulations Begin Cleaner Chapter for Wood Heating

Statement by the Alliance for Green Heat on the Wood Heater NSPS

Key EPA architects of this NSPS include
Greg Green, left, and Gil Wood,  right  and
Amanda Simcox. Gil retired on February 3. 

Overall, the EPA did a good job and released a fair rule that includes many compromises between industry and air quality agencies.  We think these rules are good for consumers and will not drive prices up substantially for most product categories, but will result in cleaner and more efficient appliances that will ultimately save consumers time and money. This is our initial reaction to the rule, which we will be followed by a more thorough analysis.

High performance stoves: The EPA took some key steps to address the lack of recognition for high performing appliances. Notably, stoves that test with cordwood in the next 5 years can use a special EPA label that will alert consumers that the device is designed and tested for use like the consumer will use it. This shift is possibly as important than just lowering emission standards for wood stoves. Along these lines, the EPA is also allowing stoves that already meet the 2020 standards, to use a special label so consumers can more easily recognize these higher performing stoves. We are, however, very disappointed that the EPA removed the long-standing requirement that all stoves have a consumer hang-tag that helps consumers better appreciate the basic differences between all stoves on the showroom floor.

Boiler testing: Another positive step forward is EPA’s recognition of the European test method EN303-5 to certify European style indoor pellet boilers that have been accepted by Renewable Heat New York (RHNY). Also boilers certified by the New York State Department of Environmental Conservation (NYSDEC) will be automatically deemed EPA certified. This is another step to recognizing higher performance equipment. NYSERDA deserves credit for the R&D, test method and other funding that EPA and DOE should have been doing to develop higher performance equipment. These parts of the new EPA rule will help give consumers more options to buy cleaner and more efficient devices.

Stove emission standards: As expected, the EPA is staying with the de facto status quo for the next 5 years, at 4.5 grams an hour (g/hr). The 2 g/hr standard for stoves as of 2020 is fair and reasonable. As the EPA explained in the rule “nearly 90 percent of current catalytic/hybrid stoves and over 18 percent of current non-catalytic stoves” already meet the Step 2 emission limit of 2 g/hr. We hope that those manufacturers who have to redesign stoves use the opportunity to redesign to use cordwood and to reduce start-up and fugitive emissions. The optional Step 2 certification test for cordwood at 2.5 g/hr represents a very creative and positive approach by the EPA to move towards required cord wood testing.

Some independent stove and boiler companies played a vital role in broadening the debate and sharing key data sets that enabled the EPA to show that some stoves can already meet the Step 2 standards of 2 g/hr with cordwood. We are pleased that companies who participated in the 2013 Wood Stove Design Challenge helped the EPA and OMB understand that smallest manufacturers can undertake the R&D to make very clean and affordable stoves that operate well on cordwood.

Key issues not addressed: Some of the most important issues with wood stoves are difficult to address in regulations, such as indoor air quality from fugitive smoke and the ability for homeowners to reduce air-flow so much that the stove smolders for hours on end, which is often a nightly occurrence. Ultimately, we believe that some types of automation are needed to prevent the widespread consumer misuse of wood stoves. The attempt by the EPA to set a maximum emission level while the stove is on its lowest burn rate was a good start. We had urged the EPA to more formally address alternative tests for automated stoves that hold tremendous promise to reduce widespread poor operation by consumers.

Warm air furnaces: Delaying the standards for all warm air furnaces for 1 - 2 years was a mistake because some companies have little ability or intention of meeting the Step 1 standards. An interim measure after 6 months to distinguish between companies on their way towards meeting standards and those who aren’t would have been far better.

Exempt wood stoves: We are very pleased to see that the era of exempt wood stoves is over. About 1 out of every 3 or 4 new wood stoves sold in America has been exempt in recent years and EPA had considered a weaker standard for them, but is now holding them to same standard as all other stoves.

Masonry heaters: The EPA was not able to set standards for masonry heaters but we are glad to see that the EPA has charted a path forward to work with the Masonry Heater Association so that masonry heaters become a certified appliance category

Sell-through period: The sell-through period, set at 8 months through December 31st is fair for certified wood stoves, pellet stoves and qualified or EN303-5 approved boilers, but too long for exempt wood stoves and traditional outdoor boilers which should have come off the market sooner.

Electronic reporting: We were very glad to see that the EPA will begin electronic reporting for stove certification tests and provide more transparency for the public and access more data that is not Confidential Business Information (CBI) about stove tests.

Efficiency: Achievable efficiency standards are important in the near future and we are pleased that the EPA will finally require the manufacturers to test for, and report actual efficiency numbers not only to the EPA, but also on their websites. In practice however, many existing stoves many not have to retest for 3-5 years and it is unclear if they will have to disclose efficiency before then, unless they do it voluntarily. This is particularly important for boilers and pellet stoves that have a very wide range of efficiencies.

Renewable energy: We are very disappointed that the EPA did not mention the term “renewable” in this rule. The EPA Office of Air and Radiation should take into consideration that this sector has potential not just to make cleaner energy, but to use a renewable energy source and displace fossil fuels. Governor Cuomo’s Renewable Heat New York is investing tens of millions into the sector and integrates the goal of driving down emissions, driving up efficiency while replacing fossil fuels and offering homeowners an affordable, renewable heating source. In addition to setting minimum emission standards for lab testing, the EPA should adopt a more integrated approach to this technology that is being increasingly adopted not just by New York, but by other states as well.

In conclusion, the EPA crafted a fair and balanced rule overall and took some important steps towards testing with cordwood and recognizing those companies who take steps to build stoves based on how consumers operates them. In the long run, this new rule will result in cleaner appliances and a better foundation for renewable wood and pellet heating.

Full EPA rule and fact sheets

Wood and pellet stoves

Step	New PM emissions limit	Compliance deadlines
Step 1: All uncertified wood and pellet stoves (cat and non-cat)	4.5 grams per hour for crib wood test method If tested with cordwood, emissions test method must be approved, and stoves must meet crib wood limit	60 days after publication in the Federal Register
Step 2: All wood and pellet stoves (cat and non-cat)	2.0 grams per hour, or 2.5 grams per hour if tested with cordwood (test method must be approved)	5 years after publication in the Federal Register (2020)

Hydronic heaters

Step	New PM emissions limit	Compliance deadlines
Step 1	0.32 pounds per million Btu heat output (weighted average), with a cap of 18 grams per hour for individual test runs (crib wood test method) If tested with cordwood, emissions test method must be approved, and stoves must meet crib wood limit	60 days after publication in the Federal Register
Step 2	0.10 pounds per million Btu heat output for each burn rate, or 0.15 pounds per million Btu heat output for each burn rate. If tested with cordwood; method must be approved	5 years after publication in the Federal Register (2020)

Warm air furnaces

Step	Standard	Compliance deadlines
Step 1	Operational/work practice standards	60 days after publication in the Federal Register
Step 2	Emissions limit of 0.93 pounds of PM per million Btu heat output, weighted average. Cordwood testing is required for forced air furnaces	Small furnaces: 1 year after publication in the Federal Register (2016) Large furnaces: 2 years after publication (2017)
Step 3	Emissions limit of 0.15 pounds of PM per million Btu heat output for each individual burn rate. Cordwood testing required	All furnaces: 5 years after publication in the Federal Register (2020)

Related stories:
Private Talks Yield Consensus on Key Issues in NSPS
Paper Undermines Stove Industry Variability Study

More than 40,000 new, uncertified stoves sold each year says EPA

The EPA recently released a figure of 40,000 uncertified, exempt stoves being sold each year.  An estimate on the volume of sales of these stoves had long been sought by the EPA and others, but manufacturers would not supply them.  Exempt wood stoves are not required by the EPA to meet any emissions standards and they are likely to emit five to ten times the smoke and particulates of an EPA certified stove.  These exempt, uncertified stoves usually sell for $200 to $500 a piece.  In contrast, EPA certified stoves typically start around $650. More and more used EPA stoves are coming onto the second hand market in the $300 - $800 price range.

Lit'l Sweetie, a typical exempt,
uncertified wood stove that has been
a popular seller in the US

Since the year 2000, about 135,000 EPA certified wood stoves and inserts have been sold each year, making the 40,000 new, uncertified stove market a considerable part of overall stoves sales in the US.  To get a sense of the robust exempt wood stove market, consumers can search for “wood stove” at Amazon.com.  Usually the majority of stoves shown for sale on the site are exempt, including barrel stove kits.

Next year the EPA is proposing to ban the production and sale of exempt wood stoves.  There is little doubt that the final rule will put an end to the sale of stoves that do not need to meet emission standards.  At the EPA’s pubic hearing in Boston on the proposed regulations, Steve Vogelzang, founder of the company that may have sold the most exempt wood stoves in the US, called on the EPA to reconsider their proposal, arguing that there is still a need for stoves like these to go into cabins and workshops.  He added that, if the EPA moves forward on the ban, “we are going to remove the most affordable stoves from the market.”  To read the full analysis of the impact of the EPA’s proposed regulations, see pp. 110 – 144 of the proposed rule.

One problem with exempt stoves is trying to keep them out of jurisdictions that they are not allowed to be sold in.  Washington and California have long banned new installations of them, and many retailers list those states as places they cannot be shipped to.  They are also not allowed to be sold or installed in Oregon and the Denver and Salt Lake City areas.  Vogelzang, probably the largest manufacturer of exempt stoves, does not provide any information to consumers on its website about where they can be shipped or installed.  US Stove, which now owns Vogelzang and is also a major manufacturer of exempt stoves, tells its consumers that they can’t ship to Washington and California, but does not mention Oregon or parts of Utah and Colorado.  According to Paul Williams, National Sales Manager for US Stove, while they may not have the information on their websites, when they get they calls and emails for exempt stoves, “our answer ... is they are not shipped to CA, OR, WA, CO and UT.”

Northern Tool + Equipment, a major in-store and online retailer that sells exempt wood stoves, advertises that the Vogelzang Lit’l Sweetie “meets or exceeds EPA requirements for exempt wood stoves.”  In reality, the Lit’l Sweetie does not meet or exceed any EPA emissions requirement, but is exempt from them.  The Alliance for Green Heat spotlighted this misleading advertising in September 2012 but misleading language is still common in advertisements for exempt stoves.  Northern Tool’s website is programmed to not take orders for exempt stoves from addresses in states where exempt stoves cannot be shipped.

Amazon.com, a venue many consumers turn to for everyday needs, may be the best major retail outlet for informing consumers that exempt stoves can’t be shipped to WA, OR, CA, UT or CO.  The site has a variety of sellers with product descriptions and also allows for consumers to directly ask and answer questions about the product.  Similarly, Home-Depot is good on both providing customer information and regulating the purchasing of exempt stoves.  They clearly label the stove as EPA exempt, say that they cannot ship to WA, OR, CA, UT or CO and the website will not let consumers purchase from those states.