DOE should focus resources on R&D to advance automated stove technologies

 The Department of Energy Bioenergy Technologies Office (BETO) released a Request for Information (RFI) seeking feedback on defining the goals and objectives for a planned effort to collect in-situ wood heater performance data in the field. The deadline to submit comments was September 30, 2024. John Ackerly, AGH President, submitted the following comment: 

There are a number of small portable
emission testing devices for wood stoves
that can be used in situ, or larger lab
equipment can be moved to a home.

"We believe BETO should minimize its role in funding in-situ testing efforts because in-situ testing is usually very complex and expensive, given BETO’s funding for residential wood heater technology development. There are many distinct objectives and reasons to do in-site testing, and stakeholders could eloquently make the case for any number of them. But given the size of BETO’s budget, we do not feel there is a compelling enough type of in-situ testing that is likely to be undertaken.

BETO’s mandate is to “support the development of cleaner burning, higher efficiency residential wood heaters” and it seems this has been interpreted more broadly over time, which is understandable to some point, given the dearth of high quality applications to develop next generation stove technology.

We would urge BETO to only fund in-site testing to the extent it directly focuses on modern, more automated stove technology. For example, it may be worthwhile doing some in-situ testing with an automated stove side by side with a traditional manually operated one, to provide data about how beneficial automation can be, if at all.

The list of questions in the Four Categories suggest that this RFI is wide-ranging without parameters related to development of cleaner burning, high efficiency residential heaters. In the United States, stoves must be tested for PM 2.5 to be certified for sale. Efficiency, as measured by B415, is not regulated, but tested and an existing IRS tax credit gives an incentive to hit 75% efficiency, HHV. Any new generation of more modern, cleaner and efficient wood stoves will need to focus on these metrics first.

To understand the potential of modern, automated stoves, it may be just as relevant to study pellet stoves, to understand how and why they have such a predictable emissions profile, compared to cordwood stoves. It is also relatively easy to test how clean and efficient pellet stoves are in-situ after 1 to 10 years in operation.

To achieve testing goals of how pellet stoves perform after 1 – 10 years of use, I would recommend simply using a Testo 380 and principally test for PM2.5, enabling more sampling of more devices.

There are a multitude of academic inquiries into residential wood smoke but BETO should first determine what avenues there are to more directly advance an R&D agenda, which could include emissions data showing how automation can reduce emissions. Cordwood furnaces have already made the transition from being manually operated to controlled by sensors, and the evidence is clear that sensors will keep a boiler or furnace far cleaner.

Some stakeholders who are heavily invested in manually operated stoves may want BETO to undertake in-situ testing studies, which can be endless. But one test of this RFI will be whether those stakeholders who are doing R&D on modern, more automated stoves need in situ testing data, and if so, what kind. Similarly, it may be instructive to see what kind of in-situ testing is recommended by stakeholders who regulate wood stoves, or are involved in health related studies.

BETO could consider doing an RFI on how to develop the next generation of wood stoves in the United States. R&D is perhaps the most important avenue but DOE funding in the solar, wind and geothermal sectors address scores of barriers to bringing a renewable technology to scale. Those barriers can also be addressed in the eco-system surrounding the wood heater community. Obviously, the wood heater sector will never have that level of resources, requiring a careful assessment of where scarce resources can best be used.

An RFI that engages this community on how to advance automated stove technology may help better understand why major manufacturers are hesitant or whether there are other initiatives that could be undertaken. In-situ testing may be one of them, but an RFI solely on in-site testing sends a confusing message to the wood heating community unless BETO better explains how it is part of a strategy to develop modern, more automated stove technology.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Alaska wood stove regulations – cleaning the air or a proxy war?

On Sept. 26, the EPA issued a resounding victory to Alaska’s strategy for improving the air in the Fairbanks area, rebuking virtually all of industry’s objections.  That victory came from the approval of Alaska’s State Implement Plan (SIP) to reduce wood smoke PM2.5 in the Fairbanks non-attainment area.

In essence, Alaska proposed different and stricter standards for wood stoves to be sold and installed in Fairbanks.  They will not allow cordwood boilers, coal heaters, stoves that emit more than 2 grams, or stoves that emit more than 4 or 6 grams during any hour of testing, and multiple other restrictions.  All of this helps. HPBA and more than a dozen wood stove manufacturers mounted a major effort to beat back the Alaska regulations, making the case that much of Alaska’s approach was arbitrary and capricious, not based on evidence, contradicted federal standards, etc. etc.  EPA’s ruling took the side of Alaska on every issue, often by simply stating that states have the authority to be more stringent than federal standard, rather than addressing the details of industry’s points.

 

Why this is a big deal

What everyone needs to understand is that the little city of Fairbanks Alaska has become a proxy war in a much larger struggle over the future of wood stove testing.  Much of Alaska’s work to review stove certifications did not address air quality in Fairbanks, but it does have major national ramifications.  Alaska developed its own list of stoves that could be installed in Fairbanks that was not based solely on emissions criteria.  Instead, it was mainly based on whether the certification paperwork was complete, and they could verify that the test labs correctly followed EPA stove testing regulations, despite the existence of some grey areas.  This set-in motion an unheralded level of scrutiny on testing done by all EPA approved labs, and sent the EPA into an embarrassing tail-spin, as they showed that the EPA had abdicated its role in effectively overseeing its certification program.

The Fairbanks North Star Borough 
(FNSB) non-attainment map.

Alaska’s scrutiny of certification paperwork was sometimes clumsy, and they found hundreds of details were missing, requiring manufacturers to show them that they often were there, but just difficult to find.  EPA has never provided a consistent format for labs to report data and it has been difficult to get the EPA to confirm which details needed to be included in the certification reports. But usually the details Alaska could not find were in fact missing and they uncovered serious patterns and deficiencies in many certification reports, something that few in industry are willing to admit. Those deficiencies had been in plain sight for years, but nobody looked carefully enough. The EPA, scrambling to show they take wood stoves seriously, began a slow but steady process to figure out what went wrong and how to fix it.  They commenced their own review of certification paperwork and over a year later, they are now sending letters to manufacturers requiring them to provide missing data.  Moreover, they are taking the unique step of requiring some stoves to be retested, similar to the audit testing that HPBA fought against.

 

The significance of the EPA’s ruling on Alaska’s SIP is difficult to summarize, as it has many highly technical themes, each one difficult to assess on its own merits.  Suffice it say that the stove community is in the midst of a historic period of change that had already started with the 2016 EPA decision to design new stove testing protocols, using the Integrated Duty Cycle (IDC) model developed by NESCAUM. Alaska has now tipped the balance of power toward a wider review of EPA’s certification program – and its enforcement and compliance unit.  One manufacturer went so far to say that Alaska had improperly pre-empted the EPA by creating a “de facto federal standard.”  There is the possibility that other states may follow Alaska’s approach, either through regulations or voluntary programs like change outs.  

 

AGH believes the Alaska initiative has had several positive impacts.  First, it’s made labs test stoves more carefully, and properly dot their i’s and cross their t’s.  Secondly, it forced the EPA to take their wood heater certification program more seriously, run it more professionally and better understand the grey areas that they had unknowingly included in the 2015 stove regulations.  

 

The long term view

But the most important outcome is something that all parties can agree on: understanding how to improve test methods so that they encourage engineers to design stoves that will perform better in the hands of consumers.  This is what we all are working for.  Alaska has now brought attention, if not clarity, to scores of issues that make for an effective certification program.  A good certification program needs clear guidance to manufacturers and labs and it needs a compliance program.

AGH is hopeful that this process will lead to genuinely cleaner stoves that get put through their paces in a test lab just as homeowners will use that stove. It’s useful to consider other EPA certification testing programs and the decades it has taken to understand their weaknesses and reform them, so consumers are getting products that work well in the real world.  

EPA auto emission standards
got stricter - and more realistic.

Automobile testing, for example, went through similar stages.  A revolution in auto testing, in the words of one expert, happened when manufactures were “motivated to produce emission controls that not only pass emission certification testing, but also remain functional when vehicles are in real-world use.”  Admittedly, the auto industry is massive and can afford levels of R&D and compliance that are impossible for the tiny, but resilient wood stove industry. Herein lies the rub: how far can the EPA and manufacturers be pushed to make lasting changes? Both are resource constrained.  Will the EPA stay focused on this program?  If they don’t, will other states undertake their own initiatives?  Will some manufacturers just quit making wood stoves and focus on their carbon intensive but profitable gas appliances? And does their industry association have the leadership and vision to steer industry through this, or will they focus more on legal and regulatory battles that may be difficult to win.  Many of the large stove manufacturers, including the biggest three, have already let their memberships lapse, for a variety of reasons.

AGH believes we need a hearth industry that can produce appliances clean enough to help households get off fossil heating fuels.  We are not there yet, except with pellet stoves and boilers which work well in the hands of consumers and can easily be improved even more.  Most New England states have incentives for pellet heating and western US states should adopt those policies as well. The electrification movement and more extreme and frequent weather events may solidify the demand for wood stoves.  Pellet heating deserves far more incentives.

A set-back for federal change-out funding

The Alaska initiative has also been very problematic and in some ways damaging.  A NESCAUM report made the implausible claim that the EPA cannot assure that new certified stoves are in fact cleaner than old, uncertified ones.  Actual lab and field testing has repeatedly found the opposite to be true.  This report helped scuttle federal legislation sought by HPBA that would have provided tens of millions for change-out programs.  The irony is that much of that funding would have helped lower-income families switch to fuels that produce less PM (but maybe more carbon), like gas, pellets, or electricity (heat pumps).  This occurred during the year that Congress increased the tax credit for high efficiency stoves, which benefits higher income taxpayers.  Change-outs also require professional installation which often reduces future PM, whereas a very large percent of stoves bought with the tax credit are self-installed.

Like America, the stove community has become even more divided, making the process of developing new test protocols more contentious.  It is unclear what individual or entity has the leadership to bring the sides together to hash out the scores of issues in a truly productive way that could reduce the bitter and litigious atmosphere. The Alaska initiative did not help but it could set the stage for more collaboration, if someone can facilitate it.  Up until a few years, 90% of the expertise in stove testing was within industry and the test labs they work closely with to certify their stoves.  This process has changed that dynamic, forcing more people at EPA and state agencies understand the regulations and the science behind stove testing.  

This NYT image shows extremely
slow growth of renewables in our
electric supply, an impediment
to the electrification movement.

There is also little consensus about the future of wood and pellet heating in America.  This process is being driven by air quality agencies who usually don’t take carbon into consideration.  Thus, even if a pellet stove fueled mainly by residuals from sawmills has higher PM than a gas stove, these officials may lean more heavily on the gas scales.  In the US, there is scant leadership that there is in most of Europe promoting certain types of high efficiency wood and pellet heating as part of the renewable energy solution, at least until our grids have a majority of renewable electricity on them.  The EPA – and Alaska – often claim to work under a technology neutral rubric, although neither is technology neutral, nor should they be.  They both need to more aggressively promote cleaner, lower carbon appliances.  The EPA and Alaska even struggle to officially tip the scales more towards pellet appliances, even though their air quality mandate should make that an obvious policy direction. Luckily, while EPA works on how to test stoves, the DOE is funding a complementary process – building innovative, next-generation wood stoves.

Industry has vital expertise that must go into the process of developing new stove testing protocols.  Many individual manufacturers also will be gathering vital test data from internal testing that they could share with the EPA.  NESCAUM is also developing data which they should share at some point. We need thoughtful leadership on both sides to make sure we get genuinely effective test methods that incentivize manufacturers to do the kind of R&D that will lead to stoves that work well in homes.  Industry sometimes seems to think the rule making process should still be a "reg neg" - a negotiated rulemaking that emerged in the 1980s and was used in the first wood heater NSPS.  Reg negs were supposed to reduce the overly adversarial process of traditional rulemaking.  This is not a reg neg but still, effective cooperation and communication can be extremely beneficial.

The lengthy process that led to the 2015 NSPS regulations did not lead to a new generation of cleaner stoves, like the 1988 regulations did.  But we are now asking the right questions and we better understand the nature of beast that we are trying to control.  Who will step forward and reset the relationship between industry and air quality agencies?

Thermal certificates can fuel commercial wood heating

Renewable Energy Certificates (RECs) are the market instruments used by state governments to identify who produced renewable energy.  When states require utilities to meet a certain percent of their energy from renewables, they can either produce it themselves or buy RECs.  RECs have been the core mechanism for solar to grow in the United States, but rarely were they used for renewable heat.  Currently a number of states provide RECs for renewable heat, which could come from biomass, solar thermal or geothermal.   A handful of states, including New Hampshire and Massachusetts now include thermal biomass and Maine, Maryland and others are exploring it.

The Governor of Maryland proposed adding thermal RECs to Maryland's renewable portfolio standard (RPS) as part of its legislative package this year.  The Alliance for Green Heat was invited to testify to the Senate Finance Committee on February 23 and we reproduce our testimony below.  During the hearing on the House side, several witnesses opposed the legislation based on particulate matter emissions and carbon, so AGH focused comments on those areas.  

Chair Kelly and Vice-Chair Feldman and Members of the Senate Finance Committee:

Thank you for the opportunity to testify before this committee.  My name is John Ackerly and I am the President and Founder of the Alliance for Green Heat, a non-profit group based in Takoma Park Maryland that promotes renewable heating options.  As you may know, Takoma Park has a corn heating co-op, started by Mike Tidwell, before he founded the Chesapeake Climate Action Network.  What we are debating here is even better than heating with corn, because corn involved forest land conversion into agricultural fields.

We worked particularly closely with the Maryland Energy Administration and Delegate Heather Mizeur back in 2012 to set up their popular Wood Stove Grant Program, where about 85% of grants go to very clean burning pellet stoves.

We enthusiastically support the passage of Senate Bill 549 and the companion House Bill 682 because of the significant benefits to displacing fossil fuel.  We also support the amendments that would end Tier 1 RECs for black liquor since RECs should incentivize more renewable energy capacity, not subsidize existing renewable energy.  Thermal RECs have fallen prey to black liquor politics for too long.  It is time for a vote on their own merits.  

Particulate matter

Larger biomass systems are able to drastically reduce particulate matter (PM2.5) through electrostatic precipitators and other PM reduction technologies.  In terms of pollution, the most important thing to recognize with biomass heating is that residential wood stoves and boilers – whether EPA certified or not – are the biggest threat to local air quality.  A study done for the State of Minnesota shows the advantages of automated biomass boilers compared to traditional wood stoves. It shows that per unit of heat, wood stoves emit 12 to 25 times more PM10 than modern boilers.  

If Maryland wants to tackle wood smoke, the best solution would be to reduce the number of traditional wood stoves, particularly in more populated areas.  Pellet stove are an excellent residential heat option, and together with solar panels, can reduce a home’s fossil fuel usage by 50 – 90%.  

The benefit of passing this legislation in Maryland, is that the Maryland Department of the Environment has strict air quality regulations and staff that understand pollution control technologies.  The commercial systems that this legislation would enable will have to have technologies like electrostatic precipitators (ESPs) or similar technologies.  Most if not all Northeastern states have similar air quality protections but in some parts of the United States, ESPs would not be required and biomass heating plants could pose local air quality problems. 

Carbon

 From a carbon perspective, wood pellet heating emits less than half the carbon of propane and is even more favorable compared to heating oil or gas.  My organization has reviewed scores of Life Cycle Analyses (LCAs) and has not found any that show wood or pellets is worse than fossil heating fuels.  It’s important for this committee not to confuse the Life Cycle Analysis of industrial scale wood or pellets used make electricity, which is a far different equation.  When biomass is used for electricity, it is combusted at about 30% efficiency, but when it is combusted for heat it is up to 80% efficiency.  In addition, the harvesting methods for industrial scale pellets, for example, that are shipped to Europe, involve using more whole trees, not residuals as they do in Maryland.  

A peer reviewed University of New Hampshire study in 2017 found that heating with pellets reduces greenhouse gas emissions by 54 percent vs. home heating oil, and 59 percent vs. natural gas. This chart summarizes their results.

Other factors

When comparing modern biomass heating systems to fossil heating fuels, there is more to look at than just PM and carbon.  There are toxicity implications for soil, water and humans.  The chart below compares softwood (pine) pellets with other fuels.  (Brassica pellets are not used in America and refer to pellets made from agricultural crops, or possibly hay.). This is important because the Chesapeake Bay watershed is a sensitive one, and we are confident that these modern biomass heating plants compare relatively well in almost all respects to other fuels.

This committee is considering other bills to expand Maryland’s renewable energy portfolio and one that specifically seeks to expand geothermal energy in Maryland.  We also urge you to support the geothermal bill and urge you to consider the cost/benefit analysis of geothermal and look at other socio-economic factors.  We need to be mindful that investments in various renewable energy pathways benefit different communities and different workforces in Maryland.  Biomass heating – both at the residential and commercial scale – has far more benefits for rural Marylanders, whose homes and businesses do not have access to natural gas lines.  In this age where we all know that environmental justice is important and jobs for lower income Marylanders is important. We urge you to vote favorably on SB 549.

Sincerely,

John Ackerly,

President

Alaska releases deficiency details on wood and pellet stove test reports

Bryce Ward, Mayor of Fairbanks
North Star Borough.

Alaska posted summary review sheets of nearly every certified wood and pellet stove, exposing issues in a certification system that has been running for decades with little oversight. Of the 131 wood stove models, 130 had major problems in their testing report based on the Alaska classification system.

ADEC is pursuing EPA approval of s smoke reduction plan similar to one in Montana. They said, “Missoula City-County Montana regulations allows installation permits only for pellet stoves emitting no more than 1.0 gm/hr.  Alaska embarked on the certification test review and the establishment of a 1-hr filter pull standard as an alternative to a pellet only program for the nonattainment area as DEC feels this approach meets the communities desire for more device options and is at least equal to the Missoula requirement."  Click here for the full email.)

Alaska also sought and received approval from the EPA for an IDC cordwood stove test method to be "broadly applicable" which means any manufacturer can choose to use it in a stove's certification test. It also sets the stage for Alaska to potentially require that test for stoves sold in Fairbanks.

Alaska is undertaking this unprecedented review in an effort to find the stoves that they can be assured are the cleanest and meet all the requirements in EPA regulations under the Clean Air Act. AGH first covered this in a October 22 blog. In addition to checking that stoves meet the extremely detailed level of documentation based on emission testing, Alaska has imposed even stricter emission requirements, which do not apply anywhere other than Fairbanks. The primary stricter standard is that stoves cannot emit more than 6 grams an hour of particulates during the first hour of a multi hour test. Ultimately, when averaging the PM of the entire test, stoves must emit no more than 2 grams an hour to meet the Fairbanks standard, even though the federal standard allows up to 2.5 grams of PM if a stove is tested with cordwood.

Part of ADECs summary sheet showing
 the preliminary and initial final
determination and the reasons.

The initiative is being undertaken by the Alaska Department of Environmental Conservation (ADEC). It only impacts which stoves and boilers can be installed in a relatively small area around the city of Fairbanks that currently fails federal air quality limits. That is a very small market for the wood stove industry but the initiative may end up having far reaching implications for the EPA, the stove industry and how stoves are tested in the future.

 

One reason why so many stove models are flagged with multiple deficiencies is simply because ADEC officials missed data in the test reports or the manufacturer of the model has not yet provided it. Of the 130 stoves with major problems, many will likely meet Alaska’s review in the coming months. Manufacturers who have requested an extension from the State have until April 1 to work with Alaska to provide details, and only after that can the model not be sold in the Fairbanks non-attainment area. In the meantime, the review appears to shpow that only one wood stove model – MF Fire’s Nova tested by ClearStak lab – could be on the market. The data sheets on all stove models can be found here and will be updated at least monthly.

A Step 1 Jotul stove being tested by
Dirigo labs, taken over by PFS-Teco.

The data on pellet stoves is far better in some respects. Rarely do pellet stoves emit more than 6 grams during the first hour of a test like many wood stoves do. Of the 97 certified pellet stoves, only 3, or about 3%, are disqualified for this reason, compared to 31% of wood stoves. However, like wood stoves, the vast majority of pellet stove test reports had missing data. Only 7 had minor issues. As with wood stoves, over the ensuing months, scores more will likely be approved after missing information is found or provided by the manufacturer. Eleven of the test reports could not be found by ADEC. Sometimes links to these reports are hard to find, sometimes the link is broken, and sometimes the report doesn’t appear to be posted.

ADEC has not yet determined which missing items on test lab reports disqualify a stove. Some of the issues ADEC is flagging have to do more with paperwork requirements than the potential cleanliness of the stove. They are engaging in a series of meetings with EPA personnel from both enforcement (OECA) and air quality (OAQPS) offices to determine what is actually required by the NSPS, what isn’t required, and what should be considered significant. One long time technician at an EPA approved lab said that “based upon ADEC’s interpretation of the language in parts of the Federal Register, they have come up with several new requirements” which never existed before.

A 2019 pie chart made by AGH
showing an approximate percent
of stoves tested by each lab based 
on one data set.

For manufacturers, a key distinction is also data that was collected and exists, but was never calculated or reported properly, compared to data that was mistakenly not collected and could only be obtained by retesting the unit. It’s unclear if any of the test reports are so deficient that the EPA would ever considering revoking a certificate.

The scrutiny of certification paperwork by labs by Alaska also comes on the heels of years of effort by the stove industry to prevent stricter emission standards and the possibility of stricter audits. States have become increasingly frustrated that the EPA is not enforcing their regulations governing wood stoves and boilers. While enforcement was explicitly curtailed under the Trump administration, under Obama and previous administrations, enforcement has been regarded as lax or sporadic. In particular, the EPA has never initiated an audit of a wood stove or boiler to determine if it can achieve the emission levels that it got on its initial certification test. There is also no documentation of the EPA denying certification of a stove or boiler based on inadequate lab reports. In addition, there are only a handful of documented cases when a stove or boiler has failed emission tests in a lab even though industry cites very high rates of variability in emissions during testing.

Some of these issues emerged in 2019 when the EPA released hundreds of documents that NESCAUM had requested in a Freedom of Information Act request. But very little has ever been written about the many complex and opaque issues in test labs other than a blog AGH posted in August 2019: Records reveal successes and challenges in laboratory wood heater testing. That article explored issues of conflicts of interest, compliance with testing regulations and suspension of certification tests, all of which are receiving are receiving more scrutiny by ADEC officials and their partner agencies.

 

An ASTM 3053 test at Omni lab in
May 2020 on a GHP Group stove. GHP
is a company that has not 
requested that ADEC review its stoves.

ADEC’s initiative is also intertwined with concerns about the ASTM E3053 cordwood method and lab tests that showed the method was lax and may have helped some stoves to achieve certification to the EPA’s stricter 2020 standards with few or no modifications to their design. A meeting between EPA and state officials and industry representatives in January of 2020 explored these concerns and ADEC presented their strategy at that time.

ADECs efforts to improve air quality in the Fairbanks non-attainment area go back at least 10 years, starting with traditional stove and boiler change-out programs and a variety of restrictions. But the tenacity of excessive wood smoke in America’s coldest city has frustrated residents and officials alike, leading to this latest effort to understand which stoves are actually cleaner than others. Fairbanks is also spearheading solutions for the other most obvious culprit: unseasoned wood. As of October 1, 2021, only seasoned firewood can be sold in the non-attainment area.

Registration for firewood retailers is
compulsory in Fairbanks and voluntary
in the rest of the state.

It is still too early to tell how much this latest initiative will lead to cleaner air in Fairbanks. There is little doubt that it will bring a new level of scrutiny and integrity to test reports submitted to the EPA, and help the EPA and state agencies better understand how to craft a federal reference method for testing stoves with cordwood.

Postscript: In March 2021, NESCAUM released a report that was largely based off of the reviews of certification reports done jointly by ADEC and NESCAUM.  The scathing report concluded that the EPA process of certifying stoves is "dysfunctional" and recommended a series of aggressive measures.  AGH's initial response that report can be found here.

Related stories

Veteran lab technician challenges Alaska's wood stove criteria (March 2021)

Alaska building list of cleaner, properly certified wood and pellet stoves (Oct. 2020)

A roadmap to get your home off fossil fuel

It took our family a few years and some investment, but it’s not that hard

Our 12-year-old son helping
move bags of pellets.  Each 
bag heats our house for a day.

by John Ackerly

Fifteen years ago I never imagined that our house and cars would be 90% fossil fuel free. It seemed like a futuristic goal that my son may achieve, but not me. Our approach is possible for millions of families who may not realize that they can do it too. With some modest upfront expenditure, it all fell into place.  

When I say fossil fuel free I am talking only about our home and cars, not our food or the junk we buy from Amazon or a store, nor our flights. But we are starting to think about those too and have some strategies.

We this did partly out of a realization that climate change really is an emergency and we don’t want to saddle future generations with a hotter world. But what we did was also smart investing that has drastically lowered our utility bills and transportation bills. Getting your home and cars off of fossil fuels may get as good a return as investing money in the stock market the next 5 to 15 years.  

We began our journey by weatherizing our house, and therefore reducing our demand for heating and cooling, as well as buying 100% wind energy into our grid through the utility company. Later on we began heating with wood pellets, added solar panels, and purchased electric cars. During the winter months when our solar panels don’t supply 100% of our electricity, at least we’re still purchasing energy through a renewable energy electric supplier. Making these changes is a process, and we still use some gas for heating and cooking.  It’s also been a journey of surprises and connections that go all the way back to my grandparents who told me about how wonderful it was when they switched to coal heat.  

Weatherization and energy reduction

Anyone interested in saving energy and reducing their carbon footprint should begin with a home energy audit, often subsidized by utilities. Ours was the best $100 we ever spent, because it made the house much less drafty and immediately started saving us $10 – 20 per month in both summer and winter utility bills.  If you walk around with the energy auditor you can understand each step they take and ask lots of questions. Our house was pretty well insulated already, but there were many gaps where the cold or warm air could escape around ceiling lighting fixtures and behind floor and ceiling molding. As a result, one of the most strategic investments we’ve made in energy efficiency over 20 years was buying about 30 tubes of caulk, sealing up the various places that the auditor’s infrared camera surfaced.  

Other initial, obvious steps to reduce energy consumption is replacing every single lightbulb with LEDs. These bulbs are subsidized by utilities in many states, including Maryland. Whether your state subsidizes them or not, places like Costco have amazing prices for big boxes of bulbs.

Heating with wood pellets

Two tons of pellets comes on 2 four
foot high pallets of 40 lb. bags and
they need to be stored in a garage,
basement, or shed.

Last week we had two tons of wood pellets delivered to our driveway. It took an hour and a half to restack them in a shed behind our house. They cost $500 ($250/ton), plus a $75 delivery charge by Lowes. Our house is about 1,900 square feet with an open floor plan. In Maryland, winters are mild, so our Ravelli pellet stove does a good job heating the house on all but the very coldest mornings. The stove cost $3,000 and installation was another $500. My family and friends love hanging out in front of it. It’s a wonderful focal point for our family, cat and dog all winter. Some states have rebates or tax incentives to buy a pellet stove, including Maryland, Idaho, Vermont, Maine, New York and Massachusetts. Maryland gives a $700 rebate which is more than half the price of one reliable, highly rated and reliable pellet stove brand, PelPro.

Our pellet stove is a wonderful focal
point for our family, requires very little
work, and makes no visible smoke. 

Pellet stoves take a bit of work – about 5 minutes a day to load the hopper and clean out the firepot. Then you just push a button and it runs all day long. This is a lot less time and effort that mowing a lawn or walking a dog – but like a dog, you have to spend a few minutes a day taking care of it, or it can leave a mess on your floor.  It’s important to buy pellets that are certified by the Pellet Fuel Institute (PFI) to ensure the pellets meet quality standards and are 100% natural wood. 

This year, we bought Green Supreme pellets made by Lignetics, one of the companies dedicated to using the PFI certification scheme. They also have good values, motivated to help families across America end the cycle of using more convenient forms of fossil fuels with residuals and low-grade wood produced by the lumber industry. So I’m back to using a solid fuel, just like my grandparents did, which takes a bit more effort. I expect my son to enter a generation that will one day have 100% renewables on the grid, enabling him to also choose a heat pump in what will hopefully be a net zero house that makes as much energy as it uses. 

Another benefit of heating with a pellet stove is that the blowers on our gas furnace cost about $25 a

In much of the US, heat is the biggest 
single source of a home's carbon
foortprint, other than yoiur car(s).

month in electricity, whereas the fans and auger on the pellet stove only cost $5-8 per month. As a point of comparison, previously we heated with a wood stove, using free wood that local tree trimmers were happy to dump in our driveway whenever we needed to split, stack and season more. But with both my wife and I getting up and out of the house in the morning for work, we basically only used the stove each evening and on weekends. This meant relying more on the gas furnace and doing much more work loading the stove and trying to keep the air adjusted properly. 

I had three different EPA wood stoves over a period of 20 years (catalytic & non-catalytic), partly in search of a really good one that could run easily with no visible smoke. Using dry wood, I could usually get them to run without visible smoke, but it wasn’t always so easy and I didn’t feel good about putting smoke in a suburban neighborhood. I bought a high-quality indoor PM sensor and then a second one and found that my indoor air quality was always quite good, but the wood stove wasn’t good for the exterior air that was seeping into my neighbors’ homes. While applauding our success in not relying on fracked gas to heat our house, two neighbors agreed that the excess smoke from wood stoves concerned them. Most neighbors said they liked the smell, one of the enduring paradoxes of a pollutant which is not good for you.  Our neighbors can't even smell, much less see the tiny emissions from our pellet stove.

Solar Electricity

We did not have a south facing roof, so
they put 8 panels facing east and 10
panels facing west, which worked well.

When we remodeled our house in 2006, we unfortunately didn’t consider the potential of solar energy. But the roof still had good enough angles and enough sun. In 2016 we put on 18 panels, rated for 5.4 kW, enough to cover 100% of the household usage, after switching to all LED bulbs, and doing other DIY energy efficiency measures. We paid $18,000 up front, got $6,000 back from the federal tax credit the following April and had no electric bills most months, aside from the monthly $12 connection fee. We worked with Solar Energy World who did a great job. Maryland, like most states, has a net metering law that requires our utility to buy back electricity we produce and don't use. It’s a good deal for our utility too, since we put our excess solar electricity back onto their grid when they need it most – the middle of hot summer days when electricity demand peaks in the Washington DC area.  Not a bad trade-off. 

The blue shows the months we used
more electricity than we made and the
green show when we made more than
we used. 

Once we bought two electric cars and let a neighbor also charge her Chevy Bolt at our house, we now have average $50 monthly electric bill.  Powering a house and keeping 2 and a half cars full of gas could cost 5 to 10 times that much.

Solar panels are great because you don't have to do anything and they work month after month, year after year.  In our case, we spend an hour or two each year trimming a few tree limbs to prevent them from shading the panels too much.  If some of our neighbors hadn't done it first, it may have taken us years longer to make the plunge.  

Purchased wind RECs

Our utility estimated our
household  usage based on
a questionnaire of appliances.

About 15 years ago, long before adding solar panels, we signed up with WGL, a company that provides 100% renewable electricity for only about 10% more than our local utility Pepco charges for their filthy mix of coal, gas and nuclear. It felt so good when we realized we could avoid that.  The way it works is that you buy RECs (Renewable Energy Certificates) from a company that sends your money to a wind farm who is only allowed to sell a limited number of RECs. First make sure the company you buy from is reputable and is part of a third party verified system. WGL is Green-e certified and meets environmental and consumer protections standards set by the non-profit Center for Resource Solutions (CRS).  

There are many companies to buy renewable electricity and most of them buy into big wind farms in Texas and the mid-west, which helps them grow and fill those grids with renewables. We don’t actually get the electrons made by those wind farms, but we pay for them. I don’t really want to subsidize companies that do large solar farms because its often not an optimal use of land, compared to covering our rooftops, parking lots and garages, etc. 

This is one of the easiest things that most people in the country can do in one hour and be an important part of the renewable energy revolution.  Don't wait.

Electric cars

By fueling our own cars at home
and rarely needing maintenance,
we basically never go to gas
stations.

My wife and I had never paid more than $10,000 for a car and I thought I may go through life without ever buying a new car.  But the federal $3,750 tax credit brought the Chevy Bolt down to $26,000, which is what most people pay for cars anyway. With a 250-mile range, it can get us to New York City on one charge. To go on longer road trips, we have to build in more time, and plan where we stop for meals and charging. The state of Maryland gave us a 40% rebate ($400) to install a level 2 charger in our driveway, which was a prerequisite for us. Since we have solar panels, we are not eligible to participate in Maryland’s pilot time-of-use program. That would have made it even cheaper to charge the car at night, when electricity is cheap.

A downside of electric cars now is that most people don’t opt in to purchasing renewable energy, so they are still driving on fossil fuels. It’s still a lower carbon mode of transportation, but it’s so easy to go all the way and select a renewable energy provider for your whole house.

Water heating

Our Rheem heat pump water
heater enabled us to switch
gas to renewable electricity.

Last year our footprint shrank even further when our 15-year-old gas water heater died.  A bit of research led to purchasing a hybrid heat pump water heater, which uses highly efficient heat pump technology. The energy needed is now covered by the electricity from our solar panels for 7 months of the year and from purchased renewable electricity during the other months. This technology requires a big enough basement for it to have enough air circulation, as well as higher up-front costs for the tank and its installation, which come to about $2,000.  The state of Maryland offered a $500 rebate, offsetting the costs. Heating water only cost us $5 - 15 a month before, and now it’s even less. While the monthly savings is small, it’s an important step to get one more appliance off of gas and onto renewable energy. We use it in an eco-mode only by turning off the hybrid features that would allow resistance heating when needed.  Running it solely on the heat pump mode has been good enough to provide us with plenty of hot water for a 3-person household.

Costs of getting off fossil fuel
Solar panels and  electric cars are the big ticket items.  We did it year by year, waiting to upgrade our cars when they needed it.  The solar panels can also be leased, with no upfront costs or financed.  Many hearth retailers provide financing for pellet stoves and Home Depot could have financed the heat pump water heater.  The lowest cost impact is probably signing up for renewable electricity since its starting to be the same price as fossil fuel electricity.  Still, we recognize many families don't have anywhere close the finances that we had to do this.  If your household income is over $100,000 and you periodically buy a new car anyway, you can do it too.  The onlyother thing you need is some time to go through the steps. And you need to care enough about your carbon footprint or climate change, and understand that over the long run, these steps will save you money.  Having kids that care about this stuff helps as they are often the ones educating us parents.

What’s left?

Gas stove. Like a lot of people, we are very attached to our gas stove, which also happens to be antique. We are focusing on the bigger picture and not getting too hung up on every last detail and this will be one of our non-guilty pleasures. That said, we know people who love their induction cook tops and that will probably be in our future.

Gas furnace and gas clothes dryer. Even though we make 80% of our heat from renewable wood pellets, we use the gas furnace for 30 minutes on the coldest mornings to get the house up to temperature while the pellet stove gets going. In the warmer than average February 2020, our gas bill came to $29 for the furnace, cooking and clothes drying, and $11 of that is the fixed system charge. This is not an insignificant amount of gas, far more than our old gas cooking stove. A heat pump space heater for our kitchen/dining room area would probably work pretty well and cut gas heat down to nearly zero. But with only a $150 annual gas bill and maybe $150 for summer air-conditioning, we are starting to get into even longer paybacks. Our gas clothes dryer will be replaced with a electric heat pump clothes dryer when it needs replacing.  Air drying clothes is cheap and in the summer we do it a little and is one of those lifestyle changes that is a hurdle for us.  Part of this energy journey is chipping away at the easiest and highest impact biggest things and then figuring out next steps. We are still working the role of natural gas in our household equation. 

Your income is likely the largest determinant of your carbon
footprint.  Wealthier people have both the ability and the
responsibility to buy renewable RECs, add PV panels, etc.

Lawn mower.  We already had a junky old cord electric mower and we just teamed up with our neighbor to split the cost of a top rated Consumer Report Ego battery powered electric lawn mower ($200 each).

Flights: We have cut down on flying a little bit but still our family flies more than most, taking one or two domestic trips a year for pleasure and many more for work, including international flights. We plan to start buying offsets for our personal flights, which is a first step, albeit not a great one.

Home battery: A home battery, like the Tesla Powerwall, is a way to keep power during a black out for a day or two. I'm not at all convinced it’s worth it yet with a $5,000 - $8,000 price tag. Our neighborhood doesn't experience many blackouts, but they may be more frequent with climate impacts already visible. During the warmer three seasons, we can ride them out pretty easily, only losing the food in our fridge and freezer that we can't eat fast enough. We already have 2 big lithium batteries in the driveway, and it would be far easier if we could top those off before a storm and just run them backwards to power the house, instead of buying another one which would just sit there, virtually doing nothing for 99% of the time. If we had time-of-use (TOU) pricing, we could fill a battery at night and then use energy during the day, but we don't have that yet and it still may be a long payback for a battery.


Good luck with your journey and leave a comment below about how its going for you.  The sooner you begin, the more you will save in the long-run.