Challenges to new heat stoves standards John Ackerly Alliance for Green Heat Warsaw Stove Summit May 29 – 30, 2017 Add AGH logo

AGH is a non-profit advocacy group that Advocates for stricter emissions and efficiency standards Monitors the stove industry & exposes false advertising Is independent of industry and funded by government and private grants. Our flagship program is the Wood Stove Design Challenge that seeks to promote automated wood stoves.

Census map of primary per capita wood heating. 10 – 13 million households use wood stove 2.5 million use them as primary heaters In hundreds of rural counties, 50% of homes have wood PM2.5 map from wood combustion. PM 2.5 from wood smoke correlates in part to type of device. Great Lake states are ground zero for unregulated outdoor wood boilers.

Cookstoves and coal stoves exempt U.S. Emission standards 1988: 7.5 grams an hour 1995: 4.5 grams an hour in Wash. state 2015: 4.5 grams an hour nationwide 2020: 2 grams an hour or 2.5 with cordwood Cookstoves and coal stoves exempt Coal stoves are exempt from emission standards in the US. Annual sales are too low for resources it takes to regulate them. Wood cookstoves also exempt, but can be tested just like heat stoves and some are now EPA certified.

Industry perspective Objections to strict emission standards include: Problem is with old, pre-certified stoves, not new ones. Focus on gains from 20 grams to 4.5 grams, not 4.5 grams to 2 grams. Test method not exact enough to reliably determine a 2 gram an our stove EPA did not have sufficient data to set a 2.5 gram an hour standard for cordwood

Industry response 1. Judicial. HPBA filed a lawsuit in federal court to prevent 2020 standards from taking effect 2. Congress. HPBA had legislation introduced to delay 2020 standards until 2023 3. White House/EPA. Industry is exploring whether the Trump administration could provide relief. 4. Redesign stoves. Most companies are already hedging their bets by preparing to meet 2020 standards, but some are waiting to see if strategy #1, #2 and/or #3 succeeds before addressing all of their product line.

What industry needs 1. Certainty and clarity. This means having sufficient, knowledgeable staff at EPA who can handle questions in a timely way. 2. A fair playing field. Knowing that EPA will hold all manufacturers and importers to same standard. 3. Enforcement. Knowledge that there will be financial penalties for non-compliance. 4. A reasonable federal standard. Industry is fearful of states adopting different emission and/or test standards or banning sale of certain certified heaters.

Dangers to reducing wood smoke Test labs increase gaming of the system, where they find subtle ways of getting passing numbers. New loopholes emerge and are not challenged by the EPA, states or enviro groups in court. Pyrrhic victories. For example: regulating wood stoves in the US but not outdoor boilers. Lack of funding. Federal gov’t doesn’t prioritize funds to change out old stoves. State & local gov’t inaction. Unless an area is in or approaching non-attainment, many states or areas with wood smoke problems may do little to address the problem. For instance, state governments in Great Lakes regions may be more likely to protect industry than to protect their citizens’ health.

Solutions Test methods that reflect how stoves are used, including cold start & reloads & similar fuel Test labs: Verification, transparency & oversight Companies paying for testing of their products creates inherent conflicts of interest risks. Live, public streaming video and audio of certification testing is one solution More round robin testing Automated stoves need aggressive promotion Oxygen sensors and controls need to balance primary and secondary air, not the homeowner. Without automation with cordwood, pellet stoves will be only reliably clean option.

Coal stove R&D and testing EPA is now undertaking research not necessarily to regulate coal stoves but because they need to replace stoves in the Navajo reservation, where sub-bituminous coal is used. Draft a test method for coal stoves that use anthracite and sub-bituminous coal. This has just been done. Undertake emission studies on existing coal stoves in the US. This is currently being done and funded by the EPA. Solicit manufacturers to try to build cleaner coal stoves and see which ones are the cleanest. 3 stoves installed to collect data in winter of 16-17 This winter, we hope to install 20 – 40 to collect much more consumer feedback, indoor air quality data, etc.

Polish stoves available in Warsaw Directive 2009/125 / EC of the European Parliament and of the Council. Ekoprojekt refers not only to furnaces or heat pumps, but also to all wood heating stove and boilers. Effective in Poland in 2022?

2018 Wood Stove Design Challenge National Mall, Wash. DC, Nov., 2018 Technology competition on: a. automated stoves controlled by sensors b. Thermo-electric stoves making electricity up to 30 kwh for light and recharging up to 100 kwh to recharge home battery

Thank you John Ackerly – jackerly@forgreenheat.org Alliance for Green Heat Takoma Park, MD www.forgreenheat.org 301-204-9562