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Does EPA test methods hinder stove innovation?

Post in 'The Hearth Room - Wood Stoves and Fireplaces' started by John Ackerly, Feb 2, 2013.

  1. John Ackerly

    John Ackerly Member

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    Here's a question that I'm sure a bunch of you guys have insights into. Does the EPA hinder stove innovation? I get that every manufacturer has to certify their stoves using same test method, but is that really what leads to so many similar stoves in the marketplace? I also get that stoves are tested with dimensional lumber cribs - not cord wood - but that in itself can't inhibit innovation that much, can it? Would love to hear thoughts.

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  2. Slow1

    Slow1 Minister of Fire

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    I'm not so sure that I would say it hinders innovation. However I do tend to believe that optimizing to an artificial lab environment to "make the numbers" - whatever number you are aiming for - can result in decisions on the design that makes them less optimal than may otherwise might be finalized.

    Examples of this is to look at the so-called "Florida bungalow syndrome" where it seems that the fixed air input and lab environment has caused some manufacturers to create stoves that may in fact be unsafe in some installs.

    I also have discussed with one stove designer/engineer of a stove capacity being limited so that it could be tested with a given protocol rather than having to move up to the next class and then be tested with a different methodology/standard.

    In general if the testing causes changes to the design that are not directly related to the standard that you are trying to enforce then there may well be something wrong with the testing (in my opinion).

    Now - back to the question 'does this hinder innovation'; maybe. All depends on what decisions are being made and why.

    The other question of course is the cost of testing etc - I don't have first hand knowledge of the process but from what I understand it is very expensive to get a stove through EPA testing. If this is true then it is a barrier to get newer models out and likely will reduce the number of variations in the marketplace.
  3. BrotherBart

    BrotherBart Hearth.com LLC Mid-Atlantic Division Staff Member

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    I think the EPA regs cause innovation. I can think of at least four non-cat secondary burn configurations and the hybrid cat stoves coming on the market come to mind. And had not the regs come into place we would not have near the efficiency in our stoves that we enjoy now. It was a byproduct, not what the EPA was out to accomplish but they drove the technology development that produces it.

    And I doubt without the regs that pellet stoves would have ever gotten off the dime.
    corey21, jeff_t and dafattkidd like this.
  4. begreen

    begreen Mooderator Staff Member

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    Had the same thought. Clean burning is a challenge that has produced some innovative designs. With the newest generation of hybrids they seem to be getting better yet.
  5. NW Walker

    NW Walker Member

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    I'm with BB on this in that I believe the regs have pushed manufacturers to develop cleaner, more efficient stoves. I also believe the hurdles associated with bringing a new product to market due to the regs may keep some great ideas from being produced. At the same time, they probably help mitigate damage from poor designs. A bit of a double edged sword, in my opinion.
  6. NW Walker

    NW Walker Member

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    Oh, and to respond to the question of " so many similar stoves," I believe that is a function of our wood burning paradigm. We are accustomed to a fire in a metal box and for many that simply is how it's done. Therefore, that is the focus of most manufacturer's innovations.
  7. wkpoor

    wkpoor Minister of Fire

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    I agree with the posters above that the EPA was the engine driving innovation and change. However being a victim of the "Florida bungalow syndrome" myself I think there needs to be more research done into how stoves are actually performing in the field. I read an article recently raising concern about CAT stoves. It stated while they can produce the cleanest burn, only at the hands of skilled users and being properly maintained. I personally know 2 people who have CAT stoves that are basically being used as pre EPA because the CAT has been out for yrs. I also think if the EPA is serious they need to do field testing on stoves in service in the field burning cordwood. I also think getting there will require chimneys to meet a spec. Right now you buy a stove that supposedly is very clean burning under lab conditions and ideal draft. Probably a vast number of installs won't allow those stoves to perform as such.
    laynes69, corey21 and jeff_t like this.
  8. John Ackerly

    John Ackerly Member

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    I don't see how EPA can drive innovation or cleaner stoves if the last time they set regulations was 1988. Their standards of 7.5 grams an hour are obsolete. If anything, the stricter Washington state standards, of 4.5 grams an hour would be driving cleaner stove technology, but even that was set in 1995, and is not all that hard to manufacturers to meet. Someone mentioned the new hybrid stoves, which are far cleaner than what EPA requires. This seems to me to be just healthy competition to see who can make cleanest and most efficient stove and producing some pretty impressive results. EPA is now considering a minimum efficiency standard, which would require manufacturers to figure out how to meet that standard if they don't already. (Hybrids are already way more efficient than anything EPA would set.) HPBA is arguing just for reported efficiency, so no company would need to innovate more, unless they voluntarily want to become more efficient.

    Two potential problems I see with EPA test methods is that they have no way to test an automated stove, that doesn't have the adjustable air intake that can do the four burn rates required by EPA - high medium high, medium low and low. Also, why do so many stoves in Europe heat water, but none do on the US market? Once a stove got up to tempurature, would be great if it could then heat water for either your domestic hot water or for space heating.
  9. Highbeam

    Highbeam Minister of Fire

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    That's a marketing decision that has little or nothing to do with EPA regs.

    Surely there are reasons that the EPA regs have encouraged innovation but the methods of testing have also stifled innovation. My current cat stove is #2 most efficient in the world yet when it is burned at a medium-high burn rate it pollutes excessively IMO. As I understand it, particulate emissions are tested at lower burn rates where cat stoves are very clean so the high burn pollution is allowed to be high. A change in test protocol would capture this and encourage innovation. Isn't it odd that the #1 and #2 most efficient stoves in the world are decades old designs?
    StihlHead likes this.
  10. begreen

    begreen Mooderator Staff Member

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    In Europe one will rarely find forced hot air heating in a residence. Hot water heating is much more common. That presents a larger market opportunity. A water jacketed stove presents a more complex problem. Water heating would require more testing both for emissions with the water jacket functioning but also as a boiler for safety reasons. It's already very expensive to have a wood stove tested so I could see how adding a hot water system to the mix could make testing cost prohibitive for a limited market.
  11. FyreBug

    FyreBug Minister of Fire

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    Yes EPA regs forces MFG to works on innovations, but the questions that need to be asked is at what cost and for what ultimate purpose?

    The 7.6 gr rule ensured clean burning technology was now in the hands of the general public at a reasonable cost. However, EPA allowed 'EPA exempt' categories so it really wasnt a full solution. Besides the increase in efficiencies the EPA or Govt did not provide a 'cash for clunker' program to rid old smoke belchers off the market.

    MFG's would like the EPA to go to 4.5 gr/hr and change the protocol to burning seasoned hardwood to better reflect 'real life' burning similar to the Canadian CSA B415 model (also European and New-Zealand/Australia). Then progressively go tighter to allow everyone (small and large MFG to adapt)

    However, EPA is now considering lowering this to 2 g/hr or less (possibly 1) with high efficiency ratings using HHV methodology. This will mean it eliminates the vast majority of current offering off the market. Imagine the expenditure in R&D for the MFG. Ultimately it this is adopted possibly 3 or 4 MFG might stick around to provide wood burning appliances. The cost of such appliances is likely to double and triple. Would the general public willing to pay for such? A very small proportion. The rest of the populace will keep their older appliances going for much longer and establish a cottage industry of anyone owning a welding torch and some steel to make wood burners for them and their neighbors.

    So we've answered at what cost, so what is the ultimate purpose? The goal or reducing emissions is laudable in itself. New technology, methodology tighter regulations should be encouraged. However, the reason and ultimate purpose for doing so must be identified. There's enough science to know wood burning by the general public in North America is not even a drop in the bucket in emissions, pollution and particulate problem.

    Road and truck dust represent a far bigger particulate problem. Other source of emissions and pollutions are far more problematic than any wood burning presumed problem.

    So why is wood burning such a priority for EPA? Low-hanging fruit... Imagine the hullabaloo if EPA was to go after the trucking industry! It would be political suicide. Highways would be blocked and the trucking industry lobby would make sure it would be painful to any government agency to implement.

    Wood burners are a minority at the low end of the earning scale represented by a small group of MFG and small association (HPBA) with limited lobby funds.

    Hopefully saner minds will prevail and the new regulations will allow small and large appliance MFG to survive while implementing clean burning innovations.
    jotulguy and stoveguy2esw like this.
  12. BrotherBart

    BrotherBart Hearth.com LLC Mid-Atlantic Division Staff Member

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    The EPA went after the trucking industry starting in 1971. Long before they turned toward wood stoves. Millions of trucks had to be retrofitted with "smoke kits" to cut down on smoke and emissions. I know. I was in the business then.
  13. pdxdave

    pdxdave Member

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    As a whole the regulations have and will drive innovation and efficiency. However there certainly are individual circumstances where user friendliness, and perhaps real-world efficiency will be hindered by the need to produce the lab results. This would be a more an issue with the testing procedure itself, rather than the end goals of the regulation.
  14. FyreBug

    FyreBug Minister of Fire

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    Ah but you've just proved the point...

    EPA regulation for trucking was done 42 years ago. I'm not picking on the trucking industry just using it as an example. A large lobby such as they would not just take the bitter medicine without at least some consultation.

    EPA is wanting to force new regulation and bypass the industry. This will have a negative effect on all concerned and for what purpose?
  15. begreen

    begreen Mooderator Staff Member

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    Wood smoke can be the primary pollutant on some days locally. It is an issue in many locations. It depends on the location, meteorology and geography. The Puget Sound region gets frequent temperature inversions. It's like a big valley between two mountain ranges. You can see and smell when wood smoke is getting overwhelming. And not just in one neighborhood. Areas like Denver, Boulder, Seattle, Libby, Mont. etc. are natural smoke traps. When there are a lot of smoke dragons churning out smoke in these areas during a temperature inversion, you know it. The health effects are known and documented.True this is not the only source of particulate pollution, but it is an easily identifiable one. There are a lot more people in our area than 20 yrs ago. As the population density increases, the need for tighter control of pollutants is going to be necessary.

    Note that they are also continuing to raise the bar for the trucking industry and recently here, the marine industry. Big freighters burning bunker oil really smoke it up when passing through the sound. If we don't keep the air clean we all pay the bill sooner or later.

    http://www.woodstovechangeout.org/fileadmin/PDF/Libby_Report-Final.pdf
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  16. BrotherBart

    BrotherBart Hearth.com LLC Mid-Atlantic Division Staff Member

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    Updated truck rules were published in 1997, 2000 and 2001. But this ain't trucking.com. Subject for another place.
  17. Huntindog1

    Huntindog1 Minister of Fire

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    I think the EPA Test method is not consistent, I see stoves that are built basically the same with much different test results.

    Plus grams of emissions dont seem to align with efficiency ratings.

    I dont think the grams of emissions should be used as a efficiency rating. As some manufactures imply.

    Efficiency should be a rating of how much heat you get into the room of the Wood Load.

    I know the EPA test is made to be consistent but the results seem to be all over the board with stoves of the same basic designs.
  18. begreen

    begreen Mooderator Staff Member

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    Pretty much old skewl thinking there. Most modern cars are vastly safer than the cars of a few decades ago in spite of weight reduction. Better engineering is a good thing. A clean running Tesla will smoke the doors off of any heavy iron vehicle one can buy. Even a stock Honda Accord EX will out run the original 389 GTO (0-60 in 6.1 sec. vs 6.8 for the '64 GTO).
    TradEddie likes this.
  19. PLAYS WITH FIRE

    PLAYS WITH FIRE Minister of Fire

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    I was, for awhile, and am still involved in chip tuning European cars. The way we make power is by leaning out the fuel delivery, advancing timing, and increasing boost pressure for simplicity sake .In most cases there is 30-45 percent addition in power from just chip tuning! Do this under normal driving conditions has made each car more efficient. So the lean burn technology is where it's at, smaller engine, higher compression ratio, turbo charged, very lean mixtures, and more hp/tq per cylinder. It does come at a cost. That's gas!

    Diesel on the other hand is a different animal, indeed!
    We love the VW TDI, particularly the pre 2006 models! Lots of extra power can be made with simple software tweeks with the addition of several mpg increase. The post 2006 versions are made with a Diesel Particular Filter. On the VW they work and they work well! The problem is with the addition of all the filters to reduce emissions the affect on longevity and reliability of the the car later. I bought mine with the 2 mentioned concerns as a benefit. Mine is post epa regulations.

    So I guess my point is in the wood burning area the epa is a great thing as long as what is needed does not take away from the longevity of the stove. Anything you do to increase the efficiency of the stove has to be good right?
  20. Slow1

    Slow1 Minister of Fire

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    I have to argue the point here that the EPA is/should be in the business of protecting the environment. Efficiency of the stove really is a byproduct of the efforts as far as I can tell. I haven't seen the EPA come out talking about how many cords of wood their standards have saved after all.

    Now, if we look at a non-epa stove running as a stereotypical "smoke dragon" then it is fouling up the air with a bunch of partially consumed fuel. Compare that to a "modern EPA stove" running clean and you have reduced the emissions (helping air quality) and as these emissions are largely burned up, you have an increase in efficiency. This is a win-win situation in my opinion. Likely much of the improvement could arguably be a result of better burning practices (dry wood etc) as the EPA stove is going to be less forgiving and thus perhaps compliance may be up, but the basic stove technology makes it easier to get the most out of the stove.

    However - I just don't think there is much more "efficiency" to be gained in taking the last few g/hr of emissions out of the smoke stack. Perhaps it will help the environment (no expert there) but I'm doubtful that it will make as great a difference. So what is to be gained in tightening the emissions standards further? Just how much better can they get and at what cost? Perhaps this will lead to innovations to get there, but under the current standards I don't see how it will net a gain for the environment.

    Perhaps instead of creating the incentive for stove manufacturers to eek out that last bit of theoretical/ideal burn emissions reduction there should be some way of creating an incentive to make it easier to burn well and/or know when you are not doing so. I.e. make it so that the stove of the future will burn clean even with a lazy burner who tries to just toss wood in there and walk away. This of course is a difficult thing to do and even harder to create a lab test for, but that (combined with getting older stoves retired) is more likely to make a material difference.

    "Measure what you wish to achieve" - if you ask for lowest emissions then perhaps you will get optimized on that. Ask for stoves that burn clean in a wider range of conditions and measure based on 'real' results then perhaps you will get that.
    FyreBug likes this.
  21. Huntindog1

    Huntindog1 Minister of Fire

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    slow1, I think you are right why pay a bunch of extra money to eek out just a little more performance. Money is better spent in make the stove easier to operate like automated controls.

    I think some of the stoves with lower grams of emissions are not actually burning more efficiently as their burn times are not all that better. I think the geometry of the firebox and maybe the smoke exit path knocks alot of the particulates from escaping up the flue.

    It would be nice if the NC-30 published their efficiency number besides its grams emissions number.

    But if your stove is 76 percent efficient or 80 percent efficient you most likely not going to be able to tell a difference. So why pay big bucks for something you can not notice.
  22. PLAYS WITH FIRE

    PLAYS WITH FIRE Minister of Fire

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    I don't want to sound like I am not environmentally conscientious, cause I'm not;-) I was talking about the ability to make the stove 98% efficient as opposed to 78% i wasn't talking the emissions.

    My first statement I was kind of kidding.
  23. Huntindog1

    Huntindog1 Minister of Fire

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    How much would a stove cost thats 98% efficient?

    I think mid to upper 80's is the best that they are gonna be able to do and be affordable.
  24. Slow1

    Slow1 Minister of Fire

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    When it comes to efficiency numbers I really wonder about the math/science behind those too - the FV and PH are not listed as being all that different in efficiency, yet I am confident that we're getting more heat from about the same wood. If I ever get around to really analyzing the data I've collected over the years I may be able to make a better case than just "it seems warmer for the amount of wood we've burned". However we've burned less wood than 2 years ago (last winter was such an anomaly it hardly counts for much) and the house has been warmer. No oil burned yet this year.

    So - perhaps the efficiency rating test should be modified in some way to reflect how much useful heat hits the room. Somehow I don't think this is being done now.
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  25. PLAYS WITH FIRE

    PLAYS WITH FIRE Minister of Fire

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    I agree, I was just giving an example. Now that I think about it, I am not sure if the epa needs to push the mfgs to make the most efficient product they can. I think the mfgs already do the best they can to develop and distribute the best and most affordable products to us.
    I wise man told me to not trip over dollars chasing pennies. Maybe this there philosophy too. Maybe till some space age products become cheaper too.

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