EPA drops cordwood testing qualification

[begreen]

The EPA just dropped the cordwood testing allowance for new stoves and has reverted to the stricter crib wood testing standards.

EPA reverts to stricter wood stove testing

Wood stove, pellet stove, NSPS, EPA, PM, grams per hour, efficiency, LHV, HHV, cleanest, best, carbon neutral, biomass, tax credit, IRS, certified

forgreenheat.blogspot.com

 

[cabinwarmer]

Good Day, will this effect the 75% HHV tax credit at all?

 

[begreen]

Good Day, will this effect the 75% HHV tax credit at all?

It will affect testing for some models.

 

[cabinwarmer]

If looking to buy before the next burn season (fall 2022) - does one wait to be sure the unit supports the tax credit?

 

[mellow]

By withdrawing those methods, the majority of stoves will have to be retested over the next 5 years with a different method, an expensive and time-intensive process for manufacturers. Normally, the EPA rubber-stamps waivers from retesting for stove certifications every 5 years, and manufacturers have come to expect that, potentially allowing them to sell the same model for decades based on the original certification testing.

The EPA will honor certification tests using ALT-125 or ALT-127 completed prior to Feb. 23, 2022, the effective date for withdrawal of these alternative test methods. The EPA released details of the withdrawal were released Jan. 21 and will appear in the Federal Register on Jan. 24, 2022.

 

[begreen]

I don't think it would be an issue, but I just learned of this an hour ago. It seems to affect all stoves tested after Feb 23, 2022. However, it will affect stovemakers that tested by cordwood standards using ALT-125 or ALT-127 when the stove is due for recertification after 5 yrs. This is not an uncontroversial move, as the article points out.

 

[cabinwarmer]

Yes, agree, read through the article. Thanks for posting it. I was just wondering and trying to avoid, a purchase in 7/22, turn in your tax credit, and by 5/23 your tax request is denied. Looks like there may be a small chance the happens.

 

[wjohn]

Definitely interesting. As an example, of the stoves in the smaller size range I was looking at the VC Aspen C3 tested with crib wood. The Morso 2B Standard, the Jotul F 602 V2, and the USS/Vogelzang 1120 all tested with cord wood.

Looks like the True North TN-10 also tested with crib wood but I did not look at that as there were none locally. Oddly enough the USS/Vogelzang 1269E cheap little cast stove also tested with crib wood, even though the rest of the smaller USS products were tested with cord wood.

I wonder what impacts re-testing with crib wood will have on the HHVs and emissions of the stoves that were tested with coord wood. The article seems to indicate it may make things harder. The F 602 V2, for example, passed with 2.1 g/hr for emissions on cord wood (and at a 70% HHV). They'll have to get under 2 g/hr. My bets are the Morso 2B has plenty of room to make it under 2 with .55 g/hr emissions (and 80% HHV, for reference).

 

[snobuilder]

The EPA’s move is part of a multi-year trend of EPA relying more on the expertise and data developed by air quality groups, and less on the expertise and data from the main industry association, the Hearth, Patio and Barbecue Association (HPBA). The EPA appears to have been approving alternative methods before they have been used to certify stove models based on the work of the stakeholder group that wants the approval of the test method.

Extreme
Pain(in the)
Ass

 

[bholler]

The EPA’s move is part of a multi-year trend of EPA relying more on the expertise and data developed by air quality groups, and less on the expertise and data from the main industry association, the Hearth, Patio and Barbecue Association (HPBA). The EPA appears to have been approving alternative methods before they have been used to certify stove models based on the work of the stakeholder group that wants the approval of the test method.

Extreme
Pain(in the)
Ass

Can you give us your opinion on which is a better test method crib or chord wood and why?

 

[snobuilder]

Check with Tom Morrissey. I would suspect he comes here for your advise as well, no?

 

[bholler]

Check with Tom Morrissey. I would suspect he comes here for your advise as well, no?

So no actual opinion on the issue?

 

[bholler]

Btw Tom is a great guy and I will gladly have that discussion with him next time I see him.

 

[snobuilder]

Maybe refer me to your opinion where you may have disagreed with cord wood method and why.

 

[snobuilder]

Btw Tom is a great guy and I will gladly have that discussion with him next time I see him.

I barely know him but I think I'm on his side.

 

[bholler]

I barely know him but I think I'm on his side.

So which is a better testing method and why?

 

[bholler]

Maybe refer me to your opinion where you may have disagreed with cord wood method and why.

What does my opinion have to do with it? I asked yours

 

[snobuilder]

So you sit as an expert in the field and questioning my comments leads me to believe that this new method is where you feel the testing should have been all along or is there another reason you want to pin me down in yet another harrassing post?

I never claimed to be an expert. My comment clearly is in opposition central government over regulation and in this case throwing another curve ball at private manufacturing who are trying incredibly hard to comply with such over regulation. I will always stand on the side of free commerce without interference from special interest groups who clearly are also NOT experts in the field but feel they should control the private sector. You seem to be all for more central control.

 

[bholler]

So you sit as an expert in the field and questioning my comments leads me to believe that this new method is where you feel the testing should have been all along or is there another reason you want to pin me down in yet another harrassing post?

I never claimed to be an expert. My comment clearly is in opposition central government over regulation and in this case throwing another curve ball at private manufacturing who are trying incredibly hard to comply with such over regulation. I will always stand on the side of free commerce without interference from special interest groups who clearly are also NOT experts in the field but feel they should control the private sector. You seem to be all for more central control.

I am just asking you to discuss the topic at hand instead of yet another blind EPA and anything to do with it is bad statement.

But I will give my opinion. Cord wood testing is a far better representation of real world use than crib wood. But it is also more inconsistent.

I never agreed with having the option of either test it should have always been one or the other. And due to the fact that crib wood testing is more consistent that should have been the one used in my opinion. But I completely agree changing it at this point is very unfair.

 

[EbS-P]

I think the variabiliy of cordwood is just too much when the standard is now much lower. Just the increased surface area of a split piece of wood would have an effect on the emissions in the first 20 minutes or so.

reading the letter (Ok I skimmed the last 5 pages) that Tom wrote and my past knowledge of the Alaska review and adding this new epa statemen ,my impressions are of a regulating body that didn’t try very hard in the past to create a truly repeatable standard Test. I’m going to admit it seems difficult. Getting some bad PR from the Alaskan report now trying to scramble and quickly come up with something. We really need them to get this one right. Any doubt will give local authorities justification to just ban wood burning all together. “ we don’t know how clean that or any stove is. NO STOVE FOR YOU!”

Relying on just one test with one fuel is a step but as Tom points out, it’s a useless step if it’s not taken transparently.

want to reduce wood pollution. prioritize home efficiency. Less wood burned = less pollution.

 

[begreen]

Yes, agree, read through the article. Thanks for posting it. I was just wondering and trying to avoid, a purchase in 7/22, turn in your tax credit, and by 5/23 your tax request is denied. Looks like there may be a small chance the happens.

If the stove was tested before 2/23/22 and certified, then its certification should be good for 5 yrs.

 

[stoveliker]

The flipflopping by the EPA here is painful in particular because it's clear their decisions are influenced by lobbying groups. Whether it is the manufacturers or the environmental groups (which do not necessarily always oppose each other, btw).

Though the irregularities uncovered in Alaska do call into question the appropriateness of the cordwood testing procedure..

 

[begreen]

I think the variabiliy of cordwood is just too much when the standard is now much lower. Just the increased surface area of a split piece of wood would have an effect on the emissions in the first 20 minutes or so.

reading the letter (Ok I skimmed the last 5 pages) that Tom wrote and my past knowledge of the Alaska review and adding this new epa statemen ,my impressions are of a regulating body that didn’t try very hard in the past to create a truly repeatable standard Test. I’m going to admit it seems difficult. Getting some bad PR from the Alaskan report now trying to scramble and quickly come up with something. We really need them to get this one right. Any doubt will give local authorities justification to just ban wood burning all together. “ we don’t know how clean that or any stove is. NO STOVE FOR YOU!”

Relying on just one test with one fuel is a step but as Tom points out, it’s a useless step if it’s not taken transparently.

want to reduce wood pollution. prioritize home efficiency. Less wood burned = less pollution.

The EPA dropped the ball by not setting clearly defined reporting criteria for the lab tests. What the Alaska review pointed out is the same thing that bugged me about the 2020 lab reports. In some you could find specifics on the stove, like the actual usable firebox volume, clearly presented at the beginning of the report in the stove specifications. In other lab reports it might be hand-scrawled in an addendum. And in many reports it was not recorded at all. The EPA did not catch this. Their bad. A consistent style guide provided by the EPA would helped a lot here. One should be able to read a report from any lab for any stove and find a consistent layout for the report with all pertinent info provided.

 

[BKVP]

Just found this...

The EPA granted the ATM based upon the ASTM 3053. The group working for years on the ASTM 3053 included state, regional, Federal air regulators, test labs and a select few manufacturers. I was part of that committee and attended 100% of the meetings.

Subsequent to the State of Alaska raising concerns about the method, industry began working late last year with EPA to refine and address any shortcoming identified by ADEC (Alaska). You see ASTM methods are consensus based are therefore able to be improved upon.

Industry has 95 cordwood tested and certified wood heaters and 60 or so M28R crib fuel certifications. Industry manufacturers spent right at $2.5M certifying those 95 heaters. What's at stake, not the tax credits, because they are based upon the official test report efficiencies.

What is really at stake, 7 years of data, very costly data, that was to be part of the FRM development. Without data, credible data, the FRM is delayed even further.

M28R was never intended to represent real world emissions numbers. It was developed to remove as many variables as possible so that when a consumer looks at stove specifications they are as closely as possible represented across the product category.

I was an ardent opponent of having more than one method! Confusion in the market place is already compounded by marketing messages. Adding additional variability was not and will never be what's best for the consumer.

Now, all the manufacturers will test to M25R. So, we return to square one. Most unfortunate because industry was open to suggested improvements of the method and still are. However, after having the rug pulled out from you, it's hard to buy in again to another ATM. EPA has acknowledged this challenge going forward.

Lastly, I want to clarify the point about certifications. EPA did nothing wrong. They are conducting an internal audit and if they finding any shortcomings they will address them.

When a manufacturer tests a stove, a test report is generated. As part of the request for certification, manufacturers, test labs and third party certifiers all attest with signatures, the test report in honest and complete. EPA's office of Enforcement & Compliance's job is to verify that all those signatures are in place as required by law. We are a manufacturer. We had a few i's not dotted and a few t's not crossed in our test reports. That is OUR FAULT and the lab and the third party certifiers. NOT EPA.

The real upshot of this is most of the "deficiencies" identified by EPA mean nothing to the airshed. Certainly there were a handful that were related to fuel loading protocols, fuel orientation etc., but there are no data to suggest these even effected emissions.

Each of you should read the comments filed during the 2015 EPA promulgation. Many of these factors and possibilities were identified prior to the rule going final.

Manufacturer certificates are valid for 5 years. EPA can, when asked, elect to extend the expiration date in for another 5 years. Basically a renewal. However, they are making it clear that any such certificates issued for the Cordwood ATM's will not be renewed.

About 6 of them will expire this year, 20+ next year etc, until all 95 have expired.

Thanks for the opportunity to provide additional clarity on this subject.

BKVP

 

[snobuilder]

Just found this...

The EPA granted the ATM based upon the ASTM 3053. The group working for years on the ASTM 3053 included state, regional, Federal air regulators, test labs and a select few manufacturers. I was part of that committee and attended 100% of the meetings.

Subsequent to the State of Alaska raising concerns about the method, industry began working late last year with EPA to refine and address any shortcoming identified by ADEC (Alaska). You see ASTM methods are consensus based are therefore able to be improved upon.

Industry has 95 cordwood tested and certified wood heaters and 60 or so M28R crib fuel certifications. Industry manufacturers spent right at $2.5M certifying those 95 heaters. What's at stake, not the tax credits, because they are based upon the official test report efficiencies.

What is really at stake, 7 years of data, very costly data, that was to be part of the FRM development. Without data, credible data, the FRM is delayed even further.

M28R was never intended to represent real world emissions numbers. It was developed to remove as many variables as possible so that when a consumer looks at stove specifications they are as closely as possible represented across the product category.

I was an ardent opponent of having more than one method! Confusion in the market place is already compounded by marketing messages. Adding additional variability was not and will never be what's best for the consumer.

Now, all the manufacturers will test to M25R. So, we return to square one. Most unfortunate because industry was open to suggested improvements of the method and still are. However, after having the rug pulled out from you, it's hard to buy in again to another ATM. EPA has acknowledged this challenge going forward.

Lastly, I want to clarify the point about certifications. EPA did nothing wrong. They are conducting an internal audit and if they finding any shortcomings they will address them.

When a manufacturer tests a stove, a test report is generated. As part of the request for certification, manufacturers, test labs and third party certifiers all attest with signatures, the test report in honest and complete. EPA's office of Enforcement & Compliance's job is to verify that all those signatures are in place as required by law. We are a manufacturer. We had a few i's not dotted and a few t's not crossed in our test reports. That is OUR FAULT and the lab and the third party certifiers. NOT EPA.

The real upshot of this is most of the "deficiencies" identified by EPA mean nothing to the airshed. Certainly there were a handful that were related to fuel loading protocols, fuel orientation etc., but there are no data to suggest these even effected emissions.

Each of you should read the comments filed during the 2015 EPA promulgation. Many of these factors and possibilities were identified prior to the rule going final.

Manufacturer certificates are valid for 5 years. EPA can, when asked, elect to extend the expiration date in for another 5 years. Basically a renewal. However, they are making it clear that any such certificates issued for the Cordwood ATM's will not be renewed.

About 6 of them will expire this year, 20+ next year etc, until all 95 have expired.

Thanks for the opportunity to provide additional clarity on this subject.

BKVP

Just a few questions. I realize you manufacturers are compliant based on keeping your companies in business.

Can a stove company simply build non compliant with EPA standards stoves or does each manny have to build a certain percentage in compliance with the EPA standards?
What is a federal air regulator?
What's up with AK and why is that where this all started?
Would you be testing these stoves to EPA standards without the EPA ?

Wood stoves were around way before an EPA existed and will be here long after unless they outlaw my torch and welder.
Sincerely,
A. Bubba.