Proposed EPA new regs - It is not the end of the world.

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MishMouse

Minister of Fire
Hearth Supporter
Jan 18, 2008
836
Verndale, MN
For the many who posted that the new APA regulations will be the end of the world as we know it.
Here is a link: http://blog.woodstove.com/2014/03/please-sign-our-petition-for-clean.html

If a wood stove manufacture is actually pushing for these regulations it is very hard for me to believe that the new regulations will be the end to wood burning. Instead it will mean a cleaner burning more efficient stove.

One thing I really would like to see added to a woodstove is a similar setup to what BK uses, a thermostat regulated to keep the wood burning at peak efficiency. That is one of the main drawbacks of my TL-300, if things are not aligned properly the stove can and will stall creating a very unclean burn. It would be nice if a thermostat was mounted so that if it detected the stove temps stating to fall below 500::F, it opens the air to maintain a clean burn.
 
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We have signed and know of many others who have also signed.
 
I personally would not sign. The initial standards seem too strict and too quick to me. But, in any case, I doubt that signing something like this is the way to get anything done...based on thousands of similar other petitions.

I've always been an advocate for cleaner and more efficient burning - but I was there when most of the manufacturers closed down due to the first EPA standards. I'm not saying that was wrong - those standards were fair.

As many other have noted - the big problems are often the stuff that's not subject to the standards - so I'd support more $$ for changeouts as well as reasonable regs for all central heating systems (indoor and out). Efficiency doesn't mean low GPH. It means cutting down on the sum total of pollutants across the entire nation for the lowest cost (per unit of reduced emissions). If that's done by paying for a change out, it's a better result than shaving off another 1/2 gram.

When someone takes two years and monitors 100+ stoves that burn at 1.5 or yes grams per hour (EPA)......in homes...and those studies prove conclusively that stoves that meet 1.5 (example) are twice as clean as those that meet 3.0, then I'm in.

It's not the end of the world as we know it either way.
 
I personally would not sign. The initial standards seem too strict and too quick to me. But, in any case, I doubt that signing something like this is the way to get anything done...based on thousands of similar other petitions.

I've always been an advocate for cleaner and more efficient burning - but I was there when most of the manufacturers closed down due to the first EPA standards. I'm not saying that was wrong - those standards were fair.

As many other have noted - the big problems are often the stuff that's not subject to the standards - so I'd support more $$ for changeouts as well as reasonable regs for all central heating systems (indoor and out). Efficiency doesn't mean low GPH. It means cutting down on the sum total of pollutants across the entire nation for the lowest cost (per unit of reduced emissions). If that's done by paying for a change out, it's a better result than shaving off another 1/2 gram.

When someone takes two years and monitors 100+ stoves that burn at 1.5 or yes grams per hour (EPA)......in homes...and those studies prove conclusively that stoves that meet 1.5 (example) are twice as clean as those that meet 3.0, then I'm in.

It's not the end of the world as we know it either way.
Standards being fair isn't the end for the EPA when their job is to write standards.
 
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Standards being fair isn't the end for the EPA when their job is to write standards.

The first standards were written largely with direct input from our industry. The CAFE standards which tightened a few years ago were agreed upon by the automakers before they were instituted.

The EPA doesn't just go in a room and create standards. They look at all sides of the issue, including the economic ones. This doesn't mean they are always right, but I think you'd be surprised to see that most standards are actually guided by folks in the industry being regulated.

It will be interesting to see what they do. I think pellet stoves will have very few problems. But whether or not a $599 or $799 woodstove can easily be made to fit the new regs...we'd need opinions from the makers on that one. So far it appears they are saying no....it can't be done for a low price.

That's somewhat what happened the first time (in 1990). Top end stoves like the Defiant Encore were some of the first to meet the standards. So I'd say there will be a curve - the initial stoves will be expensive. Then, after a few years, they'll be mid-priced. Then - maybe many years later - low priced models may come.

But will that hurt consumers? Will that make people with old stove not upgrade? Complicated stuff.

When I had a store I liked the option of being able to offer stoves to folks who weren't very wealthy. We liked to have a stove for anyone who came in - whether they wanted to spend $399 or $2000+.

As they say, whatever will be will be. Biz is a tough road and the makers and stores and consumers will just have to adapt.
 
With 85% of exiting new stoves already meeting the first 2015 levels ,thats not a problem. 2020 levels are another story. Perhaps they could bring those standards in .in 2 stages over a longer time period. Govt and EPA should also consider how wood and pellet stoves have really saved the day (for the lucky folks that had them) during this last severe winter with the propane shortage. It sure is nice to hear this does NOT apply to existing stoves.
 
If a wood stove manufacture is actually pushing for these regulations it is very hard for me to believe that the new regulations will be the end to wood burning.

It is quite common in some industries to use this unethical technique to use the power of government regulators to squash the competition. That is what Woodstock is doing, at least in part, knowingly or not.

If I explain further, this post will go on for too long, (and I shall spare us)
 
It is quite common in some industries to use this unethical technique to use the power of government regulators to squash the competition. That is what Woodstock is doing, at least in part, knowingly or not.

If I explain further, this post will go on for too long, (and I shall spare us)

I see what you are saying and have seen it in a lot of cases...however I am fairly certain that, unless they hire a million dollar lobbyist, they are not going to have an influence on it compared to the coalitions of other forces (HPBA, Manufacturers individually, states, orgs, etc.).

Frankly, I'm surprised to see For Green Heat pushing so hard on this - especially since they have many times indicated that higher standards are not the biggest problem (old stoves are, etc.)...

But, yeah, always lots of forces pushing and pulling for their own reasons.
 
Personally I wish the environmental focus in terms of biofuels would focus on a) outdoor wood boilers, b) large scale wood chip burners and c) the wide spread use of pre epa stoves, exempt stoves for sale and exempt home built stoves as these are the main issues in terms of air quality where I am. Before they attempt to make the "clean" stoves burn cleaner ... they should work on taking care of what's the larger problem.
 
...however I am fairly certain that, unless they hire a million dollar lobbyist, they are not going to have an influence on it ....

I somewhat think you're right. But, (for me at least), this taints Woodstock. I have been on their email list for some time, and often enjoyed clicking on their blog and reading. They seem to always have happy customers. Why give up their good reputation for something that they won't influence?
 
There could be larger lobbyists influencing this. Promoting wood burning in any form is not beneficial to the fossil fuel industry. Making the EPA look bad does seem to benefit them. One will note that the EPA doesn't even recognize wood as a renewable fuel. And yet this is the fastest growing heating fuel according to the 2010 census. If they did recognize this they would be promoting better burning practices by setting MC standards for wood sellers first. Education is key here. Promote wood shed building with classes, web info, subsidized kits at big box stores, etc.. Promote clean burning with traveling classes and web info. Enforce clean burning standards by actually having field agents ticket egregious wood smoke polluters. People run stoves and fireplaces poorly because there is no consequence for doing so.
 
Some of those programs have existed in states, locales and even through the EPA...

The problem is that as administrations and times (in general) change, these things tend to get thrown out because each administration has different ideas of what they should be promoting. For a long time there was an EPA edict "no new regs", which is why OWB's have been able to avoid the standards for so long. That's why they came up with that "voluntary" thing.

Burnwise is an education program of sorts.
http://www.epa.gov/burnwise/

But, yeah, it's tough to get long term consistency and agreement on this stuff. This is doubly true when there is so much fighting within the industry itself (as illustrated by the OP, etc...regarding new regs).

I remember that when I dealt with Tarm in Denmark there was much more of a spirit of working together with the Gubment and Industry. The industry didn't infight like this.....all in the industry wanted clear regulations so they knew how to go ahead.

Our system is great in some ways - that is the "teams of rivals"...but in other ways we fall short when it comes to long term planning. As BG says, biomass is barely on the radar as a potentially clean renewable.
 
People run stoves and fireplaces poorly because there is no consequence for doing so.

I'm inclined to believe it's more often than not simply because they don't know any better, have no reason to question what they've always done, and are oblivious to the fact that there are better ways of burning...and I mean better in some ways for them, as they may well not be motivated to doing anything different if only to benefit "mankind". Yes, all the information is readily available, but you have to want to find it and read it and find it to be credible before you'll even give a thought to doing anything differently. I don't think that the Hearth.com membership is representative of the wood burning population as a whole...I think we're much better informed, more concerned about how we burn, and more open to learning new stuff. Unfortunately, we're WAY outnumbered. Rick
 
If your job is to write regulations why would you ever stop? It's the culture of the agency.

I think you said that above. Actually, I've met a few of the EPA staffers at HPBA shows and their "job" was to do the burnwise (education) and hobnob with folks like me (they link to hearth.com) and do a lot of other stuff like that - education.

The EPA doesn't sit around thinking of how they can hassle folks. It's more a matter of things like upholding the law of the land (clear air and clean water acts), etc.

It's definitely a balancing act - it usually comes down to how much death and disease you (we) want to put up with vs. maybe making a couple more bucks on a product. No doubt that's a difficult job and EPA has nothing in terms of resources compared to the forces who would rather make the bucks (and not think about the disease, poison and death).

These questions of public health have been around for thousands of years...it's why the Romans didn't crap in the road and took baths.
 
I remember that when I dealt with Tarm in Denmark there was much more of a spirit of working together with the Gubment and Industry. The industry didn't infight like this.....all in the industry wanted clear regulations so they knew how to go ahead.

Our system is great in some ways - that is the "teams of rivals"...but in other ways we fall short when it comes to long term planning.
Indeed, there appears to be a fairly contentious rivalry between the cat stove makers and the non-cats. The Jotul rep I spoke to was pretty adamant that cats don't work well which is simply false. When I mentioned that the F12 has a very loyal following and thought by some to be their best stove he just blinked like a deer in headlights.
 
I think you said that above. Actually, I've met a few of the EPA staffers at HPBA shows and their "job" was to do the burnwise (education) and hobnob with folks like me (they link to hearth.com) and do a lot of other stuff like that - education.

The EPA doesn't sit around thinking of how they can hassle folks. It's more a matter of things like upholding the law of the land (clear air and clean water acts), etc.

It's definitely a balancing act - it usually comes down to how much death and disease you (we) want to put up with vs. maybe making a couple more bucks on a product. No doubt that's a difficult job and EPA has nothing in terms of resources compared to the forces who would rather make the bucks (and not think about the disease, poison and death).

These questions of public health have been around for thousands of years...it's why the Romans didn't crap in the road and took baths.

I thought that the EPA was sued to promote cleaner wood burning standards by several states. I'll see if I can dig that clip up. From what I remember, after transportation, wood smoke was the second largest source of mutagenic air pollution. But I am not sure if that was a regional or national study. It's particularly bad in certain geographic areas prone to winter temperature inversions.

(broken link removed to http://www.cleanair.org/program/outdoor_air_pollution/biomass/greenspace_major_us_polluters_wood_burning_stoves)
 
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Yes, BG, you are correct. The EPA was sued in order to create the first standards. That's part of the way our system works. A microcosm of it is the OWB thing. Individuals complained. Then more of them. Then they wrote letters to their state (VT and elsewhere). Then they started talking about it regionally. Eventually it makes it up the chain - either as an effort pushed by the states or by an group (Sierra Club, etc.) representing a group of citizens.

As far as cats, they definitely work when new. They definitely work when properly designed and if the particular stove holds up over the years. However, as it stands today, there are no long term in-home studies I am aware of which indicate cats work better than non-cats. Unless someone can point to a number of them (hundreds of stoves), it's all guesswork.

That's the sad part about all this..with the standards. There has been no impetus for makers to finance in-field testing so they rarely have. Now we have literally millions of EPA stoves out there, but very little data on in-home performance. It seems ridiculous to, in the face of a lack of data, enter into new and very strict standards.

I guess I value common sense. It would have been nice to take two years and study a couple hundred of the newer cat and non-cat stoves in the field....and/or have a program that's going to do so with these new stoves as they come down in GPH.

There is just not enough money out there - or reason - for any party to do much of this testing. All we can do is watch and look back after a decade and see if and when they went wrong.
 
According to Chris at Blaze King there have been long term studies done by the cat manufacturer and this info is out there.
http://www.chimneysweepnews.com/Combustors.htm
Sud-Chemie posts this result for a 12 yr old cat.
[Hearth.com] Proposed EPA new regs - It is not the end of the world.
More long term info on cats:
(broken link removed)
 
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I'm talking about long terms studies on the total stove/firewood/chimney setup.

There have been studies on catalytic converters. There have also been some in-home studies of stoves. In the first one, cat stoves came out worst than non-cats because of change over time in the stoves (not always the cats, but sometimes). Example - leaking bypass, etc.

In the second or last one I think the stove came out more similarly, but again there were not enough stoves and the study was not specifically to try and sort out stove designs, rather to see the total effect.

We know from cars and other industrial processes that cat converters work. That's never been in question. In fact the very definition of a catalytic converter is that it doesn't get used up (in theory). In reality there have been substrate problems since day one - why do you think companies, 30+ years after the intro, are trying new substrates? There have been problems with the cats getting dirty or poisoned.

Add some of the problems together - a cat getting dirty and a bypass leaking and maybe homeowners not engaging correct (what if you car required you to know when to engage and disengage) and you can see why there has been concern.
Here is a 1998 study. Keep in mind that cat stoves hit the market in 1983 and by 1988 (Encore) were fairly advanced. So this is 10 years in:
(broken link removed to http://www.epa.gov/ttnchie1/ap42/ch01/related/woodstove.pdf)

A scientist came up with this as "best professional judgement".
[Hearth.com] Proposed EPA new regs - It is not the end of the world.

As you see, non-cats are even with or slightly ahead of cats. Also keep in mind that many of the stoves (cat) you see today are the exact same ones which existed them....(not true with cape cod, PH, etc.)....

Let me repeat - I'm not drawing or suggesting any conclusions here - except that in-field testing has rarely been done and, as the writer of that study said:
"Under normal use the emissions of particles from most catalytic wood stoves will increase, in some cases reaching
conventional stove levels within five years of use due to the loss of catalytic activity"
"There is currently no strong impetus to improve or test wood stove efficiency"
(referring to that emissions is the only goal, not efficiency).

To go even further, the scientist mentioned that the differences in wood species would not make a difference of quite an order of magnitude (most studies were done out west!)...Is he saying that the difference could be 5-7X (if 1/2 an order?). Or is he saying that it's 50 or 70% (less than a doubling)?

Any math whizzes can try to help me?
"the effect of wood type and wood moisture on emission factors appears to be smaller than an order of magnitude."
So if a stove put out 4g per hour....what's a change of 1/2 an order of magnitude from that?

I would love to hear about in-home tests in the midwest or northeast (where perhaps 80% of stoves are sold) comparing efficiencies. I would even like to see a paper - written by someone who's not paid by someone with commercial interests - with even a theoretical conclusion based on the combo of all available evidence.

I think there was recently an article in H&H magazine by the same author (Houck) which showed vast differences in even the same stove over various tests - not sure it was that mag, but I saw it somewhere. It was mind boggling.

This is why I am currently somewhat on the same side as those who question the new regs. Not because I don't want higher efficiency, just that I don't want a bunch of regs when the original premise is not yet proven. I'm very open to seeing actually opposing views based on the real world. It's pretty simple. You can bet that if hundreds of millions or billions were involved in real world testing, it would be done. So, why isn't it? The answer is that it's not "commercially viable".

All of the above is guesswork - as is the premise that stoves in the field perform on the same curve as their lab tests...

I'm stubborn. Prove it to me.
(P.S. - if I had to buy a stove today for 24/7 burning I would strongly consider a modern cat or hybrid, but only after much study AND- most importantly, I would know about how to run and maintain the stove. If I had to give advice to an "average" customer I'd probably tell them to go non-cat or at least to make a determination as to whether they have the skills to operate bypasses, etc. properly).

It's the age-old Mac-PC question (from long ago). Is the mac better? Is a PC better? It has changed over time, but even today more non-tech people can do more on IOS than they can on Android (and I have both).
 
Agreed, the biggest variable is the person(s) owning and running the stove. Maintenance and wood moisture seems to be the major changing factor in these tests. Interestingly, it appears that one of the cat stoves was burning cleaner in later tests.

There's a follow up commentary by one of the sweeps that had several of the Portland stoves as customers. http://www.woodheat.org/advanced-technology.html . His conclusion echos what we have said here:

With proper installation and conscientious operation, including use of covered, seasoned wood and regular service by a competent professional chimney sweep, certified woodstoves after years of use burn nearly as cleanly in the real world as they did under laboratory conditions for certification.

I would add that part of the problem is finding competent sweeps, particularly in small rural communities (where most wood burning takes place). Often there is only one sweep, frequently self-trained, and working by the seat of his pants.
 
Here is some more reading and an overview on some industry opinions on the new regs - some of these people help in the settings of them:
http://tinyurl.com/qx7u4st

Notice in the beginning of the article when they show that (non-cat) EPA stoves average a 50% reduction from non-EPA stoves. That differs vastly from figures we were quoted when I had a shop. We had been told that older stoves put out 30-50 grams per hour so the newer ones were 10X as clean. I can't remember how many times I told that to consumers!

But they are only twice as clean or 1/2 as dirty!
That's a difference from what was told of 500%. I think most folks would be shocked if their car said "50 MPG)" and then it got 10. Of course, this is just emissions so it doesn't matter much to most consumers - they are interested in efficiency. The newer stoves gave a 10-25% increase (say from 55 to 65, etc.) in efficiency, sometimes more.

FYI, none of this stuff is very new at this point. When Hearth.com first started (and in my shop) one of the most often given pieces of advice was "as long as it passes EPA standards"...as opposed to "get this stove because it puts out 1.7 grams".

Example (many of these questions are from 1996-2000)
https://www.hearth.com/talk/threads/cleanest-stove-made.97141/#post-1270585

I would give the same advice today. The chimney, wood, operator and maintenance of the stove would be a greater determination of real world performance than test-lab numbers (assuming stove passes EPA).

The great thing about hearth.com and other online resources is that we can suss out the real-world experiences in many stoves based on real owners using them. So we may be privy to things like "Stove A is great at heating up quickly and throwing out the heat - but make sure you use a damper in the chimney if you have an overdraft".

BTW, the N/C Encores and similar stoves "won" the EPA competition for lowest emissions in 2005-2007. I don't think I need to remind forum members about some of the experiences with those (search everburn on the forums). They burned hot enough to quickly self-destruct.
 
. His conclusion echos what we have said here:

With proper installation and conscientious operation, including use of covered, seasoned wood and regular service by a competent professional chimney sweep, certified woodstoves after years of use burn nearly as cleanly in the real world as they did under laboratory conditions for certification.

I would add that part of the problem is finding competent sweeps, particularly in small rural communities (where most wood burning takes place). Often there is only one sweep, frequently self-trained, and working by the seat of his pants.

I'm nitpicking again - but they virtually never burn as clean in the field as they do under lab condition. Not even nearly. That's according to the data.

Problem is - as John put it above - is that everyone has interests. Even the sweep. He's 100% right that a stove needs to be maintained. But whether it ever burns nearly as clean as the lab? That's a statement he made up (I'm in marketing so have made up hundreds of "facts" over the years!)....

When I had a shop I quoted "these stoves burn 10X as clean". Now I say they burn 2 to 3X as clean. It's not that I was lying or trying to fool anyone, I just didn't know any better. Also, I have no commercial interest (now - or even over the last 15 years) either way. Hearth.com was started for that very reason - to be independent in the consumer education. It's not perfect, but it's probably the best available (independent) source.

On another note - this proves that old "classic" stoves can be quite clean....that is, if EPA stoves are only twice as clean, the operator/chimney/wood factor can definitely make that go away.

OWB's are another story because they are surrounded by water and many have air inlets that close fairly tightly and poor chimneys, so some of the benefits of operator and chimney are lost.
 
I find the Train's a coming article's premise ambiguous. What is a pre-EPA stove, an un-baffled Fisher, or a more efficient Nashua or Haugh? They mention a 50% reduction in emissions per ton of fuel burned, but don't quantify the fuel consumption reduction due to higher efficiency. If a stove is twice as clean burning and burns 10-30% less fuel to produce the same heat then the actual emissions output is significantly less. Note that Houck's 1998 testing of stoves in VT, NY, OR, CO and Yukon seems to back this up with the conventional stove putting out about 3 times more particulate/ton than an EPA non-cat or cat stove.
[Hearth.com] Proposed EPA new regs - It is not the end of the world.
 
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PS: I got a chance to finish reading the article and appreciate the ending page conclusions. It's interesting to note how the premise of declining number of home heating with wood has reversed since it's publication according to the 2010 census data.
 
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