EPA-450J2-92-002 

TECHNICAL INFORIMATION DOCUMENT 

FOR RESIDENTIAL WOOD COMBUSTION 

BEST AVAILABLE CONTROL MEASURES 

U.S. Environmental ProtE:ction Agency 

Office of Air and Radiation 

Office of Air Quality Planni.ng and Standards 

~ Research Triangle Park, North Carolina 27711 

September 1992 
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0 Disclaimer 

This document reflects'the lates•t information that the 

Environmental Protection Agency (EPA) has obtained on measures 

for control of residential wood combustion. As additional 

information becomes.available, the document will be updated, as 

approp'riate. Mention of trade names or commercial products is 

not intended to constitute endorsemen't or recommendation for use. 

Copies 

Copies of this document are available through the Library 

Services Office (MD-35), U.S. Environmental Protection Agency, 

Research Triangle Park, North Carolina 27711; or, for a fee, from 

the National Technical Information Services, 5285 Port Royal 

Road, Springfield, Virginia 22161. .. 

ii September 1992 
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C:ONTENTS 

~ Section paae 

1.0 Introduction . . . . . . . . . . . . . . . ... . . . . 1-1 

1.1 Purpose of Document . . . . . . . . . . . . . . . 1-1 

1.2 Statutory Background . . . . . . . . . . . . . 1-2 

1.2.1 Designations . . . . . . . . . . . . . . . 1-2 

1.2.1 Classifications . .. . . . . . . . . . 1-2 

1.2.3 Serious Area Attainment Dates ...... 1-4 

1.2.4 Key Serious Area SIP Requirements .... 1-4 

1.2.5 RACM and BACM Issuanc:e . . . , . . . . . 1-5 

1.3 Document Organization . . . . . . . . . . . . . . 1-6 

1.3.1 Available Control Measures for RWC BACM . 1-6 

1.3.2 RWC BACM Economic Feasibility Methodology 1-7 

2.0 Integral Measures Available for FtWC BACM. .... . 2-1 

2.1 Public Awareness and Education . , , . . . . . . 2-1 

2.1.1 Program Effectiveness and Tracking .... 2-2 

2.1.2 Key Public Awareness and Educatiori 

~ Program Elements . . . 2-2 

2.1.3 Communication Strategy 

: : : : : : : : ~ : 

2-3 

2.2 Mandatory Curtailment Program . . . . . . . . 2-3 

„ 2.2.1 Public Awareriess. . . . . . . . . . . . . 2-4 

2.2.2 Forecasting and Predi.ction . . . . . . . . 2-4 

2.2.3 Public Notifi.cation . . . . . . . . . . . 2-5 

2.2.4 Exemptions . . . . . . . . . . . . . . . 2-5 

2.2.5 Enforcement . . . . . . . . . . . . . . 2-6 

2 . 2 . 6 Tracking . . . . . . - . . . . . . . . . . . 2-7 

2.3 Measures to Improve Wood Burning Performance .. 2-7 

2.3.1 Control of Wood Moisture Content ..... 2-7 

2.3.2 Weatherization of Homes with Wood Stoves . 2-8 

2.3.3 Educational Opacity Program . . < . . . . 2-9 

2.4 A11 New Wood Stove Installations EPA-Certified, 

Phase II Stoves or E.quivalent . . . . . . . . . . 2-10 

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seOtion Pacre 

3.0 Flexible Measures Available for RWC BACM . ..... 3-1 ~ 

3.1 Emissions Reduction or;Elimination - 

Existing Installation « . . . . . . . . . . . . . 3-1 ` 

3.1.1 Conversion of Existing Wood Burning 

Fireplaces to Gas Logs . . . . . . . . . 3-1 

3.1.2 Changeover to EPA-Certified Phase II 

Stoves or Equivalent . . . . . . . . . 3-3 

3.1.3 Changeover to Lqw-emitting Devices ... 3-5 

3.2 Emission Reduction or tmission Increase 

Prevention -- New Installations . . . . . . . . 3-6 

3.2.1 Gas Fireplaces or Gas Logs for New 

Wood-Burning Fireplace Installation . . . 3-6 

3.2.2 Upgrade Offset . . . . . . . . . . . . . 3-6 

3.2.3 Restriction on Number a'nd Density of 

New Wood-Burning Stove and/or Fireplace 

Installations , . . . . . . . . . . . 3-8 

3.2.4 Requirement that New Wood Stove 

Installations be Low-Emitting . . . . . . 3-9 

3.3 Emissions Reduction -- New and Existing 

Wood Stove Installation,s . . . . . . . . . . . 3-9 ~ 

3.3.1 Device Offset . . . . . . . . . . . . . 3-10 

3.3.2 Upgrade Offset ; . . . . . . . . . . . . . 3-11 

4.0 RWC BACM Economic Feasibility Methodology ...... 4-1 

4.1 Introduction . . . . . . . . . . . . . . . . . 4-1 

4.2 Integral Measures . . . . . . . . . . . . . . . 4-1 

4.2.1 Public Awareness and Education ...... 4-1 

4.2.2 Mandatory Curtailment Program ...... 4-2 

4.2.3 Measures to Improve Wood 

Burning Performance . . . . . . . . . 4-7 

4.2.3.1 Control of Wood Moisture Content 4-7 

4.2.3.2 Weatherization of Homes 

with Wood Stoves . . . . . . . . 4-8 

4.2.3.3 Educational Opacity Program ... 4-9 

4.2.4 A11 New Wood Stove Installations EPACertified, Phase'II Stoves or Equivalent . 4-10 

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Section Pa e 

4.3 Flexible Available Measures . . . . . . . . . . 4-12 

4.3.1 Emissions Reduction or Elimination - 

Existing Installations . . . . . . . . . . 4-12 

4.4.1.1 Conversion of Existing Wood Burning 

Fireplaces to Gas Logs . . . . . -4-12 

4.3.1.2 Changeover to EPA-Certified Phase II 

Stoves or Equ.ivalent . . . . . 4-15 

4.3.1.3 Changeover to Low-emitting 

Devices . . . .

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. . . . . . . . . 4-17 

4.3.2 Emission Reduction or Emission Increase 

Prevention --- New Installations . . . . . 4-20 

4.3.2.1 Gas F'ireplaces or Gas Logs for New 

Wood-Burning Fireplace 

Installations .: . . . . . . . . 4-20 

4.3.2.2 Upgrade Offset . . . . . . . . 4-23 

4.3.2.3 Restr•iction on Number and Density of 

New Wood Burning Stove and/or Fireplace 

Installations . . . . . . . . . . 4-25 

4.3.2.4 Requirement that New Wood Stove 

Installations be Low Emitting .. 4-33 

4.3.3 Emissions Reduction --'New and Existing 

Wood Stove Installations . . . . . . . . . 4-36 

4.3.3.1 Device Offset . . . . . . . . . . 4-36 

4.3.3.2 Upgrade Offset . . . . . . . . . 4-39 

APPENDIX A RWC BACM Task Force Membership ...... A-1 

APPENDIX B Methodology for Calculating Device 

and Upgrade Offset Ra- tios . . . . . . . . B-1 

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TABLE 

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Table No. page 

1=1 Measures Available for RWC BACM ..... 1-8 

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01 
SECTION 1.0 

INTRODUCTION 

1.1 PURPOSE OF THIS DOCUMENT 

The purpose of this document is to provide technical 

information for the development of best available control 

measure (BACM) strategies for residential wood combustion 

(RWC) in areas that are designated serious nonattainment for. 

PM-10 (particles with an aerodynamic diameter less than or 

equal to a nominal 10 micrometers). The information is needed 

by States to develop control strategies for their serious 

~ PM-10 nonattainment area State-implEamentation plan (SIP) 

submittals. 

Note that while the guidance presented herein lists 

available measures which the Envirorimental Protection Agency 

(EPA) is recommending as BACM, and is intended to be 

comprehensive, it is by no means exYiaustive. It also does not 

establish any binding requirements. Consequently, the State 

is encouraged to consider other sources of information and is 

not precluded from selecting other measures and demonstrating 

to the public and EPA that -they constitute BACM. 

1.2 STATUTORY BACKGROUND 

1.2.1Designations 

Section 107(d) of the Clean Air Act (Act), as amended in 

1990, provides generaily for the descignation of w__:.3: of each 

State as attainment, nonattainment cir unclassifiable for each 

~ pollutant for which there is a national ambient air quality 

1-1 1 September 1992 
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standard (NAAQS). Certain areas meeting the qualifications of 

section 107(d)(4)(B) of the amended Act were designated ~ 

nonattainment for PM-10 by ope;ration of law upon enactment of 

the 1990 Amendments to the Act;(initial PM-10 nonattainment ~ 

areas). A Federal Register notice announcing all of the areas 

designated nonattainment for PM-10 at enactment and classified 

as moderate was published on March 15, 1991 (56 FR 11101). A 

follow-up notice correcting some of these area designations 

was published August 8, 1991 ($6 FR 37654). The boundaries of 

the nonattainment areas were formally codified in 40 CFR 

Part 81, effective January 6, 1992 (56 FR 56694, November 6, 

1991). A11 those areas of the country not designated 

nonattainment for PM-10 at enactment were designated 

unclassifiable [see section 107(d)(4)(B?(iii) of the amended 

Act]. 

1.2.2 Classif_ications 

Once an area is designated nonattainment, section 188 ~ 

outlines the process for class ~ fication of the area. In 

accordance with section 188(a),: at the time of designation, 

all PM-10 nonattainment areas are initially classified as 

moderate by operation of law. ;A moderate area can 

subsequently be reclassified as a serious nonattainment area 

under two general conditions. °First, EPA has general 

discretion under section 188(b),(1) to reclassify a moderate 

area as a serious area at any time the Administrator of EPA 

determines the area cannot practicably attain the NAAQS by the 

statutory attainment date for moderate areas. Second, under 

section 188(b)(2) a moderate ar,ea is reclassified as serious 

by operation of law after the s'tatutory attainment date has 

passed if the Administrator finds that the area has not 

attained the NAAQS. The EPA must publish a Federal Register 

notice identifying the areas that have failed to attain and 

were reclassified, within 6 months following the attainment 

date [see section 188(b)(2)(B)]. ~ 

1-*2 September 1992 
Section 188(b)(1)(A) mandates an accelerated schedule by 

~ which EPA is to reclassify appropriate initial PM-10 

nonattainment areas. The EPA proposed on November 21, 1991 

(56 FR 58656) to reclassify 14 of t:he 70 initial moderate• 

areas as serious. The final decisi.on to reclassify the areas 

proposed will be based on the criteria utilized in the 

proposal, comments received in responss to the proposal and on 

information in the moderate area SI:P's that were due on 

November 15, 1991 for each of the a:reas. 

In the future, EPA anticipates that, generally, any 

proposal-to reclassify an initial PM-10 nonattainment area 

before the attainment date will be based on the State's 

demonstration that the NAAQS cannot practicably be attained in 

the area by December 31, 1994 [the statutory attainment date 

specified in section 188(c)(1) for initial PM-10 nonattainment 

areas]. 

In addition to EPA's general authority under section 

~ 188(b)(1) to reclassify as serious any area the Administrator 

determines cannot practicably attain the PM-10 NAAQS by the 

applicable date, for areas designated nonattainment for PM-10 

subsequent to enactment of the 1990 Amendments, subparagraph 

(B) of section 188(b)(1) mandates that appropriate areas are 

to be reClassified as serious within 18 months after the 

required date for the State's submission of a moderate area 

SIP. 1Taken together with the statutory requirement that PM10 SIP's are due within 18 months after an area is designated 

nonattainment [see section 189(a)(2)(B)], the statute thus 

requires that EPA reclassif`y appropriate moderate areas as 

serious within 3 years of the nonattainment designation. 

Any decision by EPA to reclassify such.a future 

nonattainment area as serious will be based on facts specific 

1This directive does not restrict EPA's general authority 

but simply specifies that i.t must be exercised, as 

~ appropriate, in accordance with certain dates. 

1-3 - September 1992 
to the nonattainment • area at issue and will only be made after 

providing notice in the Federal Reaister and an opportunity ~ 

for public comment on the basis for EPA's proposed decision. 

1.2.3 Serious Area Attainment Dates 

The amended Act specifies'that the initial moderate 

nonattainment areas (those des; ignated nonattainment upon 

• enactment of the 1990 Amendments) reclassified to serious are 

to attain the PM-10 NAAQS as expeditiously as practicable but 

no later than December 31, 2001. Areas designated 

nonattainment subsequent to enectment that are reclassified as 

serious must attain the PM-10 NAAQS as expeditiously as 

practicable but not later than°the end of the tenth calendar 

year after the area's designation as nonattainment ~ [see 

section 188(c)(2)]. 

1.2.4 Key Serious Area SIP Reguirements 

As discussed above, States must develop and submit SIP's 

providing for the attainment ot the PM-10 NAAQS for every area ~ 

designated nonattainment and classified as moderate or serious 

for PM-10 under the amended Act. New revisions must be made 

to the PM-10 SIP in accordance with section 189(b) of the 

amended Act for areas that are'reclassified as serious 

nonattainment areas. First, provisions must be adopted to 

assure that BACM (including BAGT) will be implemented in the 

area [see section 189(b)(1)(B)I. Second, a demonstration 

(including air quality modeling) must be submitted showing 

that the plan will attain the NAAQS either by the applicable 

attainment date or, if an extension is granted under section 

188(e), by the most expeditious alternative date practicable 

[see section 189(b)(1)(A)]. 

The SIP revisions to require the use of BACM must be 

submitted to EPA within 18 months after an area is 

reclassified as serious [see section 189(b)(2)]. The BACM are 

1.-4 September 1992 

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to be implemented no later than 4 years after an area is 

~ reclassified [see section 189(b)(1)(B)]. 

The serious area attai.nment demonstration required under 

section 189(b)(1)(A) must be submitted to EPA within 4 years 

after an area is reclassifi.ed based on a determination by EPA 

that the area cannot practi.cably at.tain by the statutory 

deadline for moderate areas. It is due within 18 months after 

an area is reclassified for actually having failed to attain 

by the moderate area attainment date [see section 189(b)(2.)]. 

1.2.5RACM and BACM Issuance 

Section 1.90 of the amended Act requires EPA to issue 

technical guidance for RACM and BACM no later than 18 months 

from enactment of the 1990 Amendments to the Act for three PM10 source categories: urban fugitive dust, RWC, and 

prescribed silvicultural and agricultural burning. In 

conjunction with publication of the "General Preamble for 

~ Title I of the Clean Air Act Amendments of 1990," EPA 

discharged the section 190 requirement to issue RACM technical 

guidance for each of these three source categories [57 FR 

13541, April 16, 1992; 57 F'R 18070, April 28, 1992]. The 

General Preamble provides a policy for how to utilize the 

available RACM technical guidance to• develop area-specific 

RACM strategies. For RWC, the available RACM technical 

guidance cited is the exist.ing RWC control measure document 

issued by EPA in September 1989, "Guidance Document for 

Residential Wood Combustion Emission Control Measures" 

(referred to as "RWC Guidance Document" in this document, see 

Ref. 1). As frequently suggested in this document, the 1989 

RWC document should be consulted for background information on 

the available measures described in this document. 

The issuance of this RWC BACM technical guidance document 

. (and its fugitive dust and prescribed burning companion:. 

documents), together with•EPA's previous issuance of RACM 

~ technical guidance, wholly fulfills EPA's statutory obligation 

1-5 September 1992 
to issue RACM and BACM technic,al guidance for urban fugitive 

dust, RWC, and prescribed silv,icultural and agricultural ~ 

burning under section 190 of the amended Act. Similar to the 

manner in which EPA provided guidance on Act requirements 

applicable to moderate PM-10 nonattainment areas in the 

General Preamble, including a policy or how to utilize the 

RACM technical guidance documents, the EPA is planning to 

provide guidance on Act requirements and provisions applicable 

to serious PM-10 nonattainmentiareas, including BACM, in an 

addendum to the General Preamble. [EPA made a draft of the 

addendum available for public comment on July 16, 1992 (57 FR 

31477).] The portion of the addendum that addresses BACM 

provides a policy for how to utilize today's RWC BACM 

.. 

technical guidance (and.companion technical guidance for 

control of fugitive dust and prescribed burning) to develop 

area-specific BACM strategies.. 

The information contained;in this document was obtained, 

in large part, from the input and expertise of a task force 

• assembled in December 1990. The task force met several times ~ 

in 1991 and consisted of representatives from Federal, State, 

and local agencies involved in the control of residential wood 

combustion (see Appendix A). 

The measures described,in this document represent what 

the task force believes are the most effective measures for 

controlling PM-10 from RWC. Thus, not all the measures 

described in the 1989 "RWC Guidance Document" are included in 

this document because the task'; force.did not regard them as 

"most effective." 

1.3 DOCUMENT ORGANIZATION 

1.3.1 Available Control Measures for RWC BACM 

The available neasures for RWC BACM recommended in th 

document are divided into two types (see Table 1-1 bp'_oGt)r 

integral measures in column A and flexible measures in 

col.umns B-D. The suggested int.egral measures are measures 

1'-6 SeP tember 1992 ~ 
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that are -regarded as critic.alfor the success of RWC control 

~ programs in PM-10 nonattainment areas. The integral measures, 

though, are not, by themselves, intended to ensure long-term 

attainment of PM- 10 NAAQS by serious areas. These measures 

are described in section 2.0 of this document. 

The flexible measures (described in section 3.0 of this 

document) are intended'to provide for long-term attainment of 

the PM-10 NAAQS and reduce the need for short-term episodic 

controls. The flexible measures are listed in three 

categories (columns B-D of Tarle 1-1): (1) Measures That 

Reduce or Eliminate Emissions From Existing Installations, 

(2) Measures That Reduce Emissions or Prevent Emission 

Increases From New Installations, and--(3,) Measures that Reduce 

Emissions From New and Existing Installations. The measures 

are listed in the categories only to show what emissions they 

impact and not because this guidance recommends serious areas 

adopt a certain measure or measures per se from each column. 

~ 1.3.2 RWC BACM Economic Feasibilit y Methodology 

Section 4.0.provides a methodology that the implementing 

or lead planning agency should employ to assess the economic 

. feasibility of the available measures described in 

sections 2.0 and 3.0. The methodology consists of an approach 

for estimating the emissions reductions and costs associated 

with each measure. 

1-7 September 1992 
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TABLE 1-1. MEASURES AVAILABLE FOR RWC BACM 

A B C D 

FLEXIBLE FLEXIBLE FLEXIBLE 

INTEGRAL MEASURES MEASURES THAT REDUCE OR MEASURES THAT REDUCE MEASURES THAT REDUCE 

ELIMINATE EMISSIONS EMISSIONS OR PREVENT EMISSIONS FROM NEW AND 

FROM EXISTING INSTALLATIONS EMISSION INCREASES FROM NEN EXISTING 

INSTALLATIONS INSTALLATIONS 

1. Public awareness and 1. Conversion of existing 1. Gas fireplaces or gas 1. Device offset. 

education. wood-burning fireplaces logs in new wood 

to gas logs. burning fireplace 2. Upgrade offset. 

2. Mandatory curtailment installations. 

~ during predicted 2. Changeover to EPA- 

~ periods of high PM-10 certified, Phase II 2. Upgrade offset. 

.._ _ - 

concentrattons. _ __. - - -- . . _. stoves or eqwva ent, _ - - - 

3. Restriction on number 

3. All new stove 3. Changeover to low and density of new 

installations EPA- emitting stoves. wood-burning stove 

certified, Phase II and/or fireplace 

stoves or equivatent. installations. ~ 

4. Measures to improve 4. Requirement that new 

wood burning stove installations 

performance: be low emitting. 

- control of wood 

moisture content 

- weatherization of 

homes with wood 

stoves 

- educational opacity 

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~ References 

1. U.S. Environmental Protection Agency, GuideTine Series. 

"Guidance Document for Residential Wood Combust_ion 

Emission Control Measures." E:PA-4-50/2-89-915. September 

1989. 

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SECTION 2.0 

INTEGRAL MEASURES AVAILABLE FOR RESIDENTIAL 

WOOD COMBUSTION BACM 

This section provides guidance: on the suggested integral 

measures for RWC BACM. The.measures are regarded as critical \ 

for the success of RWC con#.rol programs. The measures, 

however, are not intended, by themselves, to result in longterm attainment of the PM-].O NAAQS for serious PM-10 

nonattainment areas. 

A background discussion of each of the - integral BACM 

~ measures is avai.lable in the EPA "RWC Guidance - Document." The 

following subsections explain the purpose of each integral 

measure and recommend an effective strategy for their 

implementation. 

2.1 PUBLIC AWARENESS AND EDUCATION 

As the "RWC Guidance Document" explains, public awareness 

and education (PAE) is crit:ical for the success of RWC 

emission control programs. The BACM PAE program should serve 

to i.nform the public about the RWC control program, (including 

program operational details, program justification and citizen 

responsibilities); and persuade and convince them to meet 

their responsibilities under the RWC control program. 

The PAE program should address the following three areas: 

• Program Effectiveness and Tracking; 

• Key PAE Program Elements; and 

• Communication Strategy. 

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Section 2 of the "RWC Guidance Document" provides details on 

existing PAE programs. ~ 

2.1.1 Program Effectiveness and Trackinq 

The PAE program should be designed to educate the public 

effectively on the reason for 'controlling RWC emissions, as 

well as on the mechanics of coxitrolling these emissions. The 

PAE program should also be tailored to the community's 

attitudes toward wood heating, their wood burning habits and 

patterns, and the extent and nature of the air quality 

problem. This information sholuld be obtained by conducting a 

survey of the community's residents. The survey's findings 

should give implementing or lead planiling agency officials an 

indication of how to tailor the PAE program to the community. 

Tn addition, a follow-up survey should be conducted to 

assess the effectiveness of the PAE program on the parameters 

measured in the initial survey'and to adjust the.program 

accordingly as necessary. Additional a.nformation on assessing ~ 

public attitudes and program effectiveness are provided xn 

sections 2.1, 2.4, and 2.5 of the "RWC Guidance Document." 

k 

2.1.2 K,ey Fub ic Awareness and Education Proqram Elements 

The local implementing or ~ lead planning agency should k provide sufficient resources a4d staff to develop a PAE 

program that educates the public about: 

k • the health risks of wood smoke; 

• proper wood-burning operation and maintenance; 

• relevant State, loca]. and EPA regulations; 

• heating fuels and practice; and 

• avai.lable stove types, including their relative 

"in-home" field testing emissions for PM-10 and 

relative efficiencies. 

More information°on•-PAE program elements is contained in 

section 2.2 of the "RWC Guidance Document." 

. ~ 

2-2 September 1992 
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2.1.3Communication Stratec,ty 

~ In a PAE program, the I.ocal implementing or lead planning 

agency should provide suffic:ient resources and staff to 

communicate the PAE elements, to the public through all three 

types of inedia: print, broadcast, a.nd public contact. 

(Section 2.3 of the "RWC Guidance Document" discusses each of 

these media at length.) An effective PAE program should 

include: (1) extensive public contact through events such as 

stove fairs and school assemblies; (2) the use of print media, 

including newspaper and broc:hures; and (3) the use of public 

service announcements for ra.dio and television. specific 

detail on a"High Level of Effort" PAE program is contained in 

section 2.4.3 of the "RWC Guidance Document." 

2.2 MANDATORY CURTAILMENT PROGRAM 

The purpose of wood smoke-curtailment programs is to 

restrict wood burning during periods when atmospheric 

~ conditions and the level of wood burning activity result in 

ambient concentrations of wood smoke in excess of the NAAQS 

for PM-10. The curtailment program should include the 

following components: 

• Public Awareness; 

• Forecasting and Prediction; 

• Public Notification; 

• Exemptions; 

• Enforcement; and 

• Tracking. 

The curtailment program should be implemented in a staged 

fashion, where the wood burning restrictions are less severe 

at lower predicted PM-10 concentrations. The implementing or 

lead planning agency administering the curtailment program 

should establish a two-stage curtailment program with two 

action points for determining when to call for restrictions on 

wood burning. One action point should trigger the 

~ implementation of Stage I voluntary curtailment (or mandatory 

2-3 September 1992 
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with exemptions) and the other`should trigger Stage II 

mandatory curtailment (with onl)( low-income exemptions). 0 

This guidance does not prescribe specific action points 

for a BAC'M curtailment program'. The action points selected, 

though, should be low enough to provide for attainment of the 

PM-10 NA.AQS and the Stage I action point should be lower than 

the Stage II. Table 5-2 of tht,"RWC Guidance Document" 

presents several sets of action points which are part of 

existing RWC curtailment programs and section 5 of the 

"RWC Guidance Document" provides details on establishing 

wood-burning curtailment programs. 

2.2.1 Public Awareness - 

The implementing or lead planning agency should conduct 

an ongoing public awareness program to educate the public on 

the elements discussed in section 5.1.3.1 of the "RWC Guidance 

Document," which includes the health threat of wood smoke and 

how the RWC control program will function. Those elements 

should be communicated to the public in three formats. One, ~ 

the implementing or lead planning agency should have staff and 

resources available to answer questions and disseminate 

information on these elements. Two, the implementing or lead 

planning agency should have mechanisms for mass media 

communication which include issuing frequent press releases 

and purchasing time on local radio and TV stations for public 

service announcements. And, three, personal public contact 

should also be established and maintained through, for 

example, town meetings and local school presentations. 

2.2.2 Porecasting and Prediction 

The purpose of this component is to establish the 

capabilities to predict when hi€gh PM-10 concentrations will 

occur so that.the implementing or lead planning agency can* 

call a curtailment ban when necessary to avert a potential 

NAAQS exceedance. To be able te predict NAAQS exceedances, ~ 

2-4 r September 1992 
~ the implementing or lead planning agency should have access to 

a meteorologist who has local forecasting capabilities and 

should have a negotiated agreement with the National Weather 

Service or other qualified entity to provide timely 

information-on meteorological conditions. In addition, the 

implementing or lead plann:ing agency should have ready-access 

to real-time air quality data via t:elemetry. During the wood 

burning season, both the forecasting information and 

monitoring data should be available 24-hours per day. 

2.2.3Public Notification 

This component concerns the mi.nimum requirements for 

notifying the public that a curtail.ment'ban is in effect. The 

implementing or lead planning agenc:y should have the ability 

to notify the media prompt:Ly in the event that curtailment is 

required, and,.if necessary, the resources to pay for media 

announcements to ensure adequate notification. The 

~ implementing or lead planning agency should - provide sufficient 

notice of the ban to allow burners time to shut down before 

the ban goes into effect. A 24-hou.r hot-line should be 

created with recorded messages on current curtailment 

activities and requirements. Notification should be made via 

all three public information media (as described in 

section 5.2 of the "RWC Guidance Document"). 

2.2.4Exemptions 

In Stage I, the implementing or lead planning agency 

should allow exemptions for EPA-certified stoves or 

2-5 September 1992 
equivalent, lwood stoves at reSidences where wood combustion 

is the°sole source of heat, and wood stoves in low-income ~ 

households, . In Stage II, exemptions should be limited to low 

income households, but not for houses where wood is sole 

source of heat. 

The implementing or lead planning agency should have a 

mechanism in place for publicizing the need to apply for an 

exemption and sufficient staff and resources to process and 

maintain exemption records. Wood burners requesting any 

exemption should be required to swear to their status (as it 

qualifies them for an exemption) in an affidavit and permit 

their premises to be inspected.toverify their status. 

Exemptions for sole-source wood burners should be sunsetted 

after a reasonable period of ti.me. ' 

2.2.5 Enforcement 

The purpose of this component is to ensure compliance 

wi.ththe curtailment program. The implementing or lead 

planning agency should commit to maintaining a curtailment ~ 

enforcement plan and resources;to ensure compliance during 

Stage II curtailment. Table 5-9 of the "RWC Guidance 

Document" discusses the necessary elements for an effective _ 

mandatory curtailment enforcement program. Table 5-7 of the 

"RWC Guidance Document" also c4ntains reported effectiveness 

1Equivalent is defined as RWC.devices for which "in-home" 

field testing data are available, document emissions equivalent 

to or less than "in-home" field,test emissions of EPAcertified, Phase II stoves. See memorandum clarifying nature 

of RWC guidance and describing procedure for entities seeking 

emission reduction credit for RWC devices not certified by EPA 

but which can demonstrate comparable or lower emissions through 

field testing.. Process includes consultation with..EPA's Office 

of Research and Development•on•appropriate in-use testing 

methods and procedures (Ref. 1),. For examnle, EPA has recently 

reviewed in-home field.data-for.c.ertain masonry.stoves tested 

during the 1991/92 heating season and has accepted the 

resultant emissions data for use in SIP-related activiti.es 

( Ref . 2). 

f ~ 2~-6 September 1992 
~ levels for curtailment programs achieved in practice as high 

as 90 percent. 

2.2.6 Tracking 

The tracking component measures how effective the 

curtailment program is at achieving compliance. The 

implementing or,lead planning agency should commit to 

conducting periodic tracking studies to determine the level of 

compliance with the burn ban. A statistically-valid method 

should be used for conducting field compliance tracking 

surveys of RWC users and there should be periodic evaluations 

of the forecasting method. Lastly, reporting and record 

keeping should be required to obtain 3ata on enforcement 

efforts and on the number of burn ban days called. 

2.3 MEASURES TO IMPROVE WOOD BURNING PERFORMANCE 

The recommended integral measures should include measures 

~ to reduce wood smoke emissions from RWC through improving wood 

burning operation and maintenance practices and modifying wood 

burning conditions. These include: 

• controlling wood moisture content; 

• weatherizing homes that contain RWC devices;'and 

• establishing an opacity limit program. 

2.3.1Control of Wood Moisture Content 

The purpose of this measure is to promote the burning of 

drier wood in wood stoves and fireplaces to reduce PM-10 

emissions. Its main thrust should be educational. The 

implementing or lead planning agency should educate the public 

on the benefits for the wood burner and the community's air 

quality of . burning - only-. well-seasoned-, . dry wood-. To achieve 

this goal, moisture-content checks should be available to the 

public at convenient locations duri-ng"convenient hours. 

Educational materials should also be made available that (1) 

~ describe proper wood splitting and storage techniques to 

2-7 September 1992 
' L 

ensure wood i.s properly seasoned before burning, and (2) 

provide information on the benefits of burning hardwoods ~ 

versus softwoods (i.e., greater heat content, etc.). j. 

In addition, if wood sold by wood dealers does not have 

sufficient time to "dry-out" before the heating season (i.e., 

if it is sold, for instance, in the fall), then the program 

should require wood dealers to"have their wood "certified" for 

moisture content prior to sale , to ensure the wood can be 

properly seasoned before burnirig. Upon request, the dealer 

should then present the certificate of moisture content to 

consumers purchasing wood to verify the wood is dry enough to 

be burned. Fines should"be imposed on'wood dealers who sell 

wood that is not certified. 

Section 3.5.2 of the "RWC Guidance•Document" provides 

more detail on measures limiting wood moisture content, 

includirq examples of existing wood moisture ordinances. 

2.3.2 Weatherization of Homes t,rith Wood Stoves 

The purpose of the weatherization program is to improve ~ 

the energy efficiencies of homes burning wood in stoves for 

heat so that less wood is burned and, hence, PM-10 emissions 

are lower. Under a weatherization program, the implementing 

or lead planning agency should explain to the public the 

rationale for improving the ene rgy efficiency of wood-burning i

' homes by making the public aware that energy-efficient homes 

require less wood and hence reduced fuel costs for the 

homeowner. 

Energy audits should be arranged by the implementing or 

lead planning agency or performed itself. Low-income homes 

would probably have the greatest need for weatherization and 

hence should be the focus of a financial incentive program. - 

Financial incentives could include low-interest loans, cash 

grants, and tax credits. 

Discussion of weatherization is provided in section 3.6 

of the "RWC Guidance Document.", ~ 

2-w8 September 1992 
2.3.3 Educational Opacitv Proaram 

~ The goal of this measure is to identify RWC device 

operation and maintenance habits th.at contribute to visible 

emissions of wood smoke and to correct the problem. The 

implementing or lead planni.ng agency should first educate the 

public that visible emissions are an indicator of completeness 

of burn and then send opaci.ty inspectors to the field to 

perform opacity readings of chimneys. 2Wood burners of homes 

with high opacity should be targeted for education and 

consultation to determine aind eliminate the cause of the 

visible emissions. In addi.tion, a consultation with a 

qualified chimney sweep should be required to educate the high 

opacity wood burner on proper wood stbve operation and 

mai.ntenance and examine the: wood burners' stove and flue 

systems. The consultation should include tips such as an 

"acid wash" that is available to clean clogged catalysts and 

hence extend their lives. 

~ Repeat opacity violators who do not correct the source of 

the high visible emissions after consultation and 

recommendations on how to correct the problem should be 

required to attend a class on how to operate and maintain a 

wood stove properly. More information on this measure is 

contained in section 3.7 of the "RWC Guidance Document." 

2 Since the intent of this measure is corrective and not 

punitive, the document does not prescribe specific opacity 

~ reading methods and procedures or opacity limits but leaves 

that flexibility to the imp:Lementincr or lead planning agency. 

2-9 " September 1992 
2.4 ALL NEW WOOD STOVE INSTAL'LATIONS3EPA-CERTIFIED, 

PIiASE II STOVES OR EQUIVALENT ~ 

This integral measure recbmmends that stoves not be 

allowed to be installed which are (1) not certified by EPA to 

Phase II emission limits or (2) cannot document (through 

"in-home" field testing data) emissions equivalent to or less 

than "in-home" field test emissions of EPA-certified Phase II 

° stoves. 4The intent of this requirement is to prevent the 

sale or resale and installation of non-EPA-certif ied stoves 

and the resale and installation of used EPA-certified Phase I 

stoves. The program should require that when homeowners 

intend to install a new or used wood stove, they file a form 

with the implementing or lead planning agency and swear in an 

affidavit that the stove is EPA-certified to Phase II emission 

limits. The implementing or lead planning agency should be 

responsible for processing the!forms and affidavits and 

checking the brand name of the'proposed stove installation 

 against a list of EPA-certified, Phase II stoves (and their ~ 

equl.valents). Properly trained and qualified inspecti.on 

personnel should conduct randoni surveys of stoves in homes to 

confirm compliance. 

The implementing or lead planning agency should make the 

public aware of the requirement for stove certification, the 

3New installations should include both "brand-new" stoves 

and fireplaces and "new-used" units (i.e., newly purchased 

units that are not "brand-new") r 

4See memorandum clarifying.nature of RWC guidance and 

describing procedure for entities seeking emission reduction 

credit for RWC devices not certified by EPA but which can 

demonstrate comparable or lower;emissions through field 

testing. Process includes consultation with.EP.A:s 0ffice of. - 

Research and Development_on appropriate in-use testing methods 

and procedures (Ref. 1). For example, EPA has recert1 ~

+ 

~ 

reviewed in-home field data f-or- certain masonry taves.-tested ~ 

during the 1991/92 heating season and has accepted the 

resultant emissions data for use in SIP-related activities ~ 

( Ref . 2). 

2-r10 September 1992 
• ~~: " - 

need to file a form and affidavit, and which stove types are 

~ certified. The local building code should also be modified to 

prohibit the installation of non-EPA-certified, Phase II 

stoves. A11 installations should be performed by trained and 

certified installers to en.sure the performance of the new 

stove (see section 3.3 of the "RWC Guidance Document'!.for a 

discussion of installation quality assurance). 

Discussion of this integral measure is provided in 

section 3.2.3 of the "RWC Guidance Document." 

2-11 September 1992 
~ 

•i 

01 
l 

~ References 

1. Memorandum. Renner, F'red H., Acting Chief, 

S02 /Particulate Matter• Programs Branch, Air Quality 

Management Division,'Office of Air Quality Planning and 

Standards, U.S. Environmental Protection Agency, Research 

Triangle Park, North Carolina, to Chief, Air Branch, 

Regions I-X, U.S. Environmental Protection Agency. 

"Interpretation of EPA,'s Guidance for Residential Wood 

Combustion Emission Control Measures." September 23, 

1991. 

2. U.S. Environmental Protection Agency, Office of Air 

Quality Planning and Standards, Compilation of Air 

Pollutant Emission Factors (AP -42 Research Triangle 

Park, North Carolina (masonry stove data to be 

published). 

._ 

• 

2-12 September 1992 
• 

'J 

•i 

•i 
, , 

SECTION 3.0 

FLEXIBLE MEASURES AVAILABLE FOR RESIDENTIAL 

WOOD COMBUSTION BACM 

This section provides guidance on the flexible available 

measures that are designed to provi.de „permanent control of RWC 

emissions and hence long-term attai.nment of the PM-10 NAAQS. 

As with section 2.0, a background discussion of each oaf the 

measures described in this section are available in the "RWC 

Guidance Document." The following sections discuss the 

purpose of the flexible measures and effective implementatiori 

~ strategies. 

3.1 EMISSIONS REDUCTION OR ELIMINATION - EXISTING 

INSTALLATIONS 

This section discusses the measures that result iri an 

emission reduction or elimination of emissions from existing 

stove -and fireplace instal]_ations. 

3.1.1Conversion of Existing..Wood-•Burning Fireplaces to Gas 

Loas 

This measure eliminates wood smoke emissions from 

existing fireplaces by requiring conversion to °fgas log"-type 

fireplaces that use.either.natural.or propane gas.. As 

indicated in section 4.1.2 of the 1 °RWC Guidance Document," 

gas-los fireplaces are.commonly used to replace.wood 

combustion in both zero clearance and masonry types of wood- 

~ burning fireplaces. 

3-1 September.1992 
The implementing or lead planning agency should establish 

a conversion deadline and publicize the requirement to the ~ 

community. The conversi.on process should be accelerated by 

requiring conversion following ~itransfer of real estate or releasing of a rental unit. Before the new homeowner or renter 

can obtain municipal services,',the homeowner or landlord 

, 

should be required to file a form with the implementing or 

lead planning agency indicating whether any wood-burning 

fireplaces are located in the home. If so, then the homeowner 

or landlord should be required`to have the home inspected to 

verify, within a certain period of time after the re-lease or 

transfer, that the fireplace has been converted or the flue 

sealed. ,. 

For homes not transferred or re-leased prior to the 

conversi.on deadline, the implementing or lead planning agency 

should encourage the homeowner or landlord to file for an 

exemption if no wood-burning fi'replace are present or to have 

the premises inspected to verify conversion or seal of flue. ~ 

As an incentive for homeowners or landlords to file for an 

exemption or submit to an inspe'ction, the implementing or lead 

planning agency should add a"noncompliance fee" to a k municipal service bill. To havje the fee removed, the 

homeowner or landlord should have to comply with the 

conversion requirements. The noncompliance period should be 

reasonable in length but not so long as to prevent the area 

from meeting any control strategy implementation dates and 

other milestones required under the amended Act. 

After a certain period of time, the fee should expire and 

it should become a violation of'the law to operate a woodburning fireplace. The implementing or lead planning agency 

should then follow-up with random surveys of homes by properly 

trained and qualified personnel'to ensure compliance. 

In addition, the fireplace'conversicn should be enforced 

as well through a zero percent opacity limit for those homes 

required to convert. By requesting forms and affidavits to ~ 

3-2 ' September 1992 
ti 

,~. 

verify conversions, the implementing or lead planning agency 

~ should have an accurate i.nventory of the homes subject to the 

zero percent op.acity limit. 

3.1.2 Changeover to EPA-Certified Phase II Stoves or• 

Equivalent 

This measure reduces emissions from existing wood stoves 

by accelerating the replacement of conventionall stoves with 

EPA-certified, Phase II stoves or equivalent 2 . New 

installations should include both 'Fbrand-new" stoves and 

fireplaces and "new-used" units (i..e., newly purchased units 

that are not "brand new"). Sectiori 3.4 of the "RWC Guidance 

Document" discusses the advanced desitjn and technology stoves 

available and the mechanisms areas have'used to achieve stove 

changeover. 

The implementing or lead planning agency should establish 

a conversion deadline and publicize the requirement to the 

~ community. The conversion process should be accelerated by 

requiring conversion upon transfer of real estate or releasing of rental units. Before the homeowner can close on a 

lAny stove that is not EPA-certified that burns cord wood 

should be included as stoves to be converted, except for woodburning stoves that document (through "in-home" field testing) 

emissions equivalent to or lower than the "in-home," field test 

emissions of EPA-certified, Phase II stoves (see footnote 2). 

2 Equivalent is defined as RWC cievices for which "in-home" 

field testing data are available that document emissions 

equivalent to or less than "in-home" field test emissions of 

EPA-certified, Phase II stoves. See memorandum clarifying 

nature of RWC guidance and describizig procedure for entities 

seeking emission reduction credit for RWC devices not certified 

by EPA but which can demonstrate cornparable or lower emissions 

through field testing. Process inc]Ludes consultation with 

EPA's Office of Research and Development on appropriate in-use 

testing methods and procedures (Ref. 1). For Pxample, EPA has 

recently reviewed in-home field data-for certain masonry stoves 

tested during the 1991/92 heating season and has accepted the 

~ resultant emissions data for use in SIP-related activities 

(Ref. 2). 

3-3 September 1992 
real esttate transfer or a landlord re-lease a rental unit, the 

home should be inspected to ve;rify either removal of the ~ 

conventional stove and sealing,of flue or installation of an 

• EPA-certified, Phase II stove or equivalent. The conventional 

stove should be surrendered to the implementing or lead 

planning agency or its agent to be destroyed in a manner in 

accordance with any Federal, State, or local laws governing 

disposal of hazardous or potentially hazardous substances 

(i.e., creosote). The homeowner or landlord can file for an 

exemption from the changeover requirement (i.e., swear in an 

affidavit that the residence ccntains no wood stoves) and thus 

be freed from the inspection requirement. A11 installations 

should be performed by a trained and certified installer to 

enhance the emissions performance of the new stove (see 

section 3.3 of the "RWC Guidance Document" provides 

information on installation quality assurance). 

For homes not transferredior re-leased prior to the 

conversion, the implementing or lead planning agency should, ~ 

encourage the homeowner or landlord to file for an exemption 

or have the premises inspected prior to the conversion , . . . , 

deadline. As an incentive to obtain early compliance, the 

implementing or lead planning agency should add a 

"noncompliance fee" to a municipal service fee. To have the 

fee removed, the h.omeowner should have to comply with the 

conversion requirements. The raoncompliance period should be 

reasonable in length but not so long as to prevent the area 

from meeting any control strategy implementation dates and 

other milestones required under the amended Act. 

After a certain period of time, the fee should expire and 

it should then become a violation of the law to operate a nonEPA-certified stove-within the nonattainment area. The 

implementing or lead planning agency should then follow-up 

with random surveys of .homes by -trained and qualified 

personnel to ensure compliance. In addition, the implementing 

3 1-4 September 1992 
13h ~ 

~ or lead planning agency cari enhance: enforcement of the 

changeout through an opacity limit program. 

Sections 3.4.5 and 3.4.6 of the "RWC Guidance Document" 

b • 

discuss accelerated changeover reqLiirements and inducements. 

3.1.3Changeover to Low-Emittina Devices 

This measure is virtually identical to the changeover 

measure described above in section 4.1.2, except that the 

changeover is recommended t:o a"low-emitting" device 

(EPA-certified or otherwise:) that can document "in-home" field 

test emissions less than the emission factor averages of "inhome" field test emissions data for EPA-certified stoves_(Ref. 

2). This can include classes of devices that are demonstrated 

to be capable as a class of producing lower field emissions, 

as well as specific model units that perform better in the 

field than the class collectively. 

Key elements of the measure are the same as the 

~ EPA-certified, Phase II stove changeover measure and include a 

changeover deadline, a conversion acceleration vehicle, a 

conversion deadline, a survey of affected homes to ensure 

compliance, and, for further enforcement, the use of an 

opacity limit program. The conventional or non-EPA-certified 

stoves should be surrendered to the implementing or lead 

planning agency or its agen.t to be destroyed in a manner in 

accordance with any Federal, State, or local laws governing 

disposal of hazardous or potentially hazardous substances 

(i.e., creosote). Finally, all installations should be 

performed by trained and certified installers to ensure the 

performance of the new stove (see section 3.3 of the "RWC 

Guidance Document" for a discussion of installation quality 

assurance). 

3-5 September 1992 
3.2 EMISSION REDUCTION OR EMISSION INCREASE PREVENTION -- NEW 

INSTALLATIONS3 ~ 

This section discusses the measures that can be 

undertaken by a implementing ar lead planning agency to reduce 

emissions or to prevent emissions increases resulting from the 

growth of new stove or fireplace installations: 

3.2.1 Gas Fireplaces or Gas Logs for New Wood-Burning 

Fireplace Installations 

The purpose of this measure is to eliminate wood smoke 

emissions from new wood-burnini~ fireplace installations by 

requiring an alternate fuel, natural gas, or propane. Under 

this measure, the implementing'or lead planning agency should 

establish a regulatory requirement that'allows only gas 

fireplaces or gas logs in new fireplace installation in either 

new or existing housing units and educates builders, 

developers, and homeowners about the restriction. 

When the premises are inspected for conformity with the ~ 

buildi.ngcode, the building inspector.should specifically 

inspect the fireplace units to ensure they are only either 

natural gas or propane-fired, not wood burning. Any fireplace 

in violation of the regulation would have to be converted 

before the builder or homeowner could receive an approval from 

~ the building department that the dwelling complies with the 

building code. Section 4.2 of.the "RWC Guidance Document" 

discusses some existing RWC control program limit new RWC 

devices. 

3.2.2U,pgrade Offset 

The purpose of this measure is to prevent emission 

increases from new stove installations by requiring enough 

3New installations should 'include both "brand-new" stoves 

and fireplaces and "new-used" units (i.e., newly-purchased 

units that are not "brand new")'. 

0 

3-6 September 1992 
~ 

~ existing conventional stoves to be upgraded to offset any 

increase in emissions resulting from the proposed installation 

of new EPA-certified, Phase II stoves or equivalent 4 . The 

ratio of upgrades to new stoves should be based on the 

relative emissions of the devices as reflected in the emission 

reduction credits discusse<i in Appendix F of the "RWC,Guidance 

Document" as updated (see Appendix B). 

Key elements of this measure a.re an aff idavit 

requirement, a permit or rESgistration system, installation 

quality assurance, and enforcement activity. The implementing 

or lead planning agency should require that the existing stove 

owner participating in the transaction surrender the old 

conventional stove to the :implementin4 or lead planning agency 

or its agent to be destroyed in a mannet in accordance with 

any Federal, State, or loc<31 laws governing disposal of 

hazardous or potentially hazardous substances (i.e., creosote) 

and register or file a perinit for t.he new stove. For the new 

~ stove owner, the implementing or lead planning agency should 

require a permit or registration form verifying.participation 

in the program. The transaction should be overseen by the 

implementing or lead planning agency to ensure that it is bona 

fide. In addition, the implementing or lead planning agency 

should require that the installation be performed by a trained 

and certified installer (se:e section 3.3 of the "RWC Guidance 

4 Equivalent is defined as RWC devices for which "in-home" 

field testing data are available that document emissions 

equivalent to or less than "in-home" field test emissions of 

EPA-certified, Phase II stoves. See memorandum clarifying 

nature of RWC guidance and describizig procedure for entities 

seeking emission reduction credit for RWC devices not certified 

by EPA but which can demonstrate comparable or lower emissions 

through field testing. Process includes,consiiltation with 

EPA's Office of Research and Development on appropriate in-use 

testing methods and procedures (Ref. 1). For example, EPA has 

- recently.reviewed in-home field - data for certain masonry stoves 

tested during the 1991/92 heating se§Lson and has accepted the 

~ resultant emissions data for use in SIP-related activities 

(Ref. 2) . 

3-7 ' September 1992 
Document" provides information on installation quality 

assurance). ~ 

3.2.3 Restriction on Number and DensitY of New Wood-Burning 

S,tove andfor Fireplace Installations 

The purpose of this measure is to limit RWC emissions 

growth by restricting the number and density of new RWC device 

• installations--stove and firepflace--in new and existing 

housing units. Under this measure, the implementing or lead 

planning agency should establish a building code requirement 

restricting both the number and types of new RWC devices. The 

implementing or lead planning 'agency should inform builders, 

developers, and homeowners of !this requirement to prevent 

%nstallations in violation of the regulation. 

This provision should require that stove and fireplace 

dealers provide an evidence of`sale form to the implementing 

or lead planning agency for ea'ch stove and fireplace purchased 

and that information on stove and fireplace restrictions be 

made available to the purchaser at the time of purchase. The ~ 

dealers should provide the evidence . of sale forms to the 

agency in a timely manner and the agency should enforce the 

requirement through a system of warnings and fines. The 

stoves should also be installed by a trained and certified 

installer (see section 3.3 of the "RWC Guidance Document" for 

information on installation quality assurance). 

Upon receiving a record-of-sale form, the implementing or 

lead planning agency should inform the homeowner of the stove 

or fireplace installation number and density restrictions. To 

~ install the new stove or fireplace, the builder or homeowner 

should have to file a registration form or permit with the 

implementing or lead planning agency and obtain building code 

approval. 

3-8 September 1992 
~. 

~ 3.2.4Requirement that New Wood Stove fnstallations be LowEmittinq 

This measure limits RTn1C emissions growth by requiring 

that all new installations be low-emitting stoves, which is a 

device (EPA-certified or ot:herwise) that can document "inhome" field test emissions less tha.n the emission factor 

averages of "in-home" field test emissions data for EPAcertified stoves (Ref. 2). This can include classes of 

devices that are demonstrated to be capable as a class of 

producing lower field emissions, as well as specific model 

units that perform better in the field than the class 

collectively. 

Under this measure, the implemen'ting or lead planning 

agency should establish a building code"provision requiring 

that all new stoves be low-emitting. The measure should 

function similar to the number and density restriction - 

measures described in section 4.2.3 above. Additionally, in 

~ its PAE program, the implementing or lead planning agency 

should publicize the list of certified devices that qualify as 

low-emitting so that the pu.blic can understand what stoves can 

and cannot be installed in the serious PM-10 nonattainment 

area. 

3.3 EMISSION REDUCTION -- NEW5 AND EXISTING WOOD STOVE 

INSTALLATIONS 

This section discusses two measures--device and upgrade 

offsets--that the implementing or lead planning agency can 

undertake to achieve emission reductions in offset 

transactions beyond the emission reduction necessary to merely 

offset emission increases from new wood stoves. 

5New installations should include both "brand-new" stoves , 

~ and fireplaces and "new-usedll units (i.e., newly purchased 

units that - are not "brand new"). 

3-9 September 1992 
3.3.1 Device Offset 

When implemented, this measure is intended to achieve an ~ 

emissions reduction associated with retiring existing 

conventional stoves that is greater than the emissions 

increase resulting from new stove installations. The device 

offset should require that for every new EPA-certified, 

Phase II stove installation, an appropriate number of existing 

conventional stoves be retired;and destroyed (see Appendix B). 

The ratio of stoves removed to new stoves should'be based on 

the relative emissions of the devices as reflected in the 

emission reduction credi.ts disCussed in Appendix F of the "RWC 

Guidance Document" as updated (see Appendix B). Given that a 

wood burner willing to retire his or her stove probably did 

not use the stove, this measure should be limited to 

participants who rely on wood as a sole source of heat and who 

are also low-income. 

Key elements of this measure are an affidavit 

requirement, a permit or registration system, installation ~ 

quality assurance, and enforcement activity. The implementing 

or lead planning agency should require that the existing stove 

owner participating in the transaction surrender the old 

conventional stove to the implementing or lead planning agency 

or its agent'to be destroyed in a manner in accordance with 

any Federal, State, or local laws governing disposal of 

hazardous or potentially hazardous substances (i.e., 

creosote). The existing stove owner should also register or 

permit the new stove with the implementing or lead.planning 

agency. For the new stove owner, the implementing or lead 

planning agency should require a permit or registration form 

documenting participation in th'e program. The transaction 

should be documented and...o-verseen-by-the-implementing or lead 

planning agency to ensure that it is bona fide. Furthermore, 

the imp3.ementing or lead-planning .agenczy. should-a require that 

the installation be performed by a trained and certified 

3-IO September 1992 
.. 

-.v.': 

~ installer (see section 3.3 of the "RWC Guidance Document" 

provides details on installation quality assurance). 

3.3.2Upctrade Offset 

This measure is intended to achieve emission reductions 

from new stove installations by requiring enough existing 

conventional stoves to be upgraded to more than offset any 

increase in emissions resulting from the proposed installation 

of new EPA-certified, Phase II stovies or equivalent 6 . The 

ratio of upgrades to new stoves should be based on the 

relative emissions of the devices as reflected in the emission 

reduction credits discussed in Appendix F of the "RWC Guidance 

Document" as updated (s.ee Appendix S). 

The implementation of this mea:sure"should be similar to 

the upgrade offset measure described in section 3.3.1 of this 

document. Key elements of this measure are an affidavit 

requirement, a permit-or registration form system, 

~ installation quality ,assurance, and enforcement activity. The 

implementing or lead planning agency should require that the 

existing stove owners participating in the transaction 

surrender the old conventional stove to the implementing or 

lead planning agency or its agent to be destroyed in a manner 

in accordance with any Federal, State, or local laws governing 

disposal of hazardous or potentially hazardous substances 

6 Equivalent is defined as RWC d.evices for which "in-home" 

field testing data are available.tha.t document emissions 

equivalent to or less than "iri-home" field test emissions of 

EPA-certified, Phase II stoves. See memorandum clarifying 

nature of RWC guidance and describing procedure for entities 

seeking emission reduction c:redit for RWC devices not certified 

by EPA but which can demonstrate comparable or lower emissions, 

through field testing. Proc:ess includes - consultation with 

EPA's Office of Research and Development on appropriate in-use 

testing methods and procedures (Ref..i:): For example,°EPA has 

recently reviewed in-home field data for certain masonry stoves 

tested during the 1991/92 heating season and has accepted the 

~ resultant emissions data foi- use in SIP-related activities 

( Ref . 2). 

3-11 September 1992 
(i,.e., creosote). The existing stove owner should also 

register or permit the new stove with the implementing or lead 

planning agency. For the new istove owner, the implementing or 

lead planning agency should re'quire a permit or registration 

form indicating participation in the program. The transaction 

should be documented and overseen by the implementing.or lead 

planning agency to ensure thatllit is bona fide. Furthermore, 

the implementing or lead plann ~ng agency should require that 

the installation be performed by a trained and certified 

installer (see section 3.3 of the "RWC Guidance Document" 

provides details-on .installation quality assurance). 

r • 

3=12 ~ September 1992 

• 

• 
,3 

~ References 

1. Memorandum. Renner, Fred H., Acting Chief, 

S02 /Particulate Matter Programs Branch, Air Quality 

Management Division, Office of Air Quality Planning and 

Standards, U.S. Environmental Protection Agency, Research 

Triangle Park, North Carolina, to Chief, Air Branch, 

Regions I-X, U.S. Environmental Protection Agency. 

"Interpretation of EPA's Guidance for Residential - Wood 

Combustion Emission Control Measures." September 23, 

1991. 

2. U.S. Environmental Protection Agency, Office of Air 

Quality Planning and Standards, Compilation of Air 

Pollutant Emission Factors fAP-42 .Research Triangle 

Park, North Carolina (masonry stove data to be 

published). 

3-13 September 1992 
•I 

1. 

.. 

• 
SECTION 4.0 

RWC BACM ECONOMIC FEASIBILITY METHODOLOGY 

4.1 INTRODUCTION 

This methodology is provided to enable serious PM-10 

nonattainment areas to assess the economic feasibility of the 

measures described in sections 2.0 aiZd 3, .0 of this document. 

Specifically, this section provides a methodology for 

estimating the cost and emission reduction effectiveness of 

,each available integral and flexible measure. The methodology 

~ does not provide specific data for agency and user costs 

associated with each measure since they are largely areaspecific in nature and, hence, should be obtained locally. 

For example, full-time employee (FTE) costs will vary from 

area-to-area, as will fuel,costs and the purchase and 

installation costs for RWC devices. 

4.2 INTEGRAL MEASURES 

4.2.1Public Awareness and Education 

Emission Reduction Calculations : 

As a general rule, no emissions, reductions are generally 

associated with this measure, thougYi a public awareness and 

education (PAE) program is vital to the overall success of any 

RWC control program. It.is typically very difficult to 

ascertain and quantify specific emission reductions that 

result from this program. Therefore, no emission reduction 

~ methodology is given for this.measure. 

September 1992 

4-1 
Cost Calculations: 

The cost of implementing a BACM PAE program is more ~ 

easily quantified and consists'of the amount of time an FTE 

should spend to administer the;program, plus any other costs 

such as radio, newspaper, and television advertising; 

establishment of an informatio'n hotline; education seminars; 

and the like. The equations nacessary to quantify these costs 

are given below. 

A x B = C 

where: 

A= annual time for FTE to administer program, fraction 

B = annual cost f or an FTE ,$ 

C= annual cost for FTE,;$/year„ 

The annual cost obtained above, C,'is then added to the 

total cost of other program facets (e.g., advertising, 

hotlines, education seminars, etc.) to obtain the total'annual 

cost. 

C + D = E 

where: ~ 

D= total annual cost of'other program facets, $/year 

E= total annual cost fot PAE program, $/year 

4.2.2Mandatory Curtailment Program 

Emi.ssion Reduction Calculations : 

Unlike other RWC control measures in which PM-10 emission 

reductions are calcul•ated on an annual basis, emission 

reductions from episodic curtailment are calculated on both an. 

annual and worst case 24-hour basis. This is because episodic 

curtailment is fundamentally a measure designed to reduce 

24-hour emissions and, over the course of the heating season, 

implementation of this measure;will also reduce annual 

emissions simply due to the cumulative effect of multiple 

24-hour reductions. - Therefore,!- reductions on an annual and 

worst case 24-hour basis are calculated below. 

September 1992 ~ 

4~-2 
t 

Annual curtailment emissions are 

fraction of heating degree days (HDD) 

curtailment episodes divi.ded by total 

multiplied by total yearly emissions. 

The f irst step ,in this procedure 

PM-10 emissions during the exceedance 

following formula: 

calculated based on the 

occurring during 

HDD for the year 

is to calculate annual 

months using the 

A x B/C = D 

where: 

A= Annual baseline PM-10 RWC emissions, tons per year 

(tPy) 

B= Heating degree days during exceedance days 

C= Annual heating degree days . 

D= Annual emissions of PM-10 duri,ng all exceedance 

days, tpy 

The emission reductions are calculated as: 

0 

D x E = F 

where: 

E= emission reduction credit level, fraction 

F= annual emissions reductions, tons PM-10 removed/year 

Worst-case 24-hour emission reductions are calculated in 

-a similar manner: 

D24-hour x E = F24-hou.r 

where: 

D 24-hour - worst case 24-hour PM-10 emission, tons 

per day 

F 24-hour = 24-hour emission reductions, tons, PM-10 

removed/day 

Cost Calculations : 

The costs of implementing this program are calculated on 

both an annual and 24-hour basis. These costs are divided 

into costs incurred by the implementing agency and the user. 

~ The annual costs to the implementing agency are largely a 

function of the effort necessary to enforce and administer 

effec-tively a curtailment program. The costs of a curtailment 

September 1992 

4-3 
program to the wood stoves and,fireplace user are the costs 

associated with heating through an alternative source. These ~ 

two cost elements (implementing agency and user) are 

determined separately as follows: 

. ; 

Imple~nent ~.nc Ac~ency Cost Calculations : The annual cost 

of implementing a BACM program may be calculated by the 

formula below: ; 

G x H = I 

where: 

G= curtailment program cost, $/stove and 

fireplace.curtailment day 

H= number of curtailment days per year 

I = annual cost, $/year 

The 24-hour implementing agency cost is'obtained by simply 

dividing the annual cost, I, by the number of curtailment days 

per year, K. 

I/K = J24-hou`r 

where: ~ 

`724-hour = 24-hour implementing agency incremental 

BACM cost, $/day 

K = number of curtailment days per year 

User Cost Calculations: The annual cost of the program 

for a stove user is based on an average cost incurred for each 

curtailment day. This estimate accounts for the daily cost of 

an alternative heating system on curtailment days. No costs 

to a fireplace user are estimated, since fireplaces are not 

intended to be used as a source of heat. 

Lo =MxK 

where: 

Lo= average annual cost to each nonexempt stove user for 

the curtailment period,$/year 

M= average cost to stove user...per- curtailment .day, 

$/day 

. ~ 

September 1992 

4*-4 
~ The average cost to each stove user per curtailment day, M, 

may be difficult to precisely calculate. A methodology for 

estimating this cost follows. 

Fi•rst, the cost of wood burning on curtailment days•needs 

to be calculated. This is oastimated in a two-step proce.ss. 

The first step yields the annual - fuel cost to the wood stove 

owner as follows: 

AC = Cd x Ct 

where: 

AC = annual fuel cost to the wood stove owner, $/year 

Cd = average number of cords burned in wood stoves, 

cords/year 

Ct = average cost of a cord of wood, $/cord 

This annual cost, AC, is then multiplied by the fraction of 

heating degree days during exceedance months divided by the 

annual heating degree days [(B/C); as calculated above], to 

obtain annual fuel costs during the curtailment period. This 

~ product is then divided by the number of curtailment days per 

year to obtain the fuel costs per curtailment day: 

FCD = [AC x (B/C)]/K 

where: 

FCD = fuel cost per curtailment day, $/day 

The cost of alternative fuels needs to then be 

calculated. This is based on the cost of obtaining an 

identical heat output (i.e., heat input x efficiency) from an 

alternative heating system. Therefore, the heat output from a 

"typical" wood sto.ve needs to be obt:ained. A"typical's wood 

stove will vary from area-to-area, depending.on the 

composition of the stove population. Generally, surveys can 

be performed to estimate -the- typical- heat , output of wood -- - 

stoves for a given area.. The energy input into a typical wood 

- -• stove per- curtailment -day- iEv -based- -on the- wood usage per- day, 

which in turn, is obtained f°rom the annual wood usage as 

~ follows: 

DEI = [Cd x EC x (B/C)]/K 

3eptember 1992 

4-5 
3 

where: 

DEI = daily energy inpu ~ into typical wood stove, ~ British thermal unit (Btu)/day 

EC = energy content ofia cord of wood, Btu/cord 

 Thi.s value, DEI, is then mult4lied by the wood stove system 

effici.ency to obtain the heat output on a daily basis. 

DHO = DEI x WSE 

where: 

DHO = daily heat output of wood stove, Btu/day 

WSE = typical wood stov6 efficiency, fraction 

The daily heat output, DHO, can then be used to obtain the 

daily heat input requirements of an alternative system as 

,. 

follows. : 

DHR = DHO/n 

where: 

DHR = daily heat input requirement for alternative ~ 

system, Btu/day 

n - alternative system efficiency, fraction 

The daily cost of this quantity of heat input is a 

function of the type of alternative system in the home (e.g., 

natura3 gas or propane heater, electric heat, etc.). The cost 

of alternative heat on Btu baszs [or kilowatt hour (kWh) basis 

for electricity] can be obtained from local gas or electric 

companies. If electricity is used as the alternative heat, 

the energy units in Btu's must'be converted to kWh as follows: 

9.486 x 10 -4Btu = 2.778 X 10 -7kWh 

As an example, the conversion of 100,000 Btu to kWh would be 

~ calculated as: 

100,000 Btu x(2.778 x 10- 7kWh)/(9.486 x 10 -4Btu) _ 

29.3 kWh 

The fuel'cost on a per day basis is then the difference 

between the alternativE,heating system.fuel costs and the.wood 

stove fuel heating costs as shown below: 

M = (DHR x AEC) - FCD ~ 

where: 

September 1992 

4--6 
~ 

~ DHR = daily heating requirement for alternative heat 

source, Btu/day 

' AEC = alternative energy cost, $/Btu 

The 24-hour cost to the stove user is simply M as definea 

above. 

4.2.3 Measures to Improve Wood Bur - ning Performance 

4.2.3.1 Control of Wood Moisture Content. 

Emission Reduction Calculations: 

This measure reduces ItWC emissions by promoting the 

burning of drier wood. It is difficult to accurately quantify 

either emission reductions or costs from.this measure due to 

factors that will necessarily vary from area to area. 

However, the guidance document for residential wood combustion 

("RWC Guidance Document") recommends that a maximum credit of 

5 percent of baseline emissions be allowed for areas 

~ i.mplementing this measure (Ref. 1). For purposes of this 

document, a 5 - percent credi.t is assumed. This credit can be 

calculated according to the formula below: 

A x 0.05 = B 

where: ° 

A= RWC annual baseline emissions, tons per year 

B= emissions r-eductions- fr_om control of wood 

moisture, tons per year 

Cost Calculations: 

In areas where this measure is not included in any 

pre-serious area control strategy, -the full cost of 

instituting this measure would.be i3:icurred. The cost to the 

implementing agency would include the purchase of wood 

-- moisture monitors and - various--administrative - and - educational 

charges. The cost to the RWC owner would include the time and 

effort necessary to -- ensure th~-wood -burned falls withiri an ` 

acceptable moisture content range. 

~ 

September 1992 

4-7 
4.2.3.2 Weatherization ot Homes with Wood Stoves . 

Emission Reduction Calculations : ~ 

The "RWC Guidance Document!' suggests a credit for a 

weatherization program (Ref. 2). The emission reductions from. 

this measure are calculated using the formula below: 

A x B = C 

where: 

A= RWC annual baseline emissions, tons per year 

B = emission reduction credit 

C= emission reductions from weatherization, tons per 

year ; 

Co t Calculations: 

For this measure, the annual implementing agency costs 

are assumed to equal the product of t4p average cost of 

weatherizing a home multiplied'by the number of homes 

weatherized per year. There are minimal or no user costs 

assumed for this measure since it is intended to target low 

income households. 

Implemen ing Anency cost Calculations: Total costs for ~ 

tha.s proggram are the product of the number of homes 

weatherized multiplied by the average cost to weatherize each 

home as shown below: 

D x E = F 

where: 6 

D= average cost to weatheri-ze a- home, $ 

E= number of homes weatYierized per year 

F = cost of weatherizatian'program, $/year 

A community may prefer to defer weatherization costs and 

implement the program over a langer time period as prescribed 

by EPA. In that instance, the cost of the weatherization 

~ program should be amortized over that period. 

Amortizing purchases is quite common and most people have 

experience with this. : thr.o_ugh: -,o.ar -and-.house: purchases . The - 

technique described below is a amortizing method which yield ~, 

equal payments incurred by the borrower over the life_of the 

finance period. The amortization factor is called the capital 

~ 

September 1992 

4~-8 

recovery factor and is calculated as follows: 
r ~ CRF = [i/12(i + i/12) n ]/[(1'~- +'i/12)n-1] 

where: 

CRF = capital recovery factor, decimal 

i = annual real in'terest rate, decimal 

n = length of finance time, months 

As an example, the CRF can be calculated using a 10 percent 

real interest rate and a 10-year time period (i.e., 120 

months): 

CRF = [0.1/12 (1 + 0.1/12) 120 ]/[(1 + 0.1/12)120-1] _ 

0.01322 

This factor should be multiplied by the purchase cost to 

obtain the monthly payment over the length of the finance 

time: 

E x CRF = G 

where: 

G= implementing agency monthly payment for program, $ 

The monthly payment multiplied by 12 then yields the annual 

0 cost to the implementing agency: 

F x 12 = Cm 

where: 

Cm = annual cost to implementing agency, $/year 

4.2.3.3Educational Opacity Program . 

Emission Reduction Calculati'ons : 

This measure reduces P'M-10 emissions through an 

educational program identifying operation and maintenance 

habits c.ontributing to visi:ble emissions. It is difficult to 

accurately quantify the emission reductions or costs from this 

measure due to lack of ineasurable parameters. Therefore, a 

low credit (i.e., a maximum of 5 percent of baseline 

a emissions) is recommended- in-.the -"MVC Guidance Document" 

(Ref. 3). For purposes of this document, the following .. 

formula can be used to.estimate emission reductio ~~s rrom this 

~ measure: a 

A'x 0.05 = B 

September 1992 

4-9 
where: 

A= RWC baseline emissions, - tons per year ~ 

B= emission reductions from educational opacity, 

tons per year 

Cost Ca- ~,culations: ; 

f 

In areas where this measure is not included in any 

pre-serious area control strate,~gies, the full cost of 

instituting this measure would 'be incurred, which would 

include opacity enforcement checks, public education forums 

and seminars, and related items. 

4.2.4 All New Wood Stove In`stallations EPA-certified, 

Phase II Stoves or Equivalent 

E]Ma.ssion Reduction Calculations: • 

Annual emission reductions,are based upon the number of 

installations that occur in a given year of non-EPA-certified, 

Phase II stoves (or equivalent). The emission reductions are 

calculated based on the emission reduction credit associated ~ 

wi.ththe conversion of a conventional to an EPA-certified, 

Phase II stove (or equivalent).' These reductions can be 

calculated using the formula below: 

(A x Blx B2x C x D)/(454',x 2,000) = E 

where: 

A = number of new installations of used, non-EPAcertified, Phase II stoves (or equivalent) per 

year 

Bi = emission reduction'credit 1from conventional to 

Phase II or equivaient, decimal (Ref. 4) 

B2= conventional wood stove emission factor, (Ref. 5) 

g/Kg 

C = average cords of wood burned in each stove per 

year, cords/year 

D = wood density, kg/cord 

E = annual emissions reductions from this measure, 

tpy 

1The credit should reflect the types of stoves it is 

assumed would be installed in the absence of the restriction ~ 

(e.g., conventional stoves and tPA-certified, Phase I stoves). 

September 1992 

4-10 
0 

~ 454 = conversion fac•tor, grams to pounds, g/lb 

2,000 = conversion factor, pounds_to tons, lb/ton 

Cost Calculations : 

Implementina Agency Cost Calculations : To administer and 

enforce effectively this program, some cost will be incurred. 

These costs may be estimated based on the amount of time an 

FTE would spend to administer and enforce this program each 

year. This cost can be estimated using the formula below: 

F x G = H 

where: 

F= time for an FTE to administer program, fraction 

G= annual cost for an FTE, $/year 

H =. implementing Agency cost, $/,year 

User Cost Calculations : To calculate the incremental 

cost to each stove user, the purchase and installation costs 

of an EPA-certified, Phase II stove (or equivalent) and of a 

conventional stove need to be obtairied from local wood stove 

~ dealers. The cost of the conventional stove is subtracted 

from the cost of an EPA-certified, Phase II stove (or 

equivalent). This cost difference is assumed to be financed 

over a period of time by tYie stove buyer. This requires that 

these costs be "amortized" by a numerical factor based on the 

length of the f inance period and the interest rate. The 

technique described below is a amort:izing method which vields 

equal payments incurred by the borrower over the life of the 

finance period. Amortizing purchases is quite common and most 

people have experience with this through car and house 

purchases. This amortization factor is called the capital 

recovery factor and is calcialated as .follows: 

CRF = [i/12(i + i/12) n ]/[(1 + i/12) n-1] 

where: 

CRF = capital recovery factor, decimal 

i = annual real interest rate,_ decima-1 

n = length of finailce time, months 

~ As an example, the CRF can be calculated using a 10 percent 

real interest rate and a 10--year length of time (i.e., 120 

months): 

September 1992 

4-11 
w 

CRF = [0.1/12 (1 + 0.1/12) 120 7/[(1 + 0.1/12)120-1 ~ _ 

0.01322 , 

This factor multiples the purchase cost to obtain the monthly 

payment over the length of the`finance time: 

I x CRF = J 

where: 

I= differential purchase and installation cost of 

stove, $ 

J = monthly payment, $/month 

The monthly payment multiplied,by 12 then yields the annual 

cost: 

J x 12 = Co 

where: 

Co = annual cost to stove owner, $/year.stove 

t 

4.3 FLEXIBLE AVAILABLE MEASURtS 

4.3.1 Emission Reduction or E_limination - Existing, 

Installations 

4.3.1.1 Conversion of E_xisting Wood Burning Fireplaces 

to Gas Loas . 

Emission Reduction Calculations : - ~ . Annual emission reductions are based on the number of 

wood-burning fireplaces converting to gas logs per year. The 

first step is to obtain the number of fireplaces that will 

convert to gas logs under this measure for a given 

implementation period. This implementation period is 

determined by the circumstances under which the nonattainment 

area is reclassified to serious. This is done using the 

formula given below: F 

(A/X) = B 

• 

❑ 

where: 

A= number of existing fil replaces for baseline year 

X= implementation period of available measure, years 

B= annual number of fireplaces converting to gas logs 

September 1992 

4-12 

❑ 
'J 

0 

~ The emission reductions from this measure can then be 

calculated as follows: 

(B x D x E x F)/(454 x 2,000) = G 

where: 

D = fireplace emission factor, (Ref. 6) g/kg wood 

burned 

E = average wood usage in one fireplace, cords/year 

F = average wood density, kg/cord 

G = annual emission reductions from this measure, 

tpy 

454 = conversion factor, grams to pounds, g/lb 

2,000 = conversion factor, pounds to tons, lb/ton 

Cost Calculations : „ 

Implementing Aaency Cost Effect iveness Calculations : To 

administer and enforce effectively -the program, some costs 

will be incurred. These costs may be estimated based on the 

amount of time an FTE would spend to administer and enforce 

the program each year. This cost can be estimated using the 

~ following formula: 

H x I = J 

where: 

H= time for an FTE to administer program, decimal 

I= annual cost for an FTE, $/year 

J= annual implementing agency cost, $/year 

User Cost Calculations _: The costs to the fireplace user 

are based upon two componen-ts. The first is the conversion 

cost of a conventional fireplace to gas logs, and the second• 

is the difference in annual energy <:osts between wood and 

natural gas. 

The cost to convert a conventional fireplace to a gas log 

fireplace will vary from coinmunity to community, but is not 

typically a big expense. The loc.al gas company and local wood 

stove and fireplace dealers should be contacted to obtain this 

cosL. Since this amount is not larcfe, it is assumed the user 

will not finance this cost. 

~ The energy cost difference betvueen wood and natural gas 

is calculated assuming the fireplace usage (i.e., hours used 

September 1992 

4-13 
. . 

per year) between a conventional and gas fireplace will not 

vary. The fireplace usage can'i be calculated as shown below: ~ 

(E x F)/K = L 

where: 

K= fireplace burn rate,'l (Ref. 7) kg wood/hour 

L = fireplace usage, hours/year 

The amount of natural gas consumed during this time period is 

then calculated as follows: 

L x M = N 

where: 

M= natural gas fireplace consumption rate•, Btu/hour 

N= energy consumption of natural gas fireplace, 

Btu/year ' 

The annual cost difference betcaeen natural gas and wood is 

then calculated as shown below: The cost of natural gas can 

be obtained from the local gas,company, while the cost of wood 

can be obtained from wood stove dealers or local classified 

advertisements. ~ 

(E x O) -(N x P) = Q 

where: 

O= cost of a cord of wo4d, $/cord 

P= cost of natural gas,t$/Btu 

Q= annual cost differenCe between natural gas and wood, 

$/year 

The total annual cost of the user is then the difference of 

these two cost components: 

R -Q = Co 

where: 

Co = annual user cost $/year 

R= cost to convert a conventional fireplace, $ 

~ September 1992 

4-14 
El 

~ 4.3.1.2Changeover to EPA-•Certifie dPhase II Stoves or 

Equivalent. 

Emission Reduction Calculat:ions: 

Annual emission reduct:ions from this measure are based 

upon the number of conventional and non-EPA-certified stoves 

that convert annually to EPA-certified, Phase II stoves (or 

equivalent) minus the number of EPA-certif ied, Phase II stoves 

presently in the stove inventory. The number of-stoves 

annually converting to EPA-certified, Phase II stoves (or 

equivalent) is determined by the total number of stoves that 

will convert over the allowed implementation period. 

To calculate the emission reductions that would occur 

through implementation of this measure, the formula below can 

be used: , 

[(A/X) x B lx B2x C'x D]/(454 x 2000) = E 

where:. 

A = number of af f ected stoves 

~ Bi = emission reduction credit from conventional to 

Phase II or equivalent, decimal (Ref. 8) 

B2 = conventional stove emission factor, (Ref. 9) 

g/Kg wood burned 

C = average cords of wood burned in each wood 

stoves per year 

D = wood density, kg/cord 

E = emissions reductions from this measure, tpy 

X = implementation period, years 

454 = conversion factor, grams to pounds, g/lb 

2,000 = conversion factor, pounds to tons, lb/ton 

Cost Calculations : 

Implementing Agency Cost Calculations : To effectively, 

administer and enforce this program, some cost will be 

incurred. These costs may be estim<ited based on the amount of 

time an FTE would spend to administer and enforce this program 

each year. This cost can be estimat:ed using the formula 

below: 

F x 'G = H 

~ where: 

F= time for an FTE to administer program, fraction 

G= annual cost for an FTE, $/year 

H = implementing agency cost, $/year 

September 1992 

4-15 
~ 

User Cost Calculations: To calculate the cost to each 

stove user, the purchase and installation cost of an -EPAcertified, Phase II stove (or equivalent) needs to be obta.ined . 

from local wood stove dealers. 'For purposes of this analysis, 

i.t i.s assumed that the stove buyer will finance the purchase 

and installation cost over a pexiod of time. This requires 

that these costs be "amortized",by a numerical factor based on 

the length of the fi.nance period and the interest rate. The 

technique described below.isanlamortization method which 

yields equal payments incurred by the borrower over the life 

of the finance period.._Amortizing purchases is-quite common 

and most people have experience with this through car and 

house purchases. This amortization factor is called the 

capital recovery factor and is dalculatcd as follows: 

CRF = [i/12(i + i/12) n ]/C(1 + i/12) n-1] 

where: 

CRF = capital recovery factor, decimal 

i = annual real interest rate, decimal 

n = length of finance time, months 

As an example, the CRF can be calculated using a 10 percent 

real interest rate and a 10-yeaz length of time (i.e., 120 

months): 

CRF = [0.1/12 (1 + 0.1/12) 120 ]/[(1 ± 0.1/12)120-1] _ 

0.01322 

This factor multiples the purchase cost to obtain the monthly 

payment over the length of the finance time: 

I x CRF = J I 

where: 

I= purchase and installation cost of stove, $ 

J = monthly payment, $/month 

The monthly payment multiplied by 12 then yields the annual 

cost: 

J x 12 = Co 

where: 

Co = annual cost to stove owner, $/year•stove ~ 

September 1992 

4-',16 

• 

E 
~ 4.3.1.3 Changeove.r to Low-Emi:tting Devices. 

Emission Reduction Calculations: 

Annual emission reductions from this measure are based 

upon the number of conventional and non-EPA-certified stoves 

annually converting to low--emitting stoves minus the number of 

low-emitting stoves presently existing. The number of stoves 

annually converting to low•-emitting is determined by the total 

number of stoves that will convert over the allowed 

implementation period. 

To calculate the emission reductions that would occur 

through implementation of this measure, the formula below can 

be used: 

[(A/X) x Bix B 2 x C x D]/(459: x\ 2000) = E 

where: 

A = baseline number of c:onventional or Oregon 1986 

certified stoves 

B 1 = emission reduction c:redit from conventional to 

low-emitting stove, decimal (Ref. 10) 

~ B2 = conventiona7_ stove emission factor, (Ref. 11) 

g/Kg wood burned 

C = average cords of wood burned in each wood 

stoves per year 

D = wood density, kg/cor•d 

E = emissions reductions from this measure, tpy 

X = implementati.on period, years . 

454 = conversion factor, grams to pounds, g/lb 

2,000 = conversion factor, pounds to tons, lb/ton 

Cost Calculations: 

Implementing Agency Cost Calculations: To administer and 

enforce effectively this program, some cost will be incurred. 

These costs may be estimated based on the amount of time an 

FTE would spend to administer and enforce this program each 

year. This cost can be est.imated using the formula below: 

F x G = H 

where: 

F'=' time for an FTE to administer program, fraction 

~ G= annual cost for an FTE, $/year 

H = Implementing Agency cost, $/year 

September 1992 

4-17 
f 

f 

User Cost Calculations : To calculate the cost to each 

stove user, the purchase and installation cost of a 1owemitting stove needs to be obtained from local wood stove 

dealers. For purposes of this analysis, it is assumed that 

the stove buyer will finance the purchase and installation 

cost over a period of time. This requires that these costs be 

"amortized" by a numerical factor based on the length of the 

finance period and the interest rate. The technique described f below is an amortization method which yields equal payments 

~ incurred by the borrower over the life of the finance period. 

Amortizing purchases is quite common and most people have 

experience with this through car and house purchases. This 

amortization factor is called the capttal recovery factor and 

is calculated as follows: • 

CRF = [i/12(i + i/12) n ]/[(1 + i/12) n- 1] 

where: 

CRF = capital recovery factor, decimal 

i. = annual real intere,st rate, decimal 

n = length of finance time, months 

As an example, the CRF can be calculated using a 10 percent 

real interest rate and a 10-year length of time (i.e., 120 

months): 

CRF = [0.1/12 (1 + 0.1/1,2) 120 }/[(1 + 0.1/12)120-1] _ 

0.01322 

This factor multiples the purchase cost to obtain the monthly 

payment over the length of the':finance time: 

I x CRF = J 

where: 

I= purchase and installation cost of stove, $ 

J = monthly payment, $/month 

The monthly payment multipliedlby 12 then yields the annual 

cost: 

El 

• 

J x 12 = Co,s 

where: 

Co ~ s = annual purchase and installation cost to stove 

owner, $/year•st©ve , 

September 1992 

4-18 

• 
~ To obtain the total costs to the user, the difference in fuel 

costs assuming an identical heat input between a conventional 

and low-emitting stove per year needs.to be calculated (this 

example assumes a pellet stove for a low-emitting device). 

'The first step is to calculate the amount of heat input to a 

conventional stove per year. 

C x K = L 

where: 

K = heat content of_ wood, (Ref. 12) 10 6Btu/cord 

L = heat input to conventional stove,Y10 6Btu/year 

The amount of pellet fuel this heat input represents is then 

calculated as shown below. 

K/(0.008 x 2,000) = L 

where: 

0.008 = heat content of pellet fuel,'(Ref. 13) 10 6 

Btu/lb 

~ 2,000 = conversion factor, pounds to tons, lb/ton 

L = tons pellet f_uel consumed per year, ton/year 

The cost difference between pellet fuel and wood is then 

calculated. The cost of pellet fuel and wood can be obtained 

through local wood stove dealers or through classified 

advertisements. 

(L x M) - (B x N) = O 

;ahere : 

M = cost of pellet fuel, $/ton 

N = cost of wood, $/cord 

O = annual cost difference between pellet fuel and 

wood, $/year 

This cost is then added to C' o 

 ,

sto obtain the total annual 

user cost, Co . 

Co ,s + 0 = Co 

whef e : 

Co= total annual user cost, $/year_ w 

September 1992 

4-19 
~ 

4.3.2 Emission Reduction or Emission Inc_rease Frevention - 

New Installations 4 

4.3.2.1 Gas Fireplaces or Gas Logs in New Fireplace 

lnstallations. 

Emission Reduction Calculations: 

Annual emission reductionS are based on the growth rate 

of fireplaces in the absence of regulations, assuming all new 

fi.replaces installed are fueled by wood. The calculations to 

obtain the emission reductions are given below. First, the 

number of new gas logs and fireplaces installed per year needs 

to be calculated as shown below. 

A x B = C 

where: .. 

A= annual wood-burning fireplacegrowth rate in absence 

of regulation 

B= current wood-burning fireplace population 

C= number of new wood-burning fireplaces installed per 

year in absence of regulation 

The number of wood-burning fireplaces not installed annually 

due to this regulation is then'assumed to equal C, the number 

of wood-burning fireplaces installed per year in the absence 

of regulation. The emission reductions obtained from this 

measure are then calculated as'follows:• 

(C x D x E x F)/(454 x 2,000) = G 

where: 

D = fireplace emission factor, (Ref. 14) g/kg wood 

burned 

E = average wood usage in one fireplace, cords/year 

F = average cord defisity, kg/cord , 

G = annual emission;reductions, tons/year 

454 = conversion factor, grams to pounds, g/lb 

2,000 = conversion factor, pounds to tons, lb/ton 

Cost Calculations : 

• Implementinct Acency Cost Calculata ,ons : To administer and 

enforce effectively the program;'some costs will be incurred. 

These costs may be estimated based on the amount of time an 

FTE would spend to administer and enforce the program each ~ 

year. This cost can be estimated using the following formula: 

September 1992 

4~-20 

• 

• 
~ H x I = J ~ 

where: 

H= time for an FTE to administer program, decimal 

I= annual c:ost for an FTE, $/year 

J= annual implementing agency cost, $/year 

User Cost Calculations: The costs to the user are based 

upon two components. The first is the difference in the 

purchase and installation cost of gas logs or gas fireplaces 

and the purchase and installation cost of a conventional, 

wood-burning fireplace which could not be installed under this 

regulation. These cost items can be obtained through local 

wood stove dealers. This difference is assumed to be financed 

over the length of the home mortgage, since this cost is 

usually included with the rest of home purchase cost. 

The second cost to the user is the difference in energy 

costs between gas and wood. This cost difference is based on 

the amount of time a conventional fireplace would be used over 

~ the course of the year. The calcul.ations to obtain both of 

' these costs are given below. 

First, the cost difference between a gas fireplace and 

wo.od fireplace is calculated. 

K - L = M 

where: 

K= cost of natural gas fireplace, $ 

L= cost of wood fireplace $ 

M= differential cost: between gas and wood f ireplace, $ 

The differential cost is the amortized over the length of the 

mortgage (which is typically 15 to 30 years) to obtain the 

annual differential cost, L. This is calculated using an 

amortization factor called the capital recovery factor. This 

requires that these costs be "amortized" by a numerical factor 

based on.the length of the finance period and the interest 

rate.. The technique describeci below is a amortization method 

~ which yields equal payments incurred by the borrower over the 

life of the finance period. Amortizing purchases is quite 

common and most people have experience with this through car 

September 1992 

4-21 
and house purchases. This amortization factor is called the 

capital recovery factor and is !calculated as follows: ; ~ 

CRF = [i/12(i + i/12) n ]/[(1 + i/12) n-1] 

where: ' 

CRF = capital recovery factor, decimal 

i - real interest rate', decimal 

n = length of finance time, months 

As an example, the CRF can be calculated using a 10 percent 

real interest rate and a 10-year length of time (i.e., 120 

months): 

CRF = [0.1/12 (1 + 0.1/12) 120 ]/[(1 + 0.1/12)120-1] _ 

0.01322 

This factor multiplies the',differential purchase cost, L, 

to obtain the monthly payment o;ver the 1'ength of the finance 

time: 

M x CRF = N 

where: 

N = monthly payment, $/month ~ 

The monthly payment multiplied ~y 12 the yields the annual 

cost for this cost component. 

~ N x 12 = O ; 

where: 

O= annual cost differential between gas and wood and 

wood fireplace, $/year 

The next step is to calculate the energy cost difference 

on an annual basis. This is obtained based on the amount of 

time a fireplace is used and th+e corresponding natural gas and 

wood usage during this time. First, the annual hours a 

conventional fireplace is used is calculated. 

(E x F)/P = Q 

where: 

P= fireplace burn rate, (Ref.. 15) kg wood/hour 

Q = firepiace usage, hours/year 

The amount of natural gas consumed during this tiine period is 

then calculated as follows: ~ 

September 1992 

4-22 
~ Q x R = S 

where: 

R= natural gas fireplace consumption rate, Btu/hour 

S= energy consumption of natural gas fireplace, 

Btu/year 

The annual cost difference between natural gas and wood is 

then calculated as shown below. The cost of natural gas can 

be obtained through the local gas company, while the cost of 

wood can be found in classified advertisements, or through 

wood stove dealers. 

(E x T) -(S x U) = V 

where: 

T= cost of a cord of wood, $/cord 

U= cost of natural gas, $/Btu 

V= annual cost difference be'tween natural gas and wood, 

$/year 

The total annual cost to the user is then the sum of these two 

~ cost components: 

O + V = Co 

where: 

Co= annual user cost, $/year 

4.3.2.2Upgrade Offset. 

Emission Reduction Calculations : 

The purpose of this measure is to prevent emission 

increases due to an increase in wood stove population. As 

such, this measure does not reduce wood stove emissions and, 

therefore, emission reductions are <:onsidered negligible. An 

emission reduction calculation for this measure is therefore 

not performed. However, the cost izicurred by the implementing 

agency and by the user can be estimated using the steps 

described below. - 

Cost Calculations : 

Imj3lementing Aaency Cost Calcu7.ations : To administer 

~ effectively this program, some costs will be incurred. These 

costs may be estimated based on the amount of time an FTE 

September 1992 

4-23 
 . 

~ • 

would spend to administer and enforce this program each year. 

This cost can be estimated using the formula below: 

E x F = G 

where: 

E= time for an FTE to administer and enforce this 

program, fraction 

F= annual cost for an FT8, $/year 

G = program cost, $/year 

No implementing ager.cy cost effectiveness for this measure is 

calculated. 

User CQst Calculations: Tb calculate the cost to each 

~ stove user, the purchase and --installation cost of an EPAcertified, Phase II stove needs;to be obtained from local wood 

stove dealers. Note that for this measure, each new stove 

buyer may need to purchase an EPA-certified, Phase II stove. 

Depending upon individual agreements between the new stove 

purchaser and the conventional Stove owner (`whose stove is to 

be upgraded), the cost to the n6w stove purchaser will vary, 

particularly if the conventional stove owner does not demand 

full payment . for a newly installed EPA-certified, Phase II 

stove to decide to upgrade his or her stove. It is therefore 

not possible to accurately quantify this cost, unless specific 

i.nformation between new stove purchasers and conventional 

stove owners is known. , 

For purposes of this analysis, it is assumed that the 

stove buyer will finance the purchase and installation cost 

over a period of time. This requires that these costs be 

"amortized" by a numerical factor based on the length of the 

finance period and the interest'rate. The technique described 

below is a amortization method which yields equal payments 

incurred by the borrower over the life of the finance period. 

Amortizing purchases is ­ quite common and most people have 

experience with this through car and house purchases. This 

amortization factorais called the capital recovery factor and 

3.s calculated as follows: 

CRF = [i/12(i + i/12)n]/[(1 + i/12)n-1] 

where: 

September 1992 

4-24 

• 

E 

r~ 

u 
~ CRF _ capital recovery factor, decimal 

i annual real iiiterest tate, decimal 

n'= length of finance time, months 

r . 

As an example, the CRF can be calculated using a 10 percent 

real interest rate and a 10-year le:ngth of time (i.e., 120 

months): 

CRF = [0.1/12 (1 + 0.1/12) 120 ]/[(1 + 0.1/12)120_1] _ 

0.01322 

This factor multiples the purc:hase cost to obtain the 

monthly payment over the length of the finance time: 

H x CRF = I 

where: 

H= cost to new stovE: purchaser, 

I = monthly payment, $/month 

The monthly payment multiplied by 12 then yields the annual 

cost: 

I x 12 = Co 

~ where: 

Co.= annual cost to st:ove owner, $/year.stove 

4.3.2.3Restriction _in_NumbPr and Density of New Wood 

Burning Stove andlor Fireelace Installations. 

Emission Reduction Calculations : 

Emission reductions from this measure should be based on 

an assumed growth rate of wood; stoves and fireplaces minus 

stoves or fireplaces not installed due to the restriction. 

This is done in two parts: calculating wood stove emission 

reductions and calculating fireplace emission reductions. 

Stoye Emission Reduction: The calculations to obtain the 

--- emission reductions from EPA-certified,-Phase II stoves are 

given below: 

A x B = C 

where : 

~ A= annual EPA-certified, Phase II stove growth rate in 

absence of regulation,.decimal 

B= current EPA-certified, Phase II stove population 

September 1992 

4-25 
h 

h 

C= number of EPA-certifxed, Phase II stoves installed 

in absence of regulation 

The number of stoves not xnstalled due to this measure is 

dependent on the type of density restriction. This may range 

from full restrictions on stoves (i.e., a ban) to partial 

restrictions. If'a full restrXction program is instituted, 

the annual number of stoves not installed is simply the annual 

stove growth rate multiplied by the stove population. 

For full restriction, use the following formula: 

E = C 

• 

where: 

E= number of stoves not;installed due to this measure 

If a partial restriction on stoves.in enacted, the number 

of stoves not installed will depend on the density allowance 

(e.g., number of stoves allowed per acre). Historical data 

may be used to determine the average number of stoves per acre 

in the area, and the difference between this and the density 

restriction multiplied by the number of acres developed per ~ 

year equals the number of stoves not installed. The 

calculation to determine this value, E, is: 

E= ( D - RS ) x AD 

where: 

E = annual number of stoves'not installed due to this 

measure 

D = average number of'stoves per acre 

RS = density restriction, number of stoves allowed per 

acre 

AD = acres developed annually 

The emission reductions obtained from not installing these 

stoves are calculated as shown below: 

(E x F x G x H)/(454 x 2,000) = I 

where: 

. , 

F = emissioiri factor I~ for EPA-certified, Phase II 

stoves, (Ref. 1 ~ )'g/kg wood burned 

G = average wood burned in one stove per year, ~ 

cords/year 

H = average cord derisity, kg/cord 

G September 1992 

4~-26 
~ I = 

454 = 

2,000 = 

annual emission reductions.from stoves, 

tons/year 

conversion f_actor, grams to pounds, g/lb 

conversion factor, pounds to tons, lb/ton 

An identical procedure needs to be performed for fireplaces. 

Fireplace Emission Reduction: The calculations to obtain 

the emission reductions from fireplaces are given below: 

AFx BF= CF 

where: 

AF= annual fireplace growth rate in absence of 

regulation-, -decintal - 

BF= current fireplace population 

C F= number of fireplaces installed in absence of 

regulation .. 

The number of fireplaces not instal,led due to this 

measure is dependent on the type of density restriction. This 

may range from full restrictions on fireplaces (i:e., a ban) 

to partial restrictions. If a full restriction program is 

~ instituted, the annual number of fireplaces not installed is 

simply the annual fireplace growth rate multiplied by the 

fireplace population. 

For full restriction, use the following formula: 

EF= CF 

where: 

EF= number of fireplaces not installed due to this 

measure 

If a partial restriction on fir_eplaces in enacted, the 

number of fireplaces not installed will depend on the density 

allowance (e.g., number of fireplac(Ss allowed per acre). 

Historical data may be used to determine the average number of 

fireplaces per acre in the area, anci the difference between 

this and the density'restriction multiplied by the number of 

acres developed per year equals the number of fireplaces not 

installed. The calculation procedure - to determine this value, 

~ Ef , is: 

EF - (DF- RSF ) x ADF 

where: 

September 1992 

4-27 
EF= annual number of fireplaces not installed due to 

this measure 

DF= average number of:fireplaces per acre 

RSF= density restriction, number of fireplaces allowed 

per acre 

ADF= annual developed dcres 

The emission reductions obtained from not installing these 

fireplaces are calculated as: i 

(EFX FF. x GF X HF )/(454 X 2,000) = I F 

where: 

FF = emission factor for fireplaces, (Ref. 17) g/kg 

wood burned 

GF = average cord usage for fireplaces, cords/year 

HF = average cord density f.or fireplaces, kg/cord 

IF = annual emission reductions from fireplaces, 

tons/year 

454 = conversion factor, grams.to pounds, g/lb 

2,000 = conversion factbr, pounds to tons, lb/ton 

Total emission reductions are then calculated as the sum of 

reductions from stoves and fireplaces. 

H + HF. = HT 

where: 

HT= total emission reductions from this measure, 

tons/year 

Cost C=lculations : 

Implementing Agency Cost Calculations : To administer 

effectively this program, some,costs will be incurred. These 

costs may be estimated based on the amount of time an FTE 

would spend to administer the program each year. This cost 

can be estimated using the forinula below: 

I x J = K 

' where: 

I= time for an FTE to aelminister program, fraction 

J= annual cost for an FtE, $/year , 

K= annual implementing zgency cost, $/year 

User Cost Calculations : There are two different 

procedures for calculating_,the cost to an RWC user, depending 

upon whether the RWC is a wood stove or fireplace. 

The cost to each wood stove user is based on two items: 

(1) the differential purchase and installation costs between a 

• 

• 

• 

September 1992 

4'-2 8 
~ gas furnace or other form pf heat ;€and an EPA-certified, Phase 

II wood stove; and (2) the differences in fuel costs based on 

an identical heat in.put to a gas furnace and a wood stove. 

Differential costs for firE_places are estimated based on the 

cost of_a wood-burning fireplace and a gas fireplace or gas 

log fireplace (both of whi<:h can be obtained from local wood 

stove and fireplace dealers) and the arnount of time a 

fireplace is used annually. 

Stoves : The purchase and installation cost differential 

for stoves is calculated as: 

L -M = N 

where: 

L= purchase and installation cost for gas furnace, $ 

M= purchase and inst:allation cost for wood stove, $ 

N = cost differential., $ 

For purposes of this analysis, it is assumed that this 

cost differential, N, is financed over the life of the stove 

~ which is typically 10 years. 

This requires that these costs be "amortized" by a 

numerical factor based on t.he length of the finance period and 

the interest rate. Amortizing purchases is quite common and 

most people have experience with this through car and house 

purchases. The technique described below is a method which 

yields equal payments incurred by the borrower over the life 

of the loan. This amortization factor is called the capital 

recovery factor and is calculated a;s follows: 

CRF = U/12(i + i/12) n ]/[-(1 + i/12) n-1] 

where: 

CRF = capital recovery factox-, decimal 

i = annual real interest rate, decimal 

n = length of finailce time, months 

As an example, the CRF can be calcu:Lated using a 10 percent 

real interest rate= and= -a= ten- - year- length -of - time : 

CRF = [0.1/12 (1 + 0.1/12) 1 2 0 ]/[(1 + 0.1/12)120,p1] _ 

~ 0.01322 

September 1992 

4-29 
This factor multiples the'.purchase cost to obtain the 

monthly payment over the length of the finance time (i.e., 120 ~ 

months): 

N x CRF . = O 

where: 

N= purchase and installa,tion cost of stove, $ 

O = monthly payment, $/mdnth 

To obtain the annual cost to the user, multiply this value, O, 

by 12 as shown below: 

O x 12 = P 

where: 

P= annual purchase installation cost to user, $/year 

The difference in energy dosts pqr year can be estimated 

once the costs for natural gas`and wood'are obtained on a 

~ $/10 6Btu basis. The cost of natural gas on a$/10 6Btu basis 

can be obtained from the local!gas company. The energy cost 

of wood on a$/10 6Btu basis can be calculated using the 

formula below. The cost of woad ($/cord) can be obtained from ~ 

local wood stove dealers or the classified advertisements. 

Q/R = S 

. 

where: 

Q = cost of wood, $/cord 

R= energy content of wodd, 10 6Btu/cord 

S= energy cost of wood,,

r

$/10 6Btu 

The differential cost is then dbtained as: 

, 

 . 

(NGC - S) = T 

where: 

NGC = natural gas cost, $/10 6Btu 

T = cost differential, $/10 6Btu 

The annual cost difference is then calculated using the 

formula below: 

GFx R x T= U 

where: 

U= annual cost difference between natural gas and wood, ~ 

$/year 

September 1992 

4=30 1 
~ The total annual cost to trie wood stove user is the sum of 

these two components as shown below: 

Cow= p + U 

where: 

Cow= annual cost to wood stove user, $/year 

Fireplaces : The purch.ase and installation cost 

differential for fireplaces is calculated as shown below. The 

cost for both types of fireplaces can be obtained from local 

wood stove dealers. The cost of a gas line,can be obtained 

from the local gas company.. 

LF- MF = NF \ 

where: 

LF= purchase and installation costr for gas fireplace or 

gas log fireplace, $ 

MF= purchase and installation cost for wood burning 

fireplace, $ 

NF= cost differential, $ 

~ For purposes of this analysis, it is assumed that this 

cost differential, NF , will be fi.nanced over the length of the 

home mortgage. 

This requires that these costs be "amortized" by a 

numerical factor based on the length of the finance period and 

the interest rate. The technique.described below is a method 

which yields equal payments .;.ncurred by the borrower over the 

life of the finance period. Amortizing purchases is quite 

common and most people have experiernce with this through car 

and house purchases - : This amortization factor is called the 

capital recovery factor and is calculated as follows: 

CRF = [i/12(i + i/12) n ]/[(1 4• i/12)n-1] 

where: 

CRF = capital recovery - factor, -deciniai ~ 

i = annual real int:erest rate, decimal 

- n = length- of 1 -finance time -;months ° = 

As an example, the CRF can be calcul.ated usi.nga 10 percent 

~ real interest rate and a teri year length of time (i.e., 120 

months): 

September 1992 

4-31 
, 

 CRF = [0.1/12 (1 + 0.1/12) 120 ]/[(1 + 0.1/12)120_1] _ 

0.01.322 

This factor multiples the'purchase cost to obtain the 

I 

monthly payment over the length of the finance time: 

OFx CRF = P F 

where: 

OF= purchase and installa:tion cost of fireplace, $ 

PF= monthly payment, $/month 

To obtain the annual cost to tYie fireplace user, multiply this 

value, PF , by 12 as shown below: 

PF. x 12 = QF 

where: 

QF= annual purchase and installation cost to fireplace 

user, $/year 

The first step to obtain the dif.ferential fuel cost 

between a conventional fireplace and gas logs, is to calculate 

the annual hours a fireplace is used. This is done according 

to the formula below. 

(GF x HF)/RF = SF 

where: 

RF= fireplace burn rate, kg wood/hour (Reference 2) 

SF= fireplace usage, h:ours/year 

The amount of natural gas consumed during this time period is 

then calculated as follows: 

SFx TF= UF 

where: 

TF= natural or propane gas fireplace consumption 

rate, Btu/hour 

UF= energy consumption of natural or propane gas 

fireplace, Btu/year 

The annual cost difference between natural gas and wood 

is then calculated as shown bel,ow. 

f 

( GF x VF )-( UF x WF )=;' XF 

where: 

VF= cost of a cord of ;wood, $/cord 

WF= cost of natural gas $/Btu ~ 

XF= annual cost difference between natural gas ~ and 

wood, $/year 

September 1992 

4-32 

11 

• 
The total annual cost to the fireplace user is the sum of XF 

and QF: 

XF+ QF= YF 

where: 

YF= total annual cost for fireplace, $/year 

4.3.2.4 Reauire New Wood Stove Installations be Low 

Emitting. 

Emission Reduction Calculations: 

Emission .redu.ctio.ns wil.l.- -be -calculated based on 

reductions from EPA-certified, Phase II stoves to low 

emitting. ,. 

The emission reductioris will be calculated assuming an . 

annual stove growth rate in the absence of regulation, and the 

emission reductions achieved by requiring these new stoves to 

be low emitting. This is done in a two step process. First, 

the number of stoves that will be required to be low emitting 

is calculated. Second, the: emission recluctions for these lowemitting stoves relative to EPA-certified, Phase II stoves are 

calculated as shown below: 

A x B = C 

where: 

A= stove growth rate in absence of regulation, decimal 

B = current stove population 

C= number of stoves restricted to low emitting 

The number of stoves restricted to low emitting, C, is then 

used to calculate the emission reductions as follows: 

(C x Dix D2x E x F)/(454 x 2,000) = G 

where: 

Di = emission reduction credit for conversion from 

Phase - II stove to loia emitting,--decimal (Ref. 

18) ' ­ 

D 2 = emission factor of EPA-certified, Phase II 

stove; - (Ref. 19) g/Kg- wood burned 

E = average number of cords per year burned in one 

wood stove, cords/year 

F = average cord density, kg/cord 

G = emission•reductions from this measure, 

tons/year _ ` 

September 1992 

4-33 
454 = 

2,000 = 

conversion factor, grams to pounds, g/lb 

conversion factor, pounds to tons, lb/ton 

Cogt Calculations: 

t • 

Imt?lementinc Agency Cbst Calculations: To administer and 

enforce effectively the program, some costs will be incurred. 

These costs may be estimated based on the amount of time an 

FTE would spend to administer',and enforce this program each 

. , 

year. This cost can be estimated using the formula below: 

H x I = J 

where: 

H= ° time for `an FTE ­t~o aldminister and enforce program, 

fraction 

I= annual cost for an FTE, $/year 

J = annual implementing`agency cost, $/year 

User Cost Calculations: To calculate the cost to each 

stove user, the purchase and i;nstallation cost of a lowemitting stove needs to be obtained from local wood stove 

dealers. For purposes of this - analysis, it is assumed the 

stove buyer will finance (i.e. f , discount) this cost over a 

period of time. The purchase'and installation of a lowemitting stove may be obtained by calling local dealers. 

Financing stove costs requires that these costs be 

"amortized" by a numerical factor based on the length of the 

fi.nance period and the interest rate. The technique described 

below is a method which yields equal payment incurred by the 

borrower over the life of the finance period. Amortizing 

purchases is quite common and most people have experience with 

this through car and house purchases. This amortization 

factor is called the capital recovery factor and is calculated 

as follows: ; 

CRF = [i/12(i ± i/12) n ]'/[(1 + i/12) n-1] 

where: 

t CRF = capital recovery factor, decimal 

i = annual ydal interast -rate, decimal 

n = length of finance'°time, months 

As an example, the CRF can bejcalculated using a 10 percent ~ 

real interest rate and a 10-year length of time: 

September 1992 

4-34 

I . . 

11 
1~ 

17- 71, 

CRF [0.1/12 (1 + 0.1/12)120]/[(1 + 120-1] 0.1/12) 

0.01322 

This factor multiples the purchase cost to obtain the 

monthly payment over the lian-gth of the finance time - (i.e-., 120 

months). 

K x CRF L 

where• 

K = purchase and installatiori cost of stove, $ 

L = monthly payment, $/month 

To obtain the annual cost to the user, multiply this value, K, 

by 12 as shown below: 

L x 12 M 

where: 

M= annual cost­ of piirchase and installation of a lowemitting stove, $/year 

In addition to the purchase and installation cost, the 

annual fuel cost must be czilculated. This cost is based on 

the difference between the cost of pellet fuel and wood, 

assuming-the same heat inpLit to a pellet stove and an EPAcertified, Phase II stove (this example assumes a pellet stove 

.for a low-emitting -device). The calculation procedure is 

given below. First, calculate the annualheat input to an 

EPA-certif ied, Phase II stove as shown: 

E x N = 0 

where: 

N= average cord energy content, Btu/cord 

O= total annual heat: input to stove, Btu/year 

Once this value is calculated, the annual cost of pellet fuel 

can be obtained usingthe following formula. The cost of 

pellet fuel ($/ton) can be obtained through local wood stove 

dealers.. 

(N x P x Q)/(8,000 x 2,000) = R 

where: 

p- = cost of pellet fuel, $/ton pellets 

Q 7 relative efficiency ratio of EPA-certified, 

Phase II wood stoves to low-emitting stoves, 

September 1992 

4-35 
decimal (Ref. 20). (e.g., pellet stoves in this 

example) ~ 

R - annual fuel cost of pellets, $/year 

2,000 = conversion factor, pounds to tons, lb/ton 

8 1 000 = heat content'of pellet fuel, Btu/lb 

» . . 

The annual cost of wood is calculated according to the formula 

below. The cost of wood ($/cord) can be obtained through wood 

stove dealers or classified advertisements. 

E x S = T 

where: 

S = cost of wood, $/cord 

T = annual wood cost, $/year 

[ 

The annual wood cost, T, is then subtracted from the annual 

pellet cost, P, to obtain the incremental fuel costs of 

switching to pellet fuel from cord wood'as shown below: 

Q - T = U f . 

where: 

U = incremental fuel cost, $/year 

The total annual costs to the stove purchaser are then 

calculated as: 

M+U=Co 

where: 

Co = total annual cost to l stove purchaser, $/year.stove 

4.3.3 Emi,ssi.on Reduction - New and Existing Installations 

4.3.3.1Device Offset . 

Ema.ssion Reduction Calculations : 

Emission reductions will be based on a decrease in 

emissions from removal of an appropriate number of 

conventional stoves for every stove installed. 

The calculations to obtaih the emission reductions are 

given below. First, . the,_number..of_new_ stoves ..installed -per 

year needs to be calculated as'shown below. 

A x B = C 

where: 

A= annual stove growth rate in absence of regulation ~ 

B = current stove population 

C= number of new stoves'installed per year 

September 1992 

4-36 
The emission reductions.can then be calculated as: 

(C x D1x D2x E x F)/(454 x 2,000) = G 

where: 

D 1 = emission reduction c:redi.t from conventional to 

Phase II stove or equivalent, decimal (Ref. 21) 

D2 = emission factor for conventional stove, (Ref. 

22) g/Kg wood burnecl 

E = average wood burned in one stove per year, 

cords/year 

F = average wood density, kg/cord 

G = annual emission reductions, tons/year 

454 = conversion factor, grams to pounds,g/lb 

2,000 = conversion f_actor, pounds to tons, lb/ton 

,. 

Cost Calculations : , 

Implementing Aaency Cost Calculations : To effectively 

administer the program, some costs will be incurred. These 

costs.may be estimated based on the amount of time an FTE 

would spend to administer the program each year. This cost 

can be estimated using the following formula: 

H x I = J 

where: 

H= time for an FTE t:o administer program, decimal 

I= annual cost for an FTE, $/year 

J= annual implementing agency cost, $/year 

The implementing agency cost effectiveness is calculated as 

the ratio of program costs divided by the total reductions 

obtained. 

CEia= J/G 

where: 

CEia= implementing agency cost effectiveness, $/ton 

PM-10 removed 

User Cost Calculations : The cdsts to stove purchasers 

proposing to install a_ new_.EPA-certified, Phase II,-stove in 

the serious nonattainment area are:assumed to equal the 

installation cost of a new EPA-certified, Phase II stove, the 

cost to remove a conventional stove, and the cost of an 

alternative heating system to replace the conventional stove. 

September 1992 

4-37 
• . 

These costs can be obtained from local wood stove dealers, the 

local gas company, and the local electric company. For 

purposes of this analysis, it is assumed the purchaser will 

finance these costs over a period of time. 

This r'equires that these ~ costs be "amortized" by a 

numerical factor based on the4length of the finance period and 

the interest rate. The technique described below is a method 

which yields equal payments incurred by the borrower over the 

life of the finance period. Amortizing purchases is quite 

common and most people have experience with this through car 

and house purchases.•..This amqrtization facto-r is called the 

capittal recovery factor and is calculated as follows: 

CRF = [i/12(i + i/12) n ]/[(1 + i/12) n-1] 

where: ' 

CRF = capital recovery factor, decimal 

i = annual real interest rate, decimal 

n = length of finance time, months 

As an example, the CRF can be`calculated using a 10 percent 

real interest rate and a 10-year length of time (i.e., 120 

months): 

CRF = [0.1/12 (1 + 0.1/12) 120 ]/[(1 + 0.1/12)120-1] _ 

0.01322 

This factor multiples the purchase cost to obtain the 

monthly payment over the length of the finance time: 

K x CRF = L 

where: 

K= total cost to remove conventional stove, plus cost 

of alternative heating system, plus cost of EPAcertified, Phase II stove, $ 

L = month3.y payment, $ 

The monthly payment multiplied by 12 then yields the annual 

cost: 

L x 12 = Co 

where: 

Co = annual cost to stove owner, $/year•stove ~ 

, 

September 1992 

4-38 

• 

• 
4. 3. 3. 2 Upgrade Of f s+at . 

Emission Reduction Calculations: 

Emission reductions are calcul.ated assuming a stove 

growth rate in the absence of regulation with an appropriate 

number of conventional stoves upgraded for every new EPAcertified, Phase II stove installed. The first step in 

calculating the emission reductions is to estimate the number 

of stoves that will be upgi-aded usi.ng the two formulas below: 

A x B = C 

where: 

A= stove growth ratE: in absence of regulation, decimal 

B = current stove population 

C= number of stoves installed 

The number of upgraded stoves is ca.lculated as: 

D = E x C 

where: 

D= number of conventional stoves upgraded 

E= appropriate number of stoves to achieve net 

emission reduction 

The emission reductions are calculated in a two-step 

process. First, the reductions from the upgraded stoves 

relative to conventional stoves are estimated. Second, the 

emissions from the new stoves installed are calcuiated and 

subtracted from the reductions obtained in the first step. 

(D x E1x E2x F x G)/(454 x 2000) = H 

where: 

E l = emission reduction.credit from conventional to 

Phase II, decimal (Ref. 23) 

E2 = emission factor for conventional stoves, (Ref. 

24 ) g/Kg wood burned--- 

F = average cords per year burned in one stove 

G = average cord density, kg/cord 

H = emission reductions `from , upgraded - stoves, 

tons/year 

454 = conversion factor, grams to pounds, g/lb 

2,000 = conversion factor, pounds to tons, lb/ton 

September 1992 

4-39 
The emissions increase resulting from installation of that new 

stove are calculated as follows;: ~ 

~ (C x I x F x G)/(454 x 200 0) = J 

where: 

I = emission factor for EPA-certified, Phase II 

stoves, (Ref. 25) 4/kg wood burned 

J = emissions from new,stove installations, tons/year 

f 

The emission reductions are the'n calculated as the difference 

between the reductions from the ~ upgraded stoves minus the 

emissions occurring from the new stoves'as shown below: 

K = H-J 

where: 

K= emission reductions from this measure, tons/year 

Cost Calculations: I" . 

Implementing Acrency Cost Calculations: To effectively 

administer this program, some costs will be incurred. These 

costs may be estimated based on the amount of tiine an FTE 

would spend to administer this program each year. This cost ~ 

can be estimated using the fo'rm'ula below: 

E x F= G i ~ 

where: 

E= time for an FTE to adxninister program, fraction 

F= annual cost for an FTE, $/year 

G = Implementing Agency ciost, $/year 

k User Cost Calculations: To calculate the cost to each 

stove user, the purchase and in'stallation cost of an EPA- r 

certified, Phase II stove needs.to be obtained from local wood 

stove dealers. Depending upon individual agreements between 

the new stove purchaser and the'conventional stove owners 

(whose stoves are to be upgraded), the cost to the new stove. 

purchaser will vary, particularly if the conventional stove 

owners do not demand full payment for a new installed EPAcertified, Phase II stove. It as therefore not pQssible to 

accurately quantify this cost, unless specific information 

between new stove purchasers and conventional stove owners is 

~ 

September 1992 

4 ,'40 

; 

known. 
3 n 

~ For purposes of this analysis, it is assumed that the 

stove buyer will f inance wtiatever costs are incurred over a 

period of time. This requires that these costs be "amortized" 

by a numerical factor based on the length of the ~ 'finance 

period and the interest rat:e. The technique described below 

is a method which yields equal payment incurred by the 

borrower over the life of t:he finance period. Amortizing 

purchases is quite common and most people have experience with 

this through car and house purchases. This amortization 

factor is called the capital recovery factor and is calculated 

as follows: 

CRF = [i/12(i + i/12) n ]/[(1 + i/12) n -1] 

where: 

CRF = capital recovery factor, decimal. 

i = annual real interest rate, decimal 

n = length of finance time, months 

As an example, the CRF can be calculated using a 10 percent 

~ real interest rate and a 10-year length of time (i.e., 120 

months): 

CRF = [0.1/12 (1 + 0.1/12) 120 ]/[(1 + 0.1/12)120-1] _ 

0.01322 

This factor multiples the purchase cost to obtain the 

monthly payment over the length of the finance time:. 

H x CRF = I 

where: 

•H = cost to new stove purchaser, 

J = monthly payment, $ 

The monthly payment multiplied by 12 then yields the annual 

cost: 

I x 12 = Co 

where: 

Co = annual cost to stove ownera $/year.stove 

September 1992 

4-41 
•i 

3 

•i 

• 
~ References 

1. U.S. Environmental Protection Agency, Guideline Ser'ies. 

"Guidance Document for• Residential Wood Combustion 

Emission Control Measures." EPA-450/2-89-015. 'September 

1989. pp. Fl - F4. 

2. Reference 1, pp. F1 - F4. 

3. Reference 1, pp. F1 - F4. 

4. Reference'1, pp. F1 - F4. 

5. U.S. Environmental Protection Agency, Office of Air 

Quality Planning and Standards, Compilation of Air 

Pollutant Emission Factors (AP-42), Research Triangle 

Park, North Carolina. 

6. Reference 5. , 

7. Reference 5. 

8. Reference 1, pp. F1 - F4. 

~ 9. Reference 5. 

10. Reference.l, pp. Fl - F4. 

11. Reference 5. 

12. Reference 1, p. A8. ~ 

13. Hearth and Home. August 1990. p. 25. 

14. Reference 5. 

15. Reference 5. 

16. Ref erence 5. 

17. Reference 5. 

18. Reference 1, pp. F1 - l?4. 

19. Reference 5. 

20. Referenc? 1, pp. F1 - F4. 

21. Reference 1, pp. Fl - F4. 

~ 21. Reference 6. 

22. Reference 5. 

September 1992 

4-42 
• k . 

23. Reference 1, pp. F1 - F4. 

24. Reference 5. 

25. Reference S. 

•i 

• 

❑ 

September 1992 

4--43 
~ APPENDI}: A 

RWC BACM TASK FORCE MEMBERSHIP 

Barbara Bates 

US EPA Regional Office IX 

75 Hawthorne Street 

San Francisco, CA 94196 

Steve Body 

US EPA Region X 

1200 Sixth Avenue 

Seattle, WA 98101 

John Chamberlin 

US EPA, Office of Policy, Planning, -and Evaluation (PM-221) 

401 M Street, S.W. 

Washington, DC 20460 . 

Kevin Golden 

Washoe County District Health Department 

Air Quality Management Di.vision 

777 Sinclair Street, Suite 101 

~ Reno, Nevada 89501 

Merlyn Hough 

Oregon Department of Environmental Quality 

Air Quality Division 

811 SW 6th Avenue 

Portland, OR 97204-1390 

Rosalyn Hughes 

US EPA Region Office IV 

345 Courtland Street, NE 

Atlanta, GA 30365 

Dan Johnson 

Washington State Department of Ecology 

M.S. PV-11 

Olympia, WA 98504 

Jim King 

Colorado Department - of - Health - 

Air Pollution Control Division 

4210 East 11th Avenue 

Denver, CO 80220 

A-1 September 1992 
i D ~ 

George Lauderdale 

US EPA Region X ~ 

1200 Sixth Avenue 

Seattle, WA 98101 

~ Linda Lay 

US EPA Office of Air and Radiation 

Stationary Source Compliance Division (EN-341W) 

401 M Street, S.W. 

Washington, DC 20460 

Bob Lebens 

US EPA Office of Air and Radiation 

Stationary Source Compliance. Division (EN-341W) 

401 M Street, W.W. 

Washington, DC 2-0460. 

Bob McCrillis 

US EPA 

Office of Research and Development 

Air and Energy Engineering Research Laboratory (MD-61) 

Research Triangle Park, NC ~ 27711 

Thompson Pace 

US EPA 

Office of Air and Radiation 

Air Quality Management Divis'ion (MD-15) ~ 

Research Triangle Park, NC 27711 

I 

Vickie Patton 

Office of General Counsel (LE-132A) 

US EPA 

401 M Street, S.W. 

Washington, DC 20460 I 

Mike Silverstein 

US EPA Regional Office VIII 

999 18th Street 

Denver Place - Suite 500 

Denver, CO 80202-2405 

Christopher Stoneman, Chairman 

US EPA 

Offi.ce of Air and Radiation 

Air Quality Management Division (MD-15) 

Research Triangle Park,_,NC 27711 

Tim Williamson 

US EPA 

Office of Policy Analysis anid Review (ANR-443) 

401 M Street, S.W. 

Washington, DC 20460 ~ 

A-2 September 1992 
~ Gary Yee 

Californi.a Air Resource:> Board 

Post Office Box 2815 

Sacramento, CA 95812 

A-3 September 1992 
I \` 

• 

• 
~. 

APPENDIX B 

METHODOLOGY FOR CALCULATING DEVICE AND 

UPGRADE OFFSET RATIOS 

Device Offset 

A 1-to-1 device offset ratio by definition produces a net 

emissions reduction since a conventional, old stove is being 

replaced with a cleaner burnirig unit. The emissions reduction 

resulting from the transactiori shouid 'be -calculated based-on the 

appropriate emissions reduction credit. To calculate the - 

emission reductions, see EPA's AP-42 document (Ref.. 1) for 

appropriate emission factors and, for a methodology on how to 

calculate emission reduction c:redits, see an updated Appendix F 

of the "RWC Guidance Document 10to lie issued. 

The participants in this measure whose stoves are being 

removed, though, should be limited to sole-source, low-income 

wood burners since a regular wood burner who has a back-up 

heating system would be wil.ling to participate in the transaction 

~

probably because the wood stove was not being used. Thus, 

emissions might increase from the transaction.- 

Uparade Offset 

From a 1-to-1 upgrade offset tran.saction, resulting 

emissions would be: 

Emissions =. (existing conventional stove emissions * 

emission reduction credit for conversion 

upgrade) + (emissions of new stove) 

The net effect on emissions from an upgrade transaction 

depends on the magnitude of the reduction in emissions relative 

to the increased emissions of the new stove. Thus, the 

appropriate ratio of upgrades to new stoves will depend on 

whether the measure is intended to.produce no net effect on 

emissions or a net reduction. To detei:-mine the appropriate ratio 

and the net impact on emissions, see EPA's AP-42 document 

(Ref. 1) for appropriate emissio-n- -factors - -and, - for -a methodoiogy 

on how to calculate emission reduction credits, see an updated 

Appendix F of the "RWC Guidance Documerit" to be issued. 

~ September 1992 

B-1 
•i 

J 

• 

~~ 
~References 

1. U.S. Environmental Protection Agency, Office of Air Quality 

Planning and Standards, Compilation of Air Pollutant 

Emission Factors (AP-421, Research Triangle Park, North 

Carolina. 

~ 

September 1992 

B-2 
* - I 

• 

~