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.

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ii September 1992

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.iC: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

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. . . . 2-9
2.4 A11 New Wood Stove Installations EPA-Certified, Phase II Stoves or E.quivalent

. . . . . . . . . . 2-10

iii September 1992seOtion Pacre

3.0 Flexible Measures Available for RWC BACM .

..... 3-1 

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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 

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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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# ~ iv; - September 1992Section 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

. . . . .

. . . . . . . . . 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

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. . . . . . . . B-1 .~

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# iTABLE



# ~ Table No. page
1=1 Measures Available for RWC BACM ..... 1-8

vi September 1992

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01SECTION 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 1.2.1 Designations 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.

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)]. 

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1-*2 September 1992Section 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. 1 Taken 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

1 This 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 1992to 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 

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1.-4 September 1992to 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.)].

1.2.5 RACM and BACM Issuance Section 1.90 of the amended Act requires EPA to issue technical guidance for RACM and BACM no later than 18 monthsfrom 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 1992to 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 

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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 Se P tember 1992 

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that are

- regarded as critic.al for 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

~ N program

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a o' cD n
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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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1-9 September 1992

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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.


# ~ 2-1 September 1992. '

Section 2 of the "RWC Guidance Document" provides details on existing PAE programs. 

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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."



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2-2 September 1992~

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2.1.3 Communication 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. t • .

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.

2.2.3 Public 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").

2.2.4 Exemptions In Stage I, the implementing or lead planning agency should allow exemptions for EPA-certified stoves or

2-5 September 1992equivalent, l wood 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.to verify 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.th the 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

1 Equivalent is defined as RWC.devices for which "in-home" field testing data are available, document emissions equivalentto 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.

2.3.1 Control 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 i rgy efficiency of wood-burning
' 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 19922.3.3 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. 2 Wood 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 19922.4 ALL NEW WOOD STOVE INSTAL'LATIONS 3 EPA-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. 4 The 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

3 New installations should include both "brand-new" stoves and fireplaces and "new-used" units (i.e., newly purchased units that are not "brand-new") r
4 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.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

01l



# ~ References

1. Memorandum. Renner, F'red H., Acting Chief, S0 2 /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.

3.1.1 Conversion of Existing..Wood-•Burning Fireplaces to Gas
L oas 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.1992The 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 andit 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 1992ti ,~

.

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

l Any stove that is not EPA-certified that burns cord woodshould 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 1992real 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 andit 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 199213h ~



# ~ 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.

3.1.3 Changeover 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" fieldtest 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 19923.2 EMISSION REDUCTION OR EMISSION INCREASE PREVENTION -- NEW

INSTALLATIONS 3 

## ~ 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.ng code, 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.

3.2.2 U,pgrade Offset The purpose of this measure is to prevent emission increases from new stove installations by requiring enough

3 New 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 1992Document" 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~

.



# ~ 3.2.4 Requirement that New Wood Stove fnstallations be Low

### Emittinq This measure limits RTn1C emissions growth by requiring that all new installations be low-emitting stoves, which is adevice (EPA-certified or ot:herwise) that can document "inhome" field test emissions less tha.n the emission factoraverages 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.

5 New 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 19923.3.1 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).

3.3.2 Upctrade 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, S0 2 /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 4.2.1 Public 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 4-1Cost 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~ -2t

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 4-3program 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: 

# ~

` 7 24-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. L o =MxK
where:

L o = 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 4-53



### 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 -4 Btu = 2.778 X 10 -7 kWh As an example, the conversion of 100,000 Btu to kWh would be

~ calculated as:
100,000 Btu x(2.778 x 10- 7 kWh)/(9.486 x 10 -4 Btu) _ 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 4-74.2.3.2 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 6 where: 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

4.2.3.3 Educational 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 4-9where: 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.th the conversion of a conventional to an EPA-certified, Phase II stove (or equivalent).' These reductions can be calculated using the formula below: (A x B l x B 2 x 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 B i = emission reduction'credit 1 from conventional to

Phase II or equivaient, decimal (Ref. 4) B 2 = 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

1 The 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 4-100



# ~ 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 4-11w



### 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 fi l 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 Effec t 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 4-14El



# ~ 4.3.1.2 Changeover to EPA-•Certifie d Phase 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 l x B 2 x C'x D]/(454 x 2000) = E where:. A = number of af f ected stoves 

## ~ B i = emission reduction credit from conventional to Phase II or equivalent, decimal (Ref. 8) B 2 = 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 eachstove 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.is anlamortization 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 B i x 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) 

## ~ B 2 = 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 4-17f

f 

### User Cost Calculations : To calculate the cost to eachstove 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:

C o

~ 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 6 Btu/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

, s to obtain the total annual user cost, C o
. C o ,s + 0 = C o whef e : C o = 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 4-21and 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 = C o where: C o = annual user cost, $/year

4.3.2.2 Upgrade Offse t. 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

4.3.2.3 Restriction _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 4-25h 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: A F x B F = C F where:
A F = annual fireplace growth rate in absence of regulation-, -decintal - B F = 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:
E F = C F
where:

E F = 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,



## ~ E f , is:

EF - (D F - RS F ) x AD F
where: September 1992 4-27E F = annual number of fireplaces not installed due to this measure D F = average number of:fireplaces per acre RS F = density restriction, number of fireplaces allowed

per acre AD F = annual developed dcres The emission reductions obtained from not installing these fireplaces are calculated as: 

# i

(E F X F F

. x G F X H F )/(454 X 2,000) = I F where:
F F = emission factor for fireplaces, (Ref. 17) g/kg

wood burned G F = average cord usage for fireplaces, cords/year H F = average cord density f.or fireplaces, kg/cord I F = 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 + H F . = H T where:
H T = 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 4-29This 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

~ $/10 6 Btu basis. The cost of natural gas on a$/10 6 Btu basis can be obtained from the local!gas company. The energy cost of wood on a$/10 6 Btu basis can be calculated using the formula below. The cost of woad ($/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 6 Btu/cord S= energy cost of wood,,
r $/10 6 Btu
The differential cost is then dbtained as:

.

, (NGC - S) = T
where: NGC = natural gas cost, $/10 6 Btu T = cost differential, $/10 6 Btu The annual cost difference is then calculated using the formula below:

G F x 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: C ow = p + U where: C ow = 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.. L F - MF = N F \ where:
L F = purchase and installation costr for gas fireplace or gas log fireplace, $ M F = purchase and installation cost for wood burning fireplace, $ N F = cost differential, $



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

cost differential, N F , 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.ng a 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:
O F x CRF = P F where: O F = purchase and installa:tion cost of fireplace, $ P F = monthly payment, $/month To obtain the annual cost to tYie fireplace user, multiply this value, P F , by 12 as shown below: P F . x 12 = Q F where: Q F = 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 = S F where:
R F = fireplace burn rate, kg wood/hour (Reference 2) S F = fireplace usage, h:ours/year The amount of natural gas consumed during this time period is then calculated as follows: S F x T F = U F where:
T F = natural or propane gas fireplace consumption

rate, Btu/hour U F = 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:
V F = cost of a cord of ;wood, $/cord W F = cost of natural gas $/Btu ~ X F = 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 

### X F

and 

### QF:

X F + Q F = Y F
where:

Y F = 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 emittingis 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 D i x D 2 x E x F)/(454 x 2,000) = G where:
D i = 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

4-33454 = 2,000 = conversion factor, grams to pounds, g/lb

conversion factor, pounds to tons, lb/ton t 

# •
Cogt Calculations: 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 eachstove 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 aperiod 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

. . 

# 111~ 17- 7 1,

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 4-35decimal (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 4.3.3.1 Device 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 4-36The emission reductions.can then be calculated as:

(C x D 1 x D 2 x 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)

D 2 = 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. CEi a = J/G where: CEi a = 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 costof 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 appropriatenumber 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 E 1 x E 2 x F x G)/(454 x 2000) = H where:
E l = emission reduction.credit from conventional to

Phase II, decimal (Ref. 23) E 2 = 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 4-39The 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 I" Cost Calculations:

. 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 stoveowners 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 1992i 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 1992I \` 

# •

•~.

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

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