1

Revision of Subpart AAA

Residential Wood Heaters

& Additional New Source 

Performance Standards (NSPS)

Panel Outreach Meeting

with Small Entity Representatives (SERs)

August 25, 2010
2

Reminder of Proposals under 

Consideration

 Tighten emission limits to reflect today’s Best Demonstrated 

Technology (BDT)

 Close “loopholes,” eliminate exemptions

 Add pellet stoves explicitly

 Add wood “boilers” (hydronic heaters) and furnaces

 Revise test methods as appropriate

 Streamline certification process & incorporate International 

Standards Organization (ISO) process plus compliance 

affirmation

 Regulate fireplaces

 Regulate devices fueled by other solid biomass, e.g., corn, 

various pelletized biomass

 Regulate coal-fired heaters (in order to level the playing field)
3

Costs and Economic Impacts Are Being 

Developed and Analyzed 

 Handout of cost impact analysis approach

 Handout of industry profile

 Handout of draft costs for pellet stoves

 Handout of draft costs for wood stoves

 Handout of preliminary cost information on hydronic heaters

 Handout of preliminary cost information on fireplaces

 Handout of questions to ask SERs

 How a wood stove looks seems to be a more important factor in 

sales price than the stove’s emissions

 There are large differences in base costs within most appliance 

categories, regardless of emission considerations
Compliance Deadlines

 Many SERs have requested more time for 

development of new model lines

 1988 NSPS allowed

 4 months for Phase I (equivalent to the most 

stringent State standard) and

 2 years for the Phase II requirements

 SERs are concerned that their current low cash flow 

requires them to stretch their R&D over a longer 

time, such as 7 years

 EPA will address this as we evaluate economic 

impacts.
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Emission Data Are Being Compiled and 

Analyzed

 Handout of EPA summaries of emission data

 See list of questions for SERs

 HPBA noted that low burn rate measurements of pre-1988 were 

somewhat lower than measurements by the current test method

 HPBA noted that the equation for conversions between 5G & 5H 

is erroneous. HPBA, manufacturers, and labs have agreed to 

conduct additional tests.

 Catalytic Hearth Coalition is conducting a review of catalytic 

performance versus time.

 MHA has prepared a summary of masonry heater performance

 EPA is working on comparisons of European and EPA test 

methods

 HPBA and BIA have provided additional information on fireplace 

potential emission reductions. SBA intends to obtain additional 

information.
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Test Method Revisions Are Being 

Developed

 EPA & HPBA are participating on numerous ASTM work groups

 HPBA participated on revision of Canadian method B415.1

 NYSERDA (New York State Energy Research and Development 

Authority) and EPA and others are reviewing European test 

methods

 Continuing concern of “real world variability” vs. lab tests, cribs, 

manufacturer preferences, etc. 

 Continuing discussions on emissions averaging (burn rate 

weightings), low burn rate, number of runs, time for hot start, 

caps, degradation, etc.

 Efficiency test methods (ASTM, CSA B415.1, etc.)
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Proceeding on More Inclusive Scope

 Pellet stoves

 Emission data show excellent performance potential with premium pellets

 Need to determine how to judge performance with different pellet quality

 Masonry heaters

 Considering development of 2-prong NSPS (emission limit and design option)

 Meeting with industry representatives on 8/18 

 Cook stoves

 Received improved definition of “traditional North American cook stoves”; expect to 

exempt these <1000 units

 Still waiting on definitions of “traditional Native American bake ovens” and “ceremonial 

fires” so that they may be excluded

 Hydronic heaters

 Typical European levels appear much lower; need to compare test methods

 Some new designs avoid operation at typically dirty low burn rates

 Considering different test method for heat storage which greatly reduces emissions 

 Furnaces – asked for data, little received yet

 Fireplaces

 Considering development of 2-prong NSPS (emission limit and design option); meeting with 

masons on 8/18 

 Numerous air agencies want regulations but SERs have recommended that EPA allow the 

voluntary program to “mature” first

 Coal – asked for data, may use transfer of technology, SERs question priority
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Compliance & Enforcement Aspects

We still intend to:

 Streamline certification process --- develop electronic system for 

submittals and approvals

 Make consumer-friendly --- Burn Wise website, spreadsheets of 

certifications ranked by emissions, tested efficiency, output

 Streamline recordkeeping and reporting of manufacturing 

tolerances and quality control

 Require compliance tests on “worst” grade of each type of pellet 

that manufacturer specifies/warrants for use

 Require Federal rules on pellet quality if adequate industry 

standards are not in place in time (see next slide)
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Pellet Fuel Certification

 PFI standards committee developed a draft 

certification program that includes adequate 

fuel characteristics and 3rd-party audits

 PFI Board gave unanimous support July18

 On schedule for October 2010

 EPA is hopeful that there will be no need for 

an EPA certification program for pellet fuels
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Wood Stove Example Options

 1988 NSPS:

 7.5 g/hr for non-catalytic

 4.1 g/hr for catalytic

 1998 Washington State limits

 4.5 g/hr for non-catalytic

 2.5 g/hr for catalytic

 On sales-weighted basis, over 85% meet today

 Require at promulgation?

 New NSPS limits for 2014?

 3.0 g/hr for either? (~half of “WA stoves” meet today)

 2.5 g/hr? (~1/4 of “WA stoves” meet today)

 2.0 g/hr? (>12% of “WA stoves” meet today)
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Pellet Stove Example Options

 1988 NSPS:

 7.5 g/hr for non-catalytic

 4.1 g/hr for catalytic

 However, most pellet stoves are exempt via the 35:1 air-to-fuel ratio 

exemption

 1998 Washington State limits:

 4.5 g/hr for non-catalytic

 2.5 g/hr for catalytic 

 Oregon tax credit level: 2.5 g/hr

 Require at promulgation? 

 Match Wood Stove NSPS 2014 (?) level: ~2.0 g/hr?

 over 2/3 of pellet stoves meet today

 Pellet Stove NSPS 2014 (?) level: 1.0 g/hr ?

 over 1/3 of pellet stoves meet today
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Hydronic Heater Example Options

 Exempt from 1988 NSPS

 Typical emissions: >4 lb /mmBTU heat output

 EPA 2010 Phase 2 Voluntary Level:

 0.32 lb / mmBTU heat output

 >14 EPA-qualified models already 

 Require at NSPS promulgation?

 Typical State 2010 regulatory level:

 0.32 lb / mmBTU heat output

 Many local jurisdictions ban HH

 New NSPS limit for 2014?

 0.20 lb / mmBTU heat output ?

 >7 EPA-qualified models already

 0.15 lb/mmBTU heat output?

 >3 EPA-qualified models already

 >100 models qualified by EN 303-05 are estimated to meet this level

 Maine Voluntary Phase 3 level:

 0.06 lb/mmBTU heat output

 Many models qualified by EN 303-05 models are estimated to meet this level
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Fireplace Example Options

 Most are exempt from 1988 NSPS via exemptions for >35:1 air-to-fuel 

ratio or “open masonry fireplace constructed on site”

 Typical emissions: 12 g/kg where not regulated

 1988 Washington State limit

 7.3 g/kg of wood burned

 EPA 2010 Phase 2 Voluntary Level:

 5.1 g/kg

 DRAFT EPA 2011 Phase 2 Voluntary Level

 2.7 g/kg of wood burned

 Typical California AQMD 2010 regulations:

 Ban

 NSPS 2014 (?) levels ?

 Allow Open doors: 4.0 g/kg?

 6 models already meet this level

 Require Closed doors: 1 g/kg?

 numerous models can meet this level with doors closed 
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Masonry Heater Example Options

 Exempt from 1988 NSPS via weight exemption (800 

kg)

 Colorado limit: 6 g/kg

 MHA requested for EPA to initiate voluntary program:

 0.13 g/MJ (0.32 lb/mmBTU heat output)

 NSPS 2014(?) level?

 2.5 g/kg, 2.5 g/hr daily average, 0.32 lb /mmBTU heat 

output, plus 7.5 g/hr max while burning?
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Single-Burn-Rate Appliance Example

Options

 Exempt from 1988 NSPS

 NSPS 2014(?) level? 

 “Camp stoves” must be for temporary use?

 Same as wood stoves, except burn rates?
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Cook Stoves Example Options

 Exempt from 1988 NSPS

 NSPS 2014 levels?

 Design requirements for “North American traditional cook 

stove”?

 Estimates of less than 1000 units per year

 Some States, same as wood stoves

 European BAT: 3.0 g/hr?
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Forced-Air Furnace Example Options

 Exempt from 1988 NSPS

 Canadian B415.1 level

 0.60 lb/mmBTU heat output

 Require at NSPS promulgation?

 NSPS 2014(?) level?

 Same as hydronic heaters?

 To level the playing field

 Allow longer time?
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Coal Stoves Example Options

 Exempt from 1988 NSPS

 NSPS 2014(?) level?

 Same as wood stoves?

 To level the playing field

 Allow longer time?
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Contacts:

Gil Wood

wood.gil@epa.gov

(919) 541-5272

David Cole

cole.david@epa.gov

(919) 541-5565