Warm Air Furnace Manufacturers’Presentation to the Office ofManagement and BudgetDecember 6, 201312/6/20131•What is a Solid Fuel WAF?–A central heating appliance that uses air to transfer heat to the homefrom combustion of wood or pellets. Similar in concept to oil or gaswarm air central heating appliances -- the only difference is thefuel.12/6/20132•Regulatory History–Unlike Hydronic Heaters, WAFs are virtually unregulatedfor PM emissions in the United States.–The Canadian Standards Association (CSA) established aconsensus-based test method including performancestandards for WAFs in February 2010.•These are codified in CSA B415.1-10, and establish a passinggradeof 0.4 g/MJ, which translates to ~0.93 lb/mmBtu output in Englishunits.•CSA B415.1-10 is a cordwood based test method which makesitmore relevant to real-world performance than crib-basedmethods.•These standards have been adopted by three Canadian Provincesand by several local Canadian jurisdictions so far.•Only a handful of WAFs, however, have been listed as complyingwith CSA B415.1-10. Most of those are EPA-certified woodstoveswith air jackets and blowers.12/6/20133Examples of CSA B415.1-10 Compliant Models12/6/20134EPA position on inclusion of WAFs inthe NSPS•EPA has been remarkably transparent about its intentionsfor the proposed NSPS over the past four years.•Until last February, EPA consistently told us that theNSPSwould adopt the CSA B415.1-10 consensus-based standardof 0.93 lb/mmBtu output, with NO step 2 standards,because of lack of data.•However, last February, EPA announced a dramatic changein position: that the Step 1 standard would be the CSAB415.1-10 level, but that it would propose a Step 2standard of 0.15 lb/mmBtu -- equivalent to the Step 2standard being considered for HHs.12/6/20135Industry Reaction•WAF manufacturers are in a very different placethan HH manufacturers: HH manufacturers havebeen working diligently on a new generation ofemission controlled appliances since well beforethe EPA Voluntary Program was first launched in2007 and are already regulated to EPA proposedStep 1 level in many states.–WAF manufacturers, on the other hand, are justgetting started, and have a very long way to go tocatch up.12/6/20136Background•When considering warm air furnaces, there are generally two types thatare marketed.–There are those that provide supplemental heating capability andare oftentied into an existing fossil-fuel fired or electric heating system.•When they are being fired, the primary system is generally dormant. If the supplementalwood heat is not meeting the heating demand, the primary system engages.–And, there are those with adequate capacity to provide whole-house heatingover the full range of heating demands that might be encountered.•These models are the primary heating source but sometimes offer fossil-fuel or electricback-up systems for times when wood-burning is not warranted such as the spring andfall shoulder seasons or when the homeowner is away and not able to add wood.•Some current models that fill primarily the supplemental heating rolehavebeen designed around clean-burning woodstove technology.–This transfer of woodstove technology to warm air furnaces has limitations interms of firebox volume (wood load capacity) and in terms of heatoutput.•The fact that woodstove certification is based on crib fuel testing rather than cordwood isa further complication.–The models that fulfill the whole-house heating role generally have largerfirebox capacities, often twice or more that of the woodstove-basedmodels.These models exceed the capabilities of the woodstove technologyand wemust look elsewhere for applicable technology. The natural tendency is tolook to hydronic heaters.12/6/20137•Hydronic Heater combustion technology has been cited asbeing the basis of technology transfer to Warm Air Furnaces.–One has to carefully examine the similarities and the differencesbetweenthese product classifications to determine if technology transfer at anythingbeyond the conceptual level is actually feasible or practicable.•Much of the work to improve PM emissions in hydronicheaters in North America has been done in outdoor hydronicheaters.–Since they are located outside the living space, they overcome several designlimitations that are present with indoor warm air furnaces.•The engineering challenges confronting WAFs are differentand may be even more daunting than the challenges facingHH manufacturers.–One obvious difference is the size of the envelope.•Outdoor hydronic heaters generally have a large footprint and are relativelyunconstrained in terms of height and even weight.•Size restrictions are more often due to shipping concerns than anything else.•Increasing a dimension to accommodate new technologyis generally not aninsurmountable problem.12/6/20138–Warm air furnaces, on the other hand, are faced with the necessity of beingable to be placed in a basement in many of their primary market areas.•The height and width are restricted to what can fit through a typical basementaccess door and weight becomes an issue since these products are often manhandled down stairs and into position.•The height is also limited by floor joists and otherobstructions and the need tomaintain clearances from hot furnace surfaces to adjacent combustible materials.•The furnace height must also be compatible with existing or new plenums thatconnect to ductwork to deliver heat.•The allowable size limits apply to even the highest output models if they areintended for residential use.•Even an extra inch in the wrong place can restrict installation opportunities.•Furnaces are generally very compact for these reasons.–When considering the addition of enhanced combustion technology, findingspace within the allowable envelope, while maintaining a reasonablefuel loadcapacity is a real challenge.•Downdraft gasifier combustion systems, now the standard approach with manyhydronic heaters, can require height increases thatmay not be practical in a warmair furnace when the various elements that comprise downdraft systems are lookedat in total.•There will be, by necessity of fitting into availablespace, trade-offs that must bemade in warm air furnace designs that aren’t forced upon outdoor hydronic heaterdesigns.12/6/20139–There is another issue that affects warm air furnaces to amuch higherdegree than outdoor hydronic heaters. That is the issue of safety.•Water used as the heat transfer media in HHs has significant safetyadvantages compared to the air used for the same purpose in WAFs.•Since warm air furnaces are most often installed indoors and nearcombustible materials (under floor joists and sub-floors, for example),extreme care must be taken to prevent those combustible materials fromoverheating.–The water jacket on the HH helps limit the maximum surface temperaturesthat can be reached under normal operation (to around the boiling point ofwater), meaning that it is less likely that adjacentcombustible materials (e.g.,floor joists and sub-floors) will be overheated compared to the temperatureof the air plenums on WAF’s.–And the volume of water in a HH system will absorb more excess heat withoutoverheating than the air in a typical WAF system, thus providing moretolerance when temperature spikes occur, especiallyduring transient (on-off)conditions in response to heating demands.–This means that control of temperature spikes during operation is even morecritical for WAFs than for HH’s, which has implications both for controllingemissions and also for complying with safety standards designed to preventhouse fires -- obviously a critically important designcriteria.12/6/201310•Indoor installations present another safety challenge as well.–Extreme care must be taken to contain all combustible gases and smoke withinfirebox and venting system when the fuel load door isopened.»Wood gasification designs are prone to having highlycombustible gasespresent in the firebox during much of the burn cycle and especially after theyhave entered an off-cycle (when heating demand has been satisfied).Opening the load door at that time can hazardous.»While a flame rollout from the loading door presents apotential safetyhazard to the operator no matter where the heater isinstalled, it alsopresents a direct fire hazard if the heater is indoors.•There are design elements to mitigate these hazards but the added costfor the safety interlocks and purging cycle that prevent flame andsmoke rollout also increase product cost and retail price.–This is yet another design challenge that must be considered when evaluating thetechnology transfer idea.•Clean-burning European downdraft hydronic heater designs, wherethe units are most frequently located indoors, can be looked to forsolving some of the dimensional and safety issues we havejustoutlined. However, importing that technology even if itcan beadapted to warm air furnaces highlights yet another challenge—cost.12/6/201311•WAF manufacturers have not had seven or more years to develop emission-controlledappliances, as HH manufacturers have had. We also haven’t had the lead time necessary todevelop a rigorous cost-effectiveness analysis. As noted, we weren’t on notice that one wasneeded until earlier this year. However, some basiceconomic information highlights theconcerns we have about product cost and retail pricing impacts.•Baseline North American warm air furnaces are targeted at price sensitive customers.–This is clear when you look at the way many of the models are distributed. Catalogs andmass merchants account for a significant portion of theoverall sales volume. Theseoutlets specialize in “value-based” products and youcan find warm air add-on furnacesfor under $1000 and whole house models for under $2000.–The average price for current uncontrolled models that will heat a typical home is in therange of $2000.•The addition of any new technology with the attendantcomponents and complexities andpotential warranty exposure must be done in a way thataddresses the price sensitivity of themarket.–If the price increases that have been seen for outdoor hydronic heaters that have beendeveloped and qualified to meet the EPA voluntary program and regulated state emissionlimit were to be applied to baseline warm air furnaces, the effects on sales volume wouldbe catastrophic.–And European hydronic heater technology presents even higher cost impacts.•The current warm air furnace market is estimated to beon the order of 20,000 units annually.–Doubling the average warm air furnace price would drive many customers away from thecategory. It would not be unrealistic to see the sales volume cut in half.–Most of the warm air furnace manufacturers are smallbusinesses and couldn’t sustaintheir presence in the market under those conditions.12/6/201312The Small Business Regulatory EnforcementFairness Act [SBREFA] Issues.•The SBREFA panel that was convened several years ago evaluateda proposed regulation for WAF’s that was completely differentfrom what EPA will now be proposing, yet there has been noindication that EPA will reopen that process to consider thecurrent proposal.•Without updating, any conclusions drawn from the Small BusinessImpact (SBREFA) process are of little value for gauging the impactsof the current proposal.•The Residential Wood Combustion NSPS that was promulgated25years ago resulted in a very large number of small businessclosures in the woodstove industry, and we are very concernedthat similar dire consequences may be looming for warm airfurnace manufacturers.12/6/201313•Questions?•Thank you!12/6/201314