Warm Air Furnace Manufactur

Presentation to the Office o

Management and Budget

December 6, 2013

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• What is a Solid Fuel WAF? – A central heating appliance that uses air to transfer heat to 

from combustion of wood or pellets. Similar in concept to warm air central heating appliances -- the only difference i

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• Regulatory History – Unlike Hydronic Heaters, WAFs are virtually unre

for PM emissions in the United States. – The Canadian Standards Association (CSA) establiconsensus-based test method including performastandards for WAFs in February 2010.

• These are codified in CSA B415.1-10, and establish a pa

of 0.4 g/MJ, which translates to ~0.93 lb/mmBtu outpuunits.

• CSA B415.1-10 is a cordwood based test method which 

more relevant to real-world performance than crib-basmethods.

• These standards have been adopted by three Canadian 

and by several local Canadian jurisdictions so far.

• Only a handful of WAFs, however, have been listed as c

with CSA B415.1-10. Most of those are EPA-certified w

with air jackets and blowers.

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Examples of CSA B415.1-10 Compliant M

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EPA position on inclusion of WA

the NSPS

• EPA has been remarkably transparent about its int

for the proposed NSPS over the past four years.

• Until last February, EPA consistently told us that th

would adopt the CSA B415.1-10 consensus-based of 0.93 lb/mmBtu output, with NO step 2 standardbecause of lack of data.

• However, last February, EPA announced a dramatic 

in position: that the Step 1 standard would be the B415.1-10 level, but that it would propose a Step 2 standard of 0.15 lb/mmBtu -- equivalent to the Stestandard being considered for HHs.

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Industry Reaction

• WAF manufacturers are in a very different 

than HH manufacturers: HH manufacturebeen working diligently on a new generatiemission controlled appliances since well the EPA Voluntary Program was first launc2007 and are already regulated to EPA proStep 1 level in many states.

– WAF manufacturers, on the other hand, are 

getting started, and have a very long way to catch up.

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Background

• When considering warm air furnaces, there are generally two t

are marketed. – There are those that provide supplemental heating capability and 

tied into an existing fossil-fuel fired or electric heating system. 

• When they are being fired, the primary system is generally dormant. If th

wood heat is not meeting the heating demand, the primary system engag

– And, there are those with adequate capacity to provide whole-ho

over the full range of heating demands that might be encountere

• These models are the primary heating source but sometimes offer fossil-f

back-up systems for times when wood-burning is not warranted such as tfall shoulder seasons or when the homeowner is away and not able to ad

• Some current models that fill primarily the supplemental heati

been designed around clean-burning woodstove technology. – This transfer of woodstove technology to warm air furnaces has li

terms of firebox volume (wood load capacity) and in terms of hea

• The fact that woodstove certification is based on crib fuel testing rather t

a further complication. – The models that fulfill the whole-house heating role generally hav

firebox capacities, often twice or more that of the woodstove-basThese models exceed the capabilities of the woodstove technologmust look elsewhere for applicable technology. The natural tendlook to hydronic heaters.

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• Hydronic Heater combustion technology has been ci

being the basis of technology transfer to Warm Air F

– One has to carefully examine the similarities and the differences b

these product classifications to determine if technology transfer abeyond the conceptual level is actually feasible or practicable.

• Much of the work to improve PM emissions in hydro

heaters in North America has been done in outdoor heaters. – Since they are located outside the living space, they overcome se

limitations that are present with indoor warm air furnaces.

• The engineering challenges confronting WAFs are dif

and may be even more daunting than the challenges HH manufacturers. – One obvious difference is the size of the envelope. 

• Outdoor hydronic heaters generally have a large footprint and are re

unconstrained in terms of height and even weight. 

• Size restrictions are more often due to shipping concerns than anyth• Increasing a dimension to accommodate new technology is generally 

insurmountable problem. 

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– Warm air furnaces, on the other hand, are faced with the necessi

able to be placed in a basement in many of their primary market 

• The height and width are restricted to what can fit through a typical 

access door and weight becomes an issue since these products are ohandled down stairs and into position. 

• The height is also limited by floor joists and other obstructions and th

maintain clearances from hot furnace surfaces to adjacent combustib

• The furnace height must also be compatible with existing or new ple

connect to ductwork to deliver heat. 

• The allowable size limits apply to even the highest output models if t

intended for residential use. 

• Even an extra inch in the wrong place can restrict installation opportu• Furnaces are generally very compact for these reasons. – When considering the addition of enhanced combustion technolo

space within the allowable envelope, while maintaining a reasona

capacity is a real challenge. 

• Downdraft gasifier combustion systems, now the standard approach 

hydronic heaters, can require height increases that may not be practair furnace when the various elements that comprise downdraft systat in total. 

• There will be, by necessity of fitting into available space, trade-offs th

made in warm air furnace designs that aren’t forced upon outdoor hdesigns.

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– There is another issue that affects warm air furnaces to a m

degree than outdoor hydronic heaters. That is the issue of 

• Water used as the heat transfer media in HHs has significant 

advantages compared to the air used for the same purpose in 

• Since warm air furnaces are most often installed indoors and 

combustible materials (under floor joists and sub-floors, for eextreme care must be taken to prevent those combustible moverheating. – The water jacket on the HH helps limit the maximum surface te

that can be reached under normal operation (to around the bowater), meaning that it is less likely that adjacent combustible mfloor joists and sub-floors) will be overheated compared to the of the air plenums on WAF’s. – And the volume of water in a HH system will absorb more excesoverheating than the air in a typical WAF system, thus providing tolerance when temperature spikes occur, especially during traconditions in response to heating demands. – This means that control of temperature spikes during operation critical for WAFs than for HH’s, which has implications both for emissions and also for complying with safety standards designehouse fires -- obviously a critically important design criteria.

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• Indoor installations present another safety challenge as well. – Extreme care must be taken to contain all combustible gases and sm

firebox and venting system when the fuel load door is opened. 

» Wood gasification designs are prone to having highly combust

present in the firebox during much of the burn cycle and espehave entered an off-cycle (when heating demand has been saOpening the load door at that time can hazardous. 

» While a flame rollout from the loading door presents a poten

hazard to the operator no matter where the heater is installedpresents a direct fire hazard if the heater is indoors. 

• There are design elements to mitigate these hazards bu

for the safety interlocks and purging cycle that prevent smoke rollout also increase product cost and retail price

– This is yet another design challenge that must be considered when 

technology transfer idea.

• Clean-burning European downdraft hydronic heater desig

the units are most frequently located indoors, can be loosolving some of the dimensional and safety issues we havoutlined. However, importing that technology even if it cadapted to warm air furnaces highlights yet another chalcost. 

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• WAF manufacturers have not had seven or more years to develop emission-co

appliances, as HH manufacturers have had. We also haven’t had the lead time develop a rigorous cost-effectiveness analysis. As noted, we weren’t on notice needed until earlier this year. However, some basic economic information highconcerns we have about product cost and retail pricing impacts.

• Baseline North American warm air furnaces are targeted at price sensitive cust

– This is clear when you look at the way many of the models are distributed

mass merchants account for a significant portion of the overall sales volumoutlets specialize in “value-based” products and you can find warm air adfor under $1000 and whole house models for under $2000. – The average price for current uncontrolled models that will heat a typical range of $2000.

• The addition of any new technology with the attendant components and comp

potential warranty exposure must be done in a way that addresses the price semarket. – If the price increases that have been seen for outdoor hydronic heaters th

developed and qualified to meet the EPA voluntary program and regulatelimit were to be applied to baseline warm air furnaces, the effects on salebe catastrophic. – And European hydronic heater technology presents even higher cost impa

• The current warm air furnace market is estimated to be on the order of 20,000 

– Doubling the average warm air furnace price would drive many customers 

category. It would not be unrealistic to see the sales volume cut in half. – Most of the warm air furnace manufacturers are small businesses and coutheir presence in the market under those conditions.

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The Small Business Regulatory Enforce

Fairness Act [SBREFA] Issues.

• The SBREFA panel that was convened several years ago 

a proposed regulation for WAF’s that was completely diffrom what EPA will now be proposing, yet there has beeindication that EPA will reopen that process to consider current proposal. 

• Without updating, any conclusions drawn from the Sma

Impact (SBREFA) process are of little value for gauging thof the current proposal.

• The Residential Wood Combustion NSPS that was prom

years ago resulted in a very large number of small businclosures in the woodstove industry, and we are very conthat similar dire consequences may be looming for warm furnace manufacturers.

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• Questions?

• Thank you!12/6/2013