Wood stovefmanuacturers askingfor a common senseapproach to the future.Concerningthe“StandardsofPerformanceforNewResidentialWoodHeaters,NewResidentialHydronicHeatersandForcedAirF rnacesandHeaters‐Furnaces,NewResidentialMasonryHeaters”ResidentialMasonryHeaters.Who are we?We are a group of manufacturers that make anddistributefreestandingandbuilt-inEPACertifieddistributestandingCertifiedwood fired products in North America:JtlNAouSBIHearthStonePacific EnergyNapoleon – Wolf SteelICC – RSFRegency–FPITogether, we represent 37% of the total industry 2012 USshipments of EPA certified appliances.NSPS 2013EPA states that this proposal “updates the 1988 NSPS toreflect significant advancements in wood heater technologiesand design, broadens the range of residential wood-heatingappliances covered by theregulation, and improves andt li i l t ti d ”streamlinesimplementation procedures.”EPA further states that the rule “is expected to requiremanufacturers to redesign wood heaters to be cleaner andlower emitting” and that these changes would provide forbetter and more efficient performance.We agree with the NSPS initiative1.EPA is tasked to regulate emissions for wood burningappliances2.EPA should set forward reasonable emissions limits3.The industry must do its part at improving air quality whileproviding wood burning appliances to homeowners for primaryor supplemental heat4.We should be reporting our appliances’ real efficiency5.New, uncertified wood burning appliances should be a thing ofthe past6.The sale of any used uncertified stoves should be stoppedExempt appliances are availablein 2013What is right to do?We believe thatencouraging locallysourced, renewableb tlTimenear carbon neutralheat is beneficialto everyone’s future.CleanCombustionWhat is right to do?When a tree rotsnaturally or burns,the carboncontained in thedi l dwoos releasedback to theatmosphere.How Can We Do It?We, as manufacturers; want to be able to continue offeringldb ilitllcean woournng appanceso a:Clean burning heaters, from compact simple stoves for asmaller budget / need tolargersophisticated fireplaces forsmallerbudget/needtosophisticatedfireplacesforbigger budgets / need and anything in betweenWith or without catalystWe, as an industry must:Consider consumer preferences: price, efficiency and userfriendlinessAlways respect EPA regulationsWhat do weKnow?We sought out an independent surveyfirm topyreveal consumer preferences and help usunderstand their likely behavior.This 15 minute survey conducted in June of 2013This15minutesurveyconductedinJuneof2013is the most recent survey conducted in ourindustry.Wood Stove/Fireplace Emissions StudyImpact On Product Replacement & Consumer Opinions7/11/2013What do WeKnow?610 relevant consumers as a data base:○539 were currently hearth product owners○71 were purchase “intenders”This significant data set gives us insight into consumerpreferences and expectationsto help us then understand thelikelybehavior of thegeneralpopulation.gpSample size precision is estimated at ± 4.0 percentage points ata 95% confidence level.a95%confidencelevel.Note: The survey excluded decorative fireplace owners. It strictly concentratedon wood heater owners,includingthose usingfreestandingstoves,built-in stoves,g g g,and stoves inserts.Who Answered our Survey?Location of the AppliancesOwnership and intentPurpose and frequency of useWhat do consumers care about?The #1 Decision Making Reason toS l tNWdBi A liieecaewoourningAppliances:Price $$Price $$1.The Stevenson Company Survey was clear.Price$$Price$$2.In 2012 sales, HPBA manufacturer’s data shows anoverall decline (-23.7%) in higher cost Cast IronEPA wood stove volume with an average wholesaleof $1230, while the lower cost Steel EPA woodstoves with an average wholesale of $752 enjoyedi f 20 6%anincrease of20.6%.Are Homeowners Likely to Spend 500$Premium for Catalytic or “New Technology”?gAre Owners more Likely to Fix Their Current ApplianceorFindaUsed “Previous Technology”Appliance?Previous Technology”Appliance?The #2DecisionMakingReasontoSelectaNewDecisionWood Burning Product is:Efficiency!Currently reported efficiencies are confusing toCurrentlyreportedefficienciesareconfusingtoconsumers;Industry needs and supports the idea of a simplestandardized method of calculating and reportingffi iecency.Natural Draft Appliances and EfficiencyOur consumers want energy independenceand power free reliability.Wood heaters are natural draft appliances:They continue to work during power failure.They generate theirown powerto create andmaintain draft.The#3 Consumer preference is:User Friendly Controls and Ease of Use!A non catalytic wood stove is designed to pass thei ti t i t W hi t St t t d d ithexisting stringentWashingtonState standardwithone air control lever, “Low to High” with a passivenon-cat secondaryburn system. Easyto use.yA catalytic wood stove can also be designed topass the existing Washington State standard but ithas at minimum one air control lever and a bypassdamper that needs to beproerloperated to burnppyclean.Catalytic Stove Owners say...What Happens if a Typical Cat Appliance isNot Operated Properly?pyOpen Closed BurnedOpen BurnedClosedDamperAlwayswithdamperopen 21%100% 0% 21% 0%Oftenwithdamperopen 22%75% 25% 17% 6%Sometimeswithdamperopen 29%50% 50% 15% 15%Rarelywithdamperopen 19%25% 75% 5% 14%Nithd9%0%100%0%9%21.0013.00Neverwithdamperopen9%0%100%0%9%Average 57% 43%Cat emissions assumptionCat Emissions vs. Non Cat2.50Emissionswithdamperclosed4.5OverallaverageemissionsforatypicalcatapplianceEmissionswithdamperclosedEmissionswithdamperopenypppEmissionsofnon‐catapplianceAssumptions:All appliances have a catalyst in working condition and are at 2.5g/h, as per the currentWashington State limit.Catappliance emissions with the damper open are equivalent to the emissions of an uncertifiedstove at 21 g/h from reference (1)applianceemissionswiththedamperopenareequivalenttotheemissionsofanuncertifiedstoveat21g/hfromreference(1)Reference: (1) Comparison of Particulate Emission Rates from the In-Home Use of Certified Wood Stove Models with U.S. EPACertification Emission Values anda Comparison with Emissions from UncertifiedWood Stoves, James E. Houck, 2011-10-31, Figure10Catalytic stove age and expectedMaintenanceWhat Happens if Cat Appliances are NotM i i d P l ?Maintained Properly?Yes No Working NotWorking CatWorking CatNotWorkingCatreplaced UnreplacedCat LikelyfunctionalCatsCatAppliance<5yrs32% 63% 37% 100% 0% 100% 0%5‐10yrs25% 48% 52% 80% 20% 90% 10%10‐20yrs15% 42% 58% 20% 80% 54% 46%20+yrs13% 36% 64% 0% 100% 36% 64%A70%30%8.0874.521.00Average70%30%Cat Emissions assumptionCat Emissions vs. Non CatOverallaverageemissionsforatypicalcatapplianceEmissionsofnon‐catappliance2.50EmissionswithcatworkingEmissionswithcatnotworkingAssumptions:All appliances with a catalyst inworking condition and are at2.5g/h, as per the currentWashington State limit.Cat appliance emissions with the catalystnot working are equivalent to the emissionsof an uncertified stove at 21 g/h from reference (1)EmissionsofnoncatapplianceEmissionswithcatnotworkingReference: (1) Comparison of Particulate Emission Rates from the In-Home Use of Certified Wood Stove Models with U.S. EPACertification Emission Values anda Comparison with Emissions from UncertifiedWood Stoves, James E. Houck, 2011-10-31, Figure10What are dealers saying aboutC l i h ?Catalyticheaters?From a dealer web site:“...Among the disadvantages is that learning to how to usethe catalyst to get the best efficiency is a bit more tricky thana non-catalytic stove, and many manuals for catalytic stovesarenotveryhelpfulWeatCustomFireplaces&Morehavehelpful.Fireplaceswritten our own "Catalytic Woodstove 101" guide, whichexplains how to get the best out of the catalyst step by stepwhen breaking in a new stove. We also make ourselvesavailable to answer any questions a new stove owner mayhave. Eventually, the catalyst willhave to be replaced....“From: http://www.customfireplacesandmore.com/hearth-articles/catalytic-non-catalytic.htmlCatalytic wood heatersThe Catalytic Hearth Coalition said:Regarding Efficiency: “....catalytic stoves are more efficientthen their non-catalytic counterparts. As you know, this hasbeen recognized for some time as manifested in the defaultefficiencies of 72% for catalyst stoves compared to 63% fornon-catalyst woodstoves in the current NSPS.”The default efficiency were derived based on a smallnumber of appliances 25 years ago.It was annumberofappliances25yearsago.Itwasanacceptable average back then, probably not veryrelevant today.Catalytic CombustorsThe Catalytic Hearth Coalition said:“A longevity study ontwocatalytic appliances was performed andconcluded that after 9 years those cats were still in workingcondition.”Omni tests on the two cats just confirmed that those two catsare in the average for longevity.Our survey revealed that morethan 40% of appliances areburned always or often on bypass. In fact, these cats may onlyhave the equivalent of 4.5 years of usage or no use at all.By comparison, the Stevenson Company survey interviewed atotal of 610 consumers. Sample size precision is estimated at± 4.0 percentage points at a 95% confidence level.Catalytic CombustorsThe Catalytic Hearth Coalition showed a home heatingcomparison between a Washington 4.5g/h non-cat stove with75% efficiency and a 1.76g/h cat stove with 82.5% efficiency.A tE l tirecenvauationof Overall Efficiencyfor EPA CertifiedNon-catalytic WoodHeaters showed nocorrelation betweenemissions andoverall efficiencyoverallefficiency.Ferguson, Andors & company, July 2011Catalytic CombustorsSome thoughts:Cat appliances burn without flames. Some people are lessthan enthusiastic about the flameless fire.Catalytic stoves work well in a laboratory but it ismisleading to believe that the air quality will be protectedwhen the homeowner hasthe very simple choice of notwhenthehomeownerhastheverysimplechoiceofnotengaging the catalyst at all, or ignoring maintenanceneeds.○The Stevenson survey revealed over 40% of homeownersuse their catalytic appliance with the bypass “always” or“often” open.What do We Want?We want the EPA:To continue to regulate wood-heater performance bypromulgatingthe current Washington emission limitsggwhich will have a better impact on the emissionsinventory than forcing higher prices and “userunfriendly” technology:e dyo ogy2.5 g/h for catalytic appliancesto offset the risks of not replacing the catalytic combustorand not using the bypass properly4.5 g/h for non-catalytic appliancesWhat do We Want?We want the EPA:To select a standardized method ofmeasuringandreportingefficiency for wood burningappliances that reflect the way homeowners usetheir wood heater.To measure and report efficiency,not regulateit.What do We Want?We want the EPA:To consider realistic minimum burn rates toaccommodate larger stovesWhat do We Want?We want the EPA:To allowmarket pressuresto direct manufacturersto come up with cost effective, user-friendlytechnologies to reduce the emissions of theirappliances. EPA needs to recognize that bysettingy gthe target for non-cat wood heaters at 4.5g/h, manymanufacturers will end-up with better results.Simply Clean CombustionThank You!