Wood stove 

manu

facturers asking 

for a common sense 

approach to the future.
Concerning the “Standards of

Performance for New ResidentialW

Heaters, New Residential Hydron

Heaters Heaters and Forced‐Air F rnaces Furnaces, a

New Residential Residential Masonry Masonry Heaters Heaters
Who are we?

 We are a group of manufacturers that make and

distribute distribute free standing standing and built-in EPA Certified Certifiedwood fired products in North America:

 Jtl o u NA SBI HearthStone Pacific Energy Napoleon – Wolf Steel ICC – RSF Regency – FPI

 Together, we represent 37% of the total industry 2012 US

shipments of EPA certified appliances.
NSPS 2013

 EPA states that this proposal “updates the 1988 NSPS to 

reflect significant advancements in wood heater technoloand design, broadens the range of residential wood-heatappliances covered by the regulation, and improves and st li i l t ti d ” treamlines implementation procedures.”

 EPA further states that the rule “is expected to require 

manufacturers to redesign wood heaters to be cleaner anlower emitting” and that these changes would provide for better and more efficient performance.
We agree with the NSPS init

1. EPA is tasked to regulate emissions for wood burning 

appliances

2. EPA should set forward reasonable emissions limits3. The industry must do its part at improving air quality whil

providing wood burning appliances to homeowners for por supplemental heat 

4. We should be reporting our appliances’ real efficiency5. New, uncertified wood burning appliances should be a th

the past

6. The sale of any used uncertified stoves should be stoppe
Exempt appliances are availabl

in 2013
What is right to do? We belie

encourasourced

Time near car

heat is bto every

Clean 

Combustion
What is right to do?

 When a tree rots 

naturally or burns, the carbon contained in the woodi l d s release

d

back to the atmosphere. 
How Can We Do It?

We, as manufacturers; want to be able to continue clean woo

d b i urn ng appliances

to all:

 Clean burning heaters, from compact simple stoves fo

smaller budget / need to smaller budget

/ need to larger sophisticated fireplaces 

sophisticated fireplaces 

bigger budgets / need and anything in between

 With or without catal

yst

We, as an industry must: Consider consumer preferences: price, efficiency and 

friendliness

 Always respect EPA regulations
What do we Know?

 We soug py ht out an independent survey firm to 

reveal consumer preferences and help us understand their likely behavior.

 This 15 minute survey conducted in June of 201

This 15 minute survey conducted in June of 201

is the most recent survey conducted in our industry.
Wood Stove/Fireplace Emissions Study

Impact On Product Replacement & Consumer Opinio

7/11/2013
What do We Know?

 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 consume

preferences and expectations to help us then understalikely gp behavior of the general population.

 Sample size precision is estimated at ± 4.0 percentage 

a 95% confidence level. a 95% confidence level.

Note: The survey excluded decorative fireplace owners. It strictly concentrated 

on wood heater owners, g g g, including those using freestanding stoves, built-in stoves,and stoves inserts.
Who Answered our Survey?
Location of the Appliances
Ownership and intent
Purpose and frequency of us
What do consumers care about? 
The #1 Decision Making Reason to 

S l te ec 

a N ew

Wood 

Burni A li ing Appliance is

Price $$Price $$

1. The Stevenson Company Survey was clear.

Price $$Price $$

2. In 2012 sales, HPBA manufacturer’s data shows an 

overall decline (-23.7%) in higher cost Cast Iron EPA wood stove volume with an average wholesale of $1230, while the lower cost Steel EPA wood stoves with an average wholesale of $752 enjoyed an i f 20 6% increase o

f 20.6%. 
Are Homeowners Likely to Spend 500$ 

Premium for Catal

y g tic or “New Technology”?
Are Owners more Likely to Fix Their Current Ap

or Find a Used “Previous Technology” Previous Technology” Applianc

Applianc
The #2 Decision Decision Making Reason to Select 

Wood Burning Product is:

Efficiency!

 Currently reported efficiencies are confusing to Currently reported efficiencies are confusing to

consumers;

 Industry needs and supports the idea of a si

standardized method of calculating and repoeffi i c ency.
Natural Draft Appliances and Efficiency

 Our consumers want energy independen

and power free reliability.

 Wood heaters are natural draft appliance

 They continue to work during power failure. They generate thei

r own powe

r to create a

maintain draft.
The #3 Consumer preference is:

User Friendly Controls and Ease of U

 A non catalytic wood stove is designed to pass t

exi ti t i t W hi t St t t d d it

isting stringent Washington State standard wit

one air control lever, “Low to High” with a passivnon-cat secondary y burn system. Easy to use.

 A catalytic wood stove can also be designed to 

pass the existing Washington State standard buhas at minimum one air control lever and a bypadamp p er that needs to be properly operated to buclean.
Catalytic Stove Owners say...
What Happens if a Typical Cat Appliance 

Not O

p py erated Pro

perl

y

?

Open Closed Burned 

Damper

Always with damper open 21% 100% 0% 21% 

Often with damper open 22% 75% 25% 17% 

Sometimes with damper open 29% 50% 50% 15% 

Rarely with damper open 19% 25% 75% 5% 

N ith

d 9% 0% 100% 0% 

21.00 13.00

Never

with

damper open 9% 0% 100% 0% 

Average 57% 

Cat emissions assumption Cat Emissions vs. Non Cat

2.50

Emissions with damper closed

4.5

Overall average emissions for a

Emissions with damper closed typical cat applianceEmissions with damper open

yp pp

Emissions of non‐cat appliance

Assumptions: All appliances have a catalyst in working condition and are at 2.5g/h, as per the current Washington State limit. Cat appliance emissions with the damper open are equivalent to the emissions of an uncertified appliance emissions with the damper open are equivalent to the emissions of an uncertified stove at 21 g/h fro

stove at 21 g/h fro

Reference: (1) Comparison of Particulate Emission Rates from the In-Home Use of Certified Wood Stove Models 

Certification Emission Values and a Comparison with Emissions from Uncertified Wood Stoves, James E. Houck, 
Catalytic stove age and expected 

Maintenance
What Happens if Cat Appliances are Not 

M i i d P l ? M

aintained Properly

?

Yes No Working Not Working Cat Wor

Cat Cat replaced Unreplaced Cat Like

Appliance

<5 yrs 32% 63% 37% 100% 0% 100% 

5‐10 yrs 25% 48% 52% 80% 20% 90% 

10‐20 yrs 15% 42% 58% 20% 80% 54% 

20+yrs 13% 36% 64% 0% 100% 36% 

A 70% 

8.087

4.5

21.00

Average 70% 

Cat Emissions assumption Cat Emissions vs. Non Cat

Overall average emissions for

a typical cat appliance

Emissions of non‐cat appliance

2.50

Emissions with cat workingEmissions with cat not working

Assumptions: All appliances with a catalyst in working condition and are at 2.5g/h, as per the current Washington State limit. Cat appliance emissions with the catalyst not working are equivalent to the emissions of an uncertified stove at 21 g/

Emissions with cat not working Emissions of non cat appliance

Reference: (1) Comparison of Particulate Emission Rates from the In-Home Use of Certified Wood Stove Models wi

Certification Emission Values and a Comparison with Emissions from Uncertified Wood Stoves, James E. Houck, 20
What are dealers saying about

C l i h ? Catalytic heaters

?

 From a dealer web site:



“...Among the disadvantages is that learning to how to the catalyst to get the best efficiency is a bit more tricky a non-catalytic stove, and many manuals for catalytic stare not very helpful helpful. We at Custom Fireplaces Fireplaces

& More 

written our own "Catalytic Woodstove 101" guide, wexplains how to get the best out of the catalyst step by when breaking in a new stove. We also make ourseavailable to answer any questions a new stove owner have. Eventually, the catalyst will have to be replaced....“

From: http://www.customfireplacesandmore.com/hearth-articles/catalytic-non-catalytic.h
Catalytic wood heaters

 The Catal

ytic Hearth Coalition said:

 Regarding Efficiency: “....catalytic stoves are more effi

then their non-catalytic counterparts. As you know, this been recognized for some time as manifested in the defficiencies of 72% for catalyst stoves compared to 63non-catalyst woodstoves in the current NSPS.”

 The default efficiency were derived based on a 

number of appliances 25 years ago. number of appliances 25 years ago. It was an It was anacceptable average back then, probably not verelevant today. 
Catalytic Combustors

 The Catalytic Hearth Coalition said:

 “A longevity study on two catalytic appliances was performe

concluded that after 9 years those cats were still in working condition.”

 Omni tests on the two cats just confirmed that those two 

are in the average for longevity. 

 Our survey revealed that more than 40% of appliances a

burned always or often on bypass. In fact, these cats may have the equivalent of 4.5 years of usage or no use at all

 By comparison, the Stevenson Company survey interview

total of 610 consumers. Sample size precision is estimat± 4.0 percentage points at a 95% confidence level.
Catalytic Combustors

 The Catalytic Hearth Coalition showed a home heating 

comparison between a Washington 4.5g/h non-cat stove with 75% efficiency and a 1.76g/h cat stove with 82.5% efficiency.

 A t recen E l ti va uation 

of Overall Efficiency for EPA Certified Non-catal

ytic Wood 

Heaters showed no correlation between emissions and overall efficiency overall efficiency.

Ferguson, Andors & company, July 2011 
Catalytic Combustors

 Some thoughts: 

 Cat appliances burn without flames. Some people are 

than enthusiastic about the flameless fire. 

 Catalytic stoves work well in a laboratory but it is 

misleading to believe that the air quality will be protectwhen the homeowner has when the homeowner has the very simple choice of no

the very simple choice of no

engaging the catalyst at all, or ignoring maintenance needs.

○ The Stevenson survey revealed over 40% of homeowners 

use their catalytic appliance with the bypass “always” or “often” o

pen.
What do We Want?

 We want the EPA:

 To continue to regulate wood-heater performa

p gg romul

gatin

g the current Washin

gton emissio

which will have a better impact on the emissioinventory than forcing higher prices and “useru e dy nfrie

n

dly” tec o ogy hn

ology:

2.5 g/h for catalytic appliances 

to offset the risks of not replacing the catalytic comb

and not using the bypass properly

4.5 g/h for non-catalytic appliances
What do We Want?

 We want the EPA:

 To select a standardized method of measurin

and reporting efficiency for wood burning appliances that reflect the way homeowners utheir wood heater.

 To measure and report efficiency, not regulate 
What do We Want?

 We want the EPA:

 To consider realistic minimum burn rates to 

accommodate larger stoves
What do We Want?

 We want the EPA:

 To allow market pressures to direct manufact

to come up with cost effective, use

r-friendly 

technologies to reduce the emissions of their appliances. EPA needs to reco

g y 

nize that b

y s

the target for non-cat wood heaters at 4.5g/h, manufacturers will end-up with better results.
Simply Clean Combustion
Thank You!